Corrective Action Plans

Finding 513997 (2024-005)

Significant Deficiency 2024

NC

Procurement, Suspension & Debarment Significant Deficiency

U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency, Nonmaterial Noncompliance - Procurement Finding 2024-005 – Repeat Finding Criteria or Specific Requirement: Per Section 200.318 of the Uniform...

U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Significant Deficiency, Nonmaterial Noncompliance - Procurement Finding 2024-005 – Repeat Finding Criteria or Specific Requirement: Per Section 200.318 of the Uniform Grant Guidance, a nonfederal entity must use documented procurement procedures for the acquisition of services required under a federal or State award. Condition: During the audit we tested 10 contracts and noted the following: a) There was one (1) instance out of 10 contracts tested where the County did not properly verify the vendor was not suspended or debarred prior to contract execution. b) There were three (3) instances out of 10 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services. Questioned Costs: None. Effect: By not having the required documentation and rationalization in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds. Cause: The County did not ensure all contracts utilized for the grant were contracted and properly documented using the required procurement requirements in accordance with the Uniform Grant Guidance procurement standards. Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or ensure new contracts are executed when Federal or State grant funds are identified to be utilized for the contracts. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: In order to better follow UG requirements, Procurement will incorporate enhanced training on UG requirements for the division and create oversight mechanisms to ensure approval processes include senior level oversight on federally funded spending where the Simplified Acquisition Threshold has been exceeded. Completion Date: February 28, 2025 Responsible Person(s): Teresa Rausch, Procurement Director & David Boyd, Chief Financial Officer

View Audit 332196

Finding 513985 (2024-002)

Significant Deficiency 2024

Mecklenburg County

NC

Questioned Costs Cash Management Period of Performance § 200.1

Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Assistance Listing Number: 14.267 Significant Deficiency, Nonmaterial Noncompliance – Period of Performance Finding 2024-002 Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval bet...

Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Assistance Listing Number: 14.267 Significant Deficiency, Nonmaterial Noncompliance – Period of Performance Finding 2024-002 Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval between the start and end date of a federal award, which may include one or more budget periods.” Condition: For one award, the 2023 grant award project was not closed timely in the general ledger system and the County erroneously recorded fiscal year 2024 grant costs of $1,059 to the project, which was beyond the approved period of performance of the award. Additionally, for one award, the County recorded grant costs of $28,685 to the project, which was beyond the approved period of performance of the award. Effect: By not having the grant project codes properly closed at the end of the period of performance, the County could potentially request reimbursement for costs incurred and recorded beyond the grants approved period of performance from the Federal government. Questioned Costs: $29,744 Cause: The County did not have a formal policy to ensure grant project codes were properly closed and expenditures were not being recorded beyond the grant award’s stated period of performance. Recommendation: We recommend the County should implement a formal policy to ensure all grants are properly closed and no costs are incurred on grants after their period of performance. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Following the end of grant term, June 30th, Shelter Plus Care (SPC) program will ensure all final payments are made out of the grant by mid-August to ensure timely reconciliation. • Grant Management /Revenue Reimbursement Team will send final draw for review and approval by SPC Supervisor and upon confirmation, email communication will be made with Accountant III (within the Budget Team) for final review. • Accountant III will provide Purchase Order by Unit report (PD615) report to SPC program to ensure all POs are closed out. • Accountant III will review PD615 report to ensure deactivation. Ongoing review will take place at least 2 months following the 90-day close-out period. •The SPC/Finance Team will work with staff, supervisors and payroll to ensure all applicable payroll is allocated to proper (active) grant unit and respective entries are processed timely. • When new grant is established, the SPC team will ensure that time posted and approved for SPC admin costs in PeopleSoft are for the correct grant unit/ grant fiscal period as well as ensure that funds are encumbered and paid from correct grant/grant fiscal period. In addition to these steps, ongoing review and monitoring of grant will occur monthly during SPC’s Finance Meeting on the 4th Thursdays of the month and during the CSS Grants Meeting on the 4th Tuesdays of the month. Completion Date: June 30, 2025 Responsible Person(s): Adia Robinson, Clinical Supervisor

View Audit 332196 Questioned Costs: $1

Finding 513968 (2024-001)

Significant Deficiency 2024

Steppingstone, Inc. and Affiliate

MA

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Corrective Action Plan: (unaudited): We agree with the recommendation and have updated the accounting manual. It should also be noted that the Organization has never filed late and has only had this happen once in the history of the Organization which is concurrent with the change in the FAC website...

Corrective Action Plan: (unaudited): We agree with the recommendation and have updated the accounting manual. It should also be noted that the Organization has never filed late and has only had this happen once in the history of the Organization which is concurrent with the change in the FAC website update.

