Corrective Action Plans

Finding 389359 (2023-001)

Significant Deficiency 2023

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University u...

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw which is effective after the completion of the current semester get processed manually in NSLDS once the semester has ended. To aid in this updated practice, a documented procedure has been established that provides a checklist of steps and collection of internal signatures to be completed for each student who indicates they wish to withdraw from the University. Additionally, we will be engaging a consultant to perform a compliance review with the US Department of Education for Enrollment Reporting. This will ensure that the withdrawal status is promptly provided within the required timeframe. Proposed completion date: February 20, 2024

View Audit 300357

Finding 389349 (2023-002)

Significant Deficiency 2023

Western North Carolina Aids Project, Inc.

NC

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

2023-002 Housing Quality Standards Condition: During testing of tenant files, there were 1 instance where inspection documentation or HQS documentation was missing. Corrective Action: The Housing Coordinator is completing the updated trainings that the HOPWA program published recently in hudexcha...

2023-002 Housing Quality Standards Condition: During testing of tenant files, there were 1 instance where inspection documentation or HQS documentation was missing. Corrective Action: The Housing Coordinator is completing the updated trainings that the HOPWA program published recently in hudexchange.info. An eligibility checklist has been implemented as well, as noted in the previous year’s single audit, which includes housing inspection or HQS documentation as one of the compliance items. In addition, to ensure that all housing staff understands the eligibility requirements, the Housing Coordinator has shared the review checklist with frontline employees, and regularly reviews client files to ensure the records are complete. Lastly, evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Inspection/HQS Records: 5 2022-23 Total Deficient Inspection/HQS Records: 1 WNCAP expects to see continued improvement in subsequent audits.

View Audit 300348

Finding 389348 (2023-001)

Significant Deficiency 2023

Western North Carolina Aids Project, Inc.

NC

Eligibility Significant Deficiency

2023-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to ...

2023-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 -- Missing documentation of housing assistance form. Corrective Action: As outlined in previous year’s corrective action plan, WNCAP has implemented an eligibility checklist to ensure that client records are complete. The Housing Coordinator has shared the review checklist with frontline employees so they can use it as reference when completing intakes and recertifications, and she regularly reviews client files to ensure the records are complete. While the checklist was implemented in the first quarter of 2023, some of the records were created prior to implementation. Going forward, all records for the following audit period will have been created after implementation of the review checklist. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Eligibility Records: 30 2022-23 Total Deficient Eligibility Records: 8 WNCAP expects to see continued improvement in subsequent audits.

View Audit 300348

Finding 389334 (2023-001)

Significant Deficiency 2023

Lake County Crisis Center D/b/a A Safe Place

IL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure t...

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. Update: A Safe Place developed an infrastructure and implemented internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. The Program Administrative Manager will ensure all program performance reports (PPR) will be reviewed and submitted timely.

View Audit 300326

Finding 389321 (2023-001)

Significant Deficiency 2023

Tougaloo College

MS

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid ...

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid Relief, and Economic Security (CARES) Act Program: • There was no evidence provided regarding the submission of the annual and quarterly reports. Recommendation – We recommend that the College ensure reporting requirements are met for all grant programs. Corrective Action – The Office of Fiscal Affairs understands the importance of federal compliance. The U.S. Department of Education was contacted about the late filings. Under federal guidance, the Year 3 quarterly reports were submitted on the College website in January 2024. The annual report for Year 3 will be submitted in July 2024 when the U. S. Department of Education reopens the portal, Annual Report Data Collection Tool.

View Audit 300307

Finding 389281 (2023-001)

Significant Deficiency 2023

Hagerstown Community College

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

View Audit 300295

Finding 388600 (2023-001)

Significant Deficiency 2023

Housing Authority of Joliet

IL

HUD Housing Programs Eligibility Significant Deficiency

The Authority will catalog and maintain all required tenant file documents in accordance with federal requirements and the Authority’s internal policies. Michael Simelton, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenanc...

The Authority will catalog and maintain all required tenant file documents in accordance with federal requirements and the Authority’s internal policies. Michael Simelton, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of April 30, 2024.

