Corrective Action Plans

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Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented proce...
Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.
Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: The auditors 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 different from the individual responsib...
Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: The auditors 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 different from the individual responsible for preparing, even when there are gaps of coverage in preparer and reviewer positions, and that the review and approval happens prior to submitting the reports to the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District acknowledges the oversight in the separation of duties for preparation and reviewing of reports. Corrective measures have been implemented to require assignment of a preparer different from the approver before finalizing the report. The procedures for submitting monthly claims have been updated to include submitting the report to the Finance Director for review and approval prior to submission. The Finance Director has added a monthly calendar reminder to review claim submission reports as part of the internal control process. Name(s) of the contact person(s) responsible for corrective action: Steven Van Wyhe Planned completion date for corrective action plan: Immediately
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it shoul...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it should have been. There is a chance that the claim was done for the correct amount, but the supporting documentation shows that the District claimed less than they were allowed to. The District is going to ensure that all totals are subtotaled correctly in the future and double checked before the claim request is made. The persons responsible for the corrective action are Jack Ledford, the Food Service Director and Katrina Bontekoe, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that funds requested for meal reimbursements agree to total meals served.
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of E...
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.
We concur with the observations and recommendations as placed forth by our auditors – KCM. In addition to staff turnover, there was also USDA Account Executive turnover. We had reached out to alert the new Account Executive, Marijane Gunter, we would be delayed and are currently working on getting t...
We concur with the observations and recommendations as placed forth by our auditors – KCM. In addition to staff turnover, there was also USDA Account Executive turnover. We had reached out to alert the new Account Executive, Marijane Gunter, we would be delayed and are currently working on getting the appropriate forms filed.
Management will work with the fiscal gaent ot create and maintain a separate general ledger.
Management will work with the fiscal gaent ot create and maintain a separate general ledger.
Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRT...
Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRTMST, a baseline process in Ellucian Banner, the District’s Enterprise Resource Planning system, to calculate or update a student’s enrollment time status, which is the date when a change occurred in the enrollment of a student due to either registering in a class(es) or withdrawing from a class(es). The enrollment time status date is included in the enrollment file submitted to NSC. NSC then submits the enrollment information to the National Student Loan Data System (NSLDS). The discrepancy identified for the nine students was between a withdrawal date in Banner versus the enrollment time status date reported to NSC/NSLDS, which was the Banner calculated date. Because of the timing of when the SFRTMST process was ran, some students’ enrollment time status date did not match the registration activity date/enrollment effective date in Banner. After conducting research using the Ellucian Customer Center, the District identified a resolution to address this issue and has already implemented it for Fall 2025. To ensure that the students’ enrollment time status date reported to NSC/NSLDS matches the students’ effective date of their registration activity in Banner, the District activated the Calculate Time Status (Indicator) in SOATERM, a Banner setup, for Fall 2025 and will do so for all terms moving forward. Per Ellucian, when this indicator is set to “Y” a dynamic time status calculation will take place. The District verified that this process works. The issue has been resolved. In addition, the dates for the nine students were corrected in NSLDS. It is important to note that this issue has had no financial impact on the District. The students have been disbursed the correct amount of financial aid. The calculation of financial aid to be disbursed is not based on the enrollment dates reported to NSC and NSLDS.
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were ...
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were duplicated. The duplication was caused by human error during an internal staff transition within the Family and Community Engagement (FACE) department. This led the new manager to incorrectly report employee home visit logs twice. The FACE team will add internal controls during staff transitions to ensure documentation is not duplicated. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: January 1, 2026
2025-001 REPORTING Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Condition/Context: The District did not accurately support the student counts reported within it’s impact aid application for student enrollment Criteria: Section 7003 (OMB No. 1810-0687) Eac...
2025-001 REPORTING Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Condition/Context: The District did not accurately support the student counts reported within it’s impact aid application for student enrollment Criteria: Section 7003 (OMB No. 1810-0687) Each year an LEA must submit this application, which provides the following information: counts of federally connected children in various categories, membership and average daily attendance data, and information on expenditures for children with disabilities. Effect: The District was not in compliance with the reporting requirement. The application noted a student count of 1,055, and the support provided denoted a student count of 1,062. Cause: The District did not have the adequate review procedures in place to ensure that student enrollment were accurately reported and verified. Corrective Action Plan: Management has developed procedures to ensure student enrollment data is maintained to support accurate reporting, and the data is reviewed and approved. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Clementina Carlyle, SFO, Chief Financial Officer
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time...
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time and effort.
Incorrect Pell Calculations Condition: The University did not properly award Pell for the Summer term under the new enrollment intensity calculation requirements. Planned Corrective Action: This is an isolated error on the part of the Financial Aid Office staff. In review of the new Pell grant calcu...
Incorrect Pell Calculations Condition: The University did not properly award Pell for the Summer term under the new enrollment intensity calculation requirements. Planned Corrective Action: This is an isolated error on the part of the Financial Aid Office staff. In review of the new Pell grant calculations staff members misinterpreted summer Pell regulations. During implementation of the new system software, Pell calculations were believed to be automatic. In subsequent years staff members will review policies for summer programs, participate in training sessions, seminars and workshops, to ensure they understand the rules, regulations and guidelines as they apply to enrollment intensity regulations, in order to manually adjust Pell amounts for part-time students. Person Responsible for Corrective Action Plan: Amanda McLaughlin, Assistant Vice President of Financial Aid; Miranda Lumley Associate Director of Financial Aid Anticipated Date of Completion: Fall of 2025 prior to end of the term and awarding aid for upcoming semesters in the 2025-26 award year.
Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: As of June 30, 2025 management did not perform the proper calculations for the debt service coverage ratio in accordance with the commitm...
Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: As of June 30, 2025 management did not perform the proper calculations for the debt service coverage ratio in accordance with the commitment letter. Additionally, the required debt service coverage ratio and required working capital amount were not presented to the board to ensure compliance is obtained. Responsible Individuals: Vicki Jensen, Chief Financial Officer Corrective Action Plan: The Platte Health Center will perform debt service ratio and working capital calculations, as required in the loan agreement. The calculations will be performed by the CFO as part of the year-end process. The CFO will provide a report to the Board of Directors and it will be noted in the official meeting minutes. Anticipated Completion Date: June 30, 2026.
Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...
Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter
Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation ...
Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.
Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline sh...
Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline shorter than the 14-day federal limit. Additionally, the CFO, Controller, and Student Accounts Coordinator will obtain training on the timing and documentation requirements under 34 CFR §668.164(h).
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.
The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval...
The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval processes, and documentation requirements for federal programs. 2. Pre-approval and Documentation: All expenditures charged to federal awards must receive prior approval from the Program Director and Business Manager, accompanied by invoices, purchase orders, and justification forms referencing the applicable federal cost principle. 3. Monthly Monitoring: The Business Manager will review program expenditures monthly for compliance with allowable cost principles and promptly correct any mischarges. 4. Training: Federal program staff and members of the CSG grants Committee will receive annual training on allowable costs, cost allocation, and time-and effort reporting.
The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue ...
The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corre...
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corrective Action Plan : The Registrar’s office generates enrollment reports every three (3) weeks and they are sent to NSLDS. These reports allow for frequent degree of enrollment reporting to correct this type of error. These changes are in place and have taken effect immediately. Name(s) of Contact Person(s) Responsible for Corrective Action: Rocio De Leon, Registrar Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will co...
Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will continue to review and adhere to our procedures for refunding awards, and the Financial Aid office will formally document the weekly review of the Return of Title IV funds. Name(s) of Contact Person(s) Responsible for Corrective Action: La Royce Housley, Director of Financial Aid Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025
SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendat...
SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendation We recommend that the College review and update its policies to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding For the issue with an institutional charge incorrectly considered in the R2T4 calculation, this was due to a Federal Direct Parent PLUS Loan that was processed and a refund to the parent. Only seven of these loans were processed in the aid year of 2024-25, and there were no other R2T4 situations that involved a Federal Direct Parent PLUS Loan. The refund to the parent was shown at the top of the Banner form while student refunds show at the bottom of the Banner form. Due to the rarity of these loans being included in the calculation and the variation of where this charge is shown in Banner, this was missed. Barton personnel are now aware of where to look for this in these very rare cases. For the situation where the incorrect starting date was identified, there was human error when that was entered. Barton does have a quality assurance process to double check all dates on the Banner withdrawal form, and the R2T4 calculation spreadsheet, however, this review will now extend to checking the enrollment dates in a second Banner form. Action Taken Since the 2024-25 aid year was still open, both instances were corrected. Barton’s Director of Financial Aid has made all personnel aware of the issues and has revised the quality assurance review to watch for these issues.
Moving to Work Demonstration Program -Assistance Listing No. 14.881 Recommendation: We recommend that management assign a designated individual to ensure rent reasonableness, income verification, and recertifications are completed accurately and on time, in accordance with HUD guidelines and the Aut...
Moving to Work Demonstration Program -Assistance Listing No. 14.881 Recommendation: We recommend that management assign a designated individual to ensure rent reasonableness, income verification, and recertifications are completed accurately and on time, in accordance with HUD guidelines and the Authority's administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Director of HCV Program Administration and Ass istant Director of HCV Program Administration will be in charge of reviewing all Rent Reasonableness. Name(s) of the contact person(s) responsible for corrective action: Teresa J. Gonzalez, and Darrell Mciver. Planned completion date for corrective action plan: Effective immediately.
Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are 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 respo...
Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are 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: Starting in January 2026, the Registrar’s Office will be performing the monthly reporting. In preparation for this change in responsibilities, Student Financial Aid has provided training to multiple individuals in the Registrar’s Office along with detailed documented procedures. Student Financial Aid and the Registrar’s Office will coordinate responses/requests from NSLDS. Name(s) of the contact person(s) responsible for corrective action: Sheila Tolley, Executive Registrar and Nick Anderson, Director of Financial Aid Planned completion date for corrective action plan: Spring Semester 2026
Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...
Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026
Finding 2025-005 Lack of Internal Controls over Activities Allowed or Unallowed, Allowable Costs/Cost Principles Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Invoices will be approved for payment by the person who receives the product and then approved also by th...
Finding 2025-005 Lack of Internal Controls over Activities Allowed or Unallowed, Allowable Costs/Cost Principles Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Invoices will be approved for payment by the person who receives the product and then approved also by the food service coordinator. No unallowable costs will be paid for with food service revenue. Proposed Completion Date: Fiscal Year 2026.
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