View Audit 332173

Finding 513951 (2024-002)

Significant Deficiency 2024

Barton County Community College

KS

Special Tests & Provisions Student Financial Aid Reporting

SIGNIFICANT DEFICIENCY 2024-002 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that 6 of the 60 students tested did not have an enrollment status change properly reported. Re...

SIGNIFICANT DEFICIENCY 2024-002 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that 6 of the 60 students tested did not have an enrollment status change properly reported. Recommendation We recommend that the College review its controls to ensure that accurate enrollment information is reported to NSLDS. Comments on the Finding Recommendation Barton County Community College understands the finding. Action Taken Barton County Community College has updated its policies and procedures to reflect emphasis on reporting the unofficial withdrawals to NSLDS within 30 days. Barton’s Financial Aid Office will perform a quality assurance review of NSLDS to ensure that the unofficial withdrawals have been reported. Additionally, Barton’s Registrar will perform a periodic check to see if other enrollment reporting is reflected accurately in the National Student Clearinghouse and the National Student Loan Data System. Date of implementation: This has been implemented for the 2024-2025 award year.

View Audit 332157

Finding 513936 (2024-003)

Significant Deficiency 2024

Town of Cary

NC

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

Finding: 2024-003 – Federal Award - Internal Control Over Compliance Auditor Recommendation: Cary should implement a review process over the reimbursement request prior to the submission to NCDOT where staff prepares, and a manager reviews the request. Evidence of performance and review of these req...

Finding: 2024-003 – Federal Award - Internal Control Over Compliance Auditor Recommendation: Cary should implement a review process over the reimbursement request prior to the submission to NCDOT where staff prepares, and a manager reviews the request. Evidence of performance and review of these requests should be maintained. Corrective Action: Cary will establish a documented review process where staff prepares and manager reviews reimbursement requests prior to the submission to any federal or state grantor. Responsible Parties: Finance and Respective Departments Date of Implementation: July 1, 2025

View Audit 332152

Finding 513880 (2024-001)

Significant Deficiency 2024

Housing Authority of Kansas City Kansas

RI

HUD Housing Programs Special Tests & Provisions Significant Deficiency

2024-001 - Public Housing Waiting List Auditee’s Response and Planned Corrective Action We acknowledge that this issue arose due to a software problem. To enhance our document management, we are taking the following steps: implementing regular system maintenance and updates, providing enhanced sta...

2024-001 - Public Housing Waiting List Auditee’s Response and Planned Corrective Action We acknowledge that this issue arose due to a software problem. To enhance our document management, we are taking the following steps: implementing regular system maintenance and updates, providing enhanced staff training, and establishing a backup procedure for critical documents. Planned Implementation Date of Corrective Action: April 1, 2024 Person Responsible for Corrective Action: Johnella Miller, Resident Selector

View Audit 331937

Finding 513877 (2024-001)

Significant Deficiency 2024

Yorktown Central School District

NY

Eligibility Significant Deficiency Internal Control / Segregation of Duties

We acknowledge and accept the findings presented above. The District will immedicately implement an additional detailed review by Denise Zapata, District Accountant, of the support worksheets and calculators for future maintenance of effort submissions, beginning with the compliance calculator that...

We acknowledge and accept the findings presented above. The District will immedicately implement an additional detailed review by Denise Zapata, District Accountant, of the support worksheets and calculators for future maintenance of effort submissions, beginning with the compliance calculator that is due March 31, 2025. Per guidance received from the State, the District will correct the 2022-23 compliance information on the compliance calculator that is due March.

View Audit 331917

Finding 513861 (2024-003)

Significant Deficiency 2024

Arlington Baptist University

CO

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Lack of Documentation of Exit Counseling Planned Corrective Action: Current SIS is set to trigger the Exit Counseling to all students that are coded anything other than E (Enrolled). The Registrar updates all student files with any enrollment changes triggering the email to go to the student. The FA...

Lack of Documentation of Exit Counseling Planned Corrective Action: Current SIS is set to trigger the Exit Counseling to all students that are coded anything other than E (Enrolled). The Registrar updates all student files with any enrollment changes triggering the email to go to the student. The FA Director will run a report in the middle of each term to pick up any students that may have been missed by the Registrar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877

Finding 513859 (2024-002)

Significant Deficiency 2024

Arlington Baptist University

CO

Questioned Costs Student Financial Aid Significant Deficiency

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. T...

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. The calendar for 2023-2024 was updated immediately and all calculations were processed and adjustments made. The ABU director has now taken NASFAA R2T4 Specialist training and is in charge of updating and maintaining the calendar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877 Questioned Costs: $1

Finding 513853 (2024-001)

Significant Deficiency 2024

Carroll Community College

MD

Reporting Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting...

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After being made aware of the NSLDS calculation for programs reported that aren’t reported in years, we looked into solving the issue. We learned that there is a screen within our student information system that sets the default time to years rather than months. Our degree programs prior to 2017 were entered into that screen but degree programs after that time and all of our certificate programs, needed to be calculated as years and entered into our SIS. We did a small trial sample of adjusting three programs in the spring to make sure the changes did not cause any issues with the Clearinghouse and NSLDS. When the data proved to be transmitted and corrected in both systems without issue, we tackled the rest of the programs at the start of this fall. We worked with the Clearinghouse to notify them that we were going to be adjusting a large number of programs that were effecting many student records. They did some alignment of our programs on their end to make the data transition go smoothly to the NSLDS. Issues with reported program lengths having the additional calculation should no longer. We have built in processes to make sure this step will be taken for any new programs. Name(s) of the contact person(s) responsible for corrective action: Greg Bricca, Director of Institutional Effectiveness

View Audit 331869

Finding 513831 (2024-001)

Significant Deficiency 2024

Doane University

NE

Student Financial Aid Subrecipient Monitoring Significant Deficiency

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an em...

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an email confirmation. Name(s) of Contact Person(s) Responsible for Corrective Action: Federico Peña Jr. (Fred), Financial Aid Director Anticipated Completion Date: November 6, 2024

View Audit 331806

Finding 513819 (2024-003)

Significant Deficiency 2024

Owen-Withee School District

WI

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of disagreement with audit finding: There is no ...

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The preparer is the bookkeeper and when she submits the claim she then needs to have approval from the superintendent to approve the claim to DPI. This way there are two eyes on the claim to see if the items that are claimed are accurate with the grants qualifications. Name(s) of the contact person(s) responsible for corrective action: Stacy Rasmussen Planned completion date for corrective action plan: 11/30/2024

View Audit 331785

Finding 513797 (2024-004)

Significant Deficiency 2024

School of Excellence in Education

TX

Cash Management Reporting School Nutrition Programs

No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation ...

No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.

View Audit 331756

Finding 513795 (2024-003)

Significant Deficiency 2024

School of Excellence in Education

TX

Allowable Costs / Cost Principles Cash Management Reporting

No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage i...

No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage in the accounting system to the approved percentages in the semi-annual time and effort logs to verify accuracy. These improved internal procedures will provide proper compliance over allowable costs. Annual audit of all grant-funded employee positions at the start of each school year, reviewed by grants team, HR, and accounting to verify accuracy of all employee costing allocations to grants.

View Audit 331756

Finding 513766 (2024-001)

Significant Deficiency 2024

Rocky Mountain Human Services

CO

Eligibility Reporting Significant Deficiency

As of June 30, 2024, RMHS has implemented procedures to ensure participants are receiving timely notifications for the need to recertify and has taken steps to ensure the client management software is functioning properly.

View Audit 331695

Finding 513760 (2024-001)

Significant Deficiency 2024

St. Catherine University

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There i...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar's Office partnered with IT to automate the transmission of enrollment and graduation files to the National Student Clearinghouse to avoid late submissions or confusion about which branch the transmission is reporting. They have been set up to be sent on the same day each month, rather than being sent manually by a staff member. Several staff members met with our NSC representative to review the transmission schedule to ensure the selected dates will lead to timely submissions. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar Planned completion date for corrective action plan: December 2024

View Audit 331691

Finding 513752 (2024-001)

Significant Deficiency 2024

Boys and Girls Clubs of Metro South, Inc.

MA

Significant Deficiency Internal Control / Segregation of Duties

2024-001 Significant Deficiency in Internal Control over Financial Reporting - Payroll Processing Recommendation: The organization should ensure personnel overseeing the payroll process are appropriately trained. In addition, we recommend that the entity add an additional level of review to ensure ...

2024-001 Significant Deficiency in Internal Control over Financial Reporting - Payroll Processing Recommendation: The organization should ensure personnel overseeing the payroll process are appropriately trained. In addition, we recommend that the entity add an additional level of review to ensure such errors do not repeat. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We have taken the following steps to respond to the noted finding: We have restructured the department to ensure all personnel have appropriate skills and knowledge to perform their role in the processing of payroll. In addition, the payroll information being transmitted for processing is reviewed by the CFO or designated approver on a regular basis. Name(s) of the contact person(s) responsible for corrective action: Alex Marshall, CFO Planned completion date for corrective action plan: The completion date for the corrective action plan occurred in August 2024. Therefore, it has been remediated as of the date of this submission.

View Audit 331664

Finding 513748 (2024-006)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Explanation of disagreement with audit finding: There is no disagreement with the...

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Title V Grant personnel will submit awards to the Financial Aid Office for official award letter notice, adhering to existing internal control policy regarding scholarship awards. Name(s) of the contact person(s) responsible for corrective action: Connie Owens and Dasha Smith Planned completion date for corrective action plan: January 31, 2025

View Audit 331630

Finding 513740 (2024-004)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 ...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar reviews an error report each month, resolves the errors, and then submits the report to NSLDS. NSLDS responds with an error resolution report, which is then used to resolve any further issues, and confirm the final reporting to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513738 (2024-002)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Eligibility Procurement, Suspension & Debarment Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding: The Registrar's Office procedure will be to convert clock hours to credit hours to avoid this situation moving forward. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513686 (2024-006)

Significant Deficiency 2024

Great Hearts America - Texas

TX

Allowable Costs / Cost Principles Significant Deficiency

Finding #2024-006 – Allowable Costs – Significant Deficiency. Applicable federal program: U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Provide additional training to employees on codi...

Finding #2024-006 – Allowable Costs – Significant Deficiency. Applicable federal program: U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Provide additional training to employees on coding and the determination of allowable costs. Planned corrective action: The Senior Director of Federal Programs is now reporting to the Vice President of Finance. She will work with the accounting team to ensure only allowable costs are charged to the IDEA, Part B program. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

View Audit 331593

Finding 513677 (2024-004)

Significant Deficiency 2024

Great Hearts America - Texas

TX

School Nutrition Programs Internal Control / Segregation of Duties Reporting

Findings #2024-002 and #2024-004 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Cont...

Findings #2024-002 and #2024-004 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Contract #’s: 202423N109946 and 202222N109946, U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Reemphasize the need for timely analysis and reconciliations of the balance sheet accounts. Planned corrective action: The School will perform timely analysis and reconciliation of the balance sheet accounts in accordance with the organization’s policies and procedures. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

View Audit 331593

Finding 513676 (2024-003)

Significant Deficiency 2024

Great Hearts America - Texas

TX

School Nutrition Programs Allowable Costs / Cost Principles Significant Deficiency

Findings #2024-001 and #2024-003 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Cont...

Findings #2024-001 and #2024-003 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Contract #’s: 202423N109946 and 202222N109946, U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Develop procedures to reconcile accounts payable batches to the related check run, restrict set up of vendors in the check processing application, and develop budget versus actual reporting for the corporate office. Planned corrective action: Management has already developed a process to reconcile accounts payable batches extracted from the Concur system to the related check run in the Ascender general ledger system. In addition, management will create a separation of duties for bank reconciliations and the setup of new vendors. Our financial analyst will also consistently develop budget versus actual reports for the corporate office as is done for the schools. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

View Audit 331593

Finding 513661 (2024-002)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Subrecipient Monitoring Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonst...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

View Audit 331568

Finding 513656 (2024-001)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not...

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not returned within 45 days of withdrawal. The withdrawal process by the student and academic staff was not completed according to process or timeframe. The course deregistration and withdrawal process for a traditional undergraduate student did not occur following standard procedures or timeframe. The Registrar’s Office entered two different course deregistration dates, within the two-week add/drop period, into the student information system and the withdrawal was entered nearly 60 days after the first day of class. The withdrawal and leave of absence reports generated daily and enrollment adjustment report generated weekly had inadequate queries to catch this complicated course deregistration and withdrawal situation to trigger timely R2T4 calculation and return of federal funding. Following this finding, the Financial Aid Office identified the reporting deficiencies and started dialog with the Registrar’s Office and Information Technology regarding student information system screens and fields being used by the Registrar’s Office that need to be adjusted on the reports. The Registrar’s Office understands the interdependency between its office and the Financial Aid Office with regards to enrollment adjustments and completing an R2T4 calculation, returning federal funding, monitoring Common Origination and Disbursement transmission and any necessary communication with students. With daily and weekly monitoring of said reports, and the Registrar’s Office proactively notifying the Financial Aid Office of any enrollment adjustments that are nearing the R2T4 deadlines rather than solely relying on reports, the Financial Aid Office will be positioned to be compliant with the federal deadlines. The Financial Aid Office will begin a two-person review of calculation and funding return and a recorded acknowledgement of such. Name of Contact Person: Kim Johnson, Vice President for Enrollment Management, 714-966-5415 Projected Completion Date: Review of all fall 2024 enrollment adjustment/withdrawal/leave of absence students after the first day of class (August 26, 2024) will be done by the vice president for enrollment management (serving as director of financial aid) and assistant director during November 2024. Going forward, said two-person review will be done daily by the assistant director and at a minimum biweekly by a senior manager.

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