View Audit 300285

Finding 388573 (2023-006)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for ...

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has recently made improvements to the process of completing the return to Title IV calculations. This was achieved by providing additional training and workshops offered through the Department of Education. Furthermore, we have also developed a spreadsheet to assist with calculating the returned aid due to withdraw. We will utilize this information to thoroughly double-check our calculations before issuing official documentation. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388572 (2023-005)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has designed a calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. This will be used as a cross-check of days when computing returns. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388571 (2023-004)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the ...

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the applicable period. The university incorrectly calculated the institutional charges within the return to Title IV calculation. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388570 (2023-003)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Reporting Significant Deficiency

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title...

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University is continuing to improve communication between the Registrar's office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed. Anticipated Completion Date- July 1, 2024

View Audit 300264

Finding 388547 (2023-001)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Cheyney University: Additional policies and procedures were implemented to mitigate errors in the future. Pennsylvania Western University: This finding resulted from a combination of staff turnover and the complexity of integration. All grant-related reporting requirements will be reviewed to ensur...

Cheyney University: Additional policies and procedures were implemented to mitigate errors in the future. Pennsylvania Western University: This finding resulted from a combination of staff turnover and the complexity of integration. All grant-related reporting requirements will be reviewed to ensure that they are properly documented and scheduled for completion and review when required by the granting authority.

View Audit 300242

Finding 388544 (2023-005)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month r...

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month reconciled, date reconciled and preparer. The monthly reconciliations will be reviewed and approved by the Director of Financial Aid or the Assistant Director of Financial Aid. The approver will notate the date reviewed and their initial in the reconciliation log. Records of direct loan reconciliations will be retained for 5 years for auditing purposes. Reconciliation procedures will be documented, and employees will receive proper training and support on an on‐going basis.

View Audit 300242

Finding 388538 (2023-004)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will b...

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will be uploaded into our SIS within 1-2 days. When the report is loaded in our SIS, we will review each file to see which files did not transmit to COD. For the files that fail, we will correct the error/issue in our SIS and send the file out to COD in a timely manner for processing. After our Pell reconciliation is complete, we wll review our SIS and COD to ensure records agree between our SIS and COD (award amounts and processing dates). WCU is currently reviewing its policies and procedures around COD reporting and will ensure students' information is reported timely and accurately between our SIS and COD. WCU understands and agrees that the errors identified in the program review relate to Pell Grant disbursement reporting; and agrees, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculation as students' interest accrues based on the disbursement date reported to COD. Going forward, WCU will review the SIS and COD data to ensure that all booked files link to the appropriate dates between our SIS and COD. Kutztown University: We reviewed our policies and procedures for COD reporting. A financial aid resource has implemented a sweep every fourteen days to ensure that compliance with the 15-day rule for PELL reporting is met consistently.

View Audit 300242

Finding 388537 (2023-003)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a stude...

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a student is withdrawing from the University or being administratively withdrawn due to an unofficial withdrawal, the University Records” Office will monitor student accounts to ensure that adjustments made to student records are not overridden by automated procedures. All reporting will be completed through the National Student Clearinghouse. Kutztown University: We re-evaluated policies and procedures to ensure compliance in reporting. We worked with the Registrar’s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so the National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient. Commonwealth University (Lock Haven): Controls have been put in place across multiple offices to ensure that program enrollment effective date and program enrollment status is reported correctly to NSLDS. Actions will include, but are not limited to, timely review of changes and checking data files prior to upload. West Chester University: Initial action has been taken to update the student's record with NSLDS. WCU will also add an additional check to our transmission process to review the file for this specific scenario. We will develop a report from our student information system to assist us in this review.

View Audit 300242

Finding 388536 (2023-002)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monit...

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monitor the time it takes to complete these tasks and make any necessary modifications to support timely reporting to NSLDS. East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure students’ enrollment statuses are being reported to NSLDS through the National Student Clearinghouse. Reporting will occur on a monthly basis by means of the University Records’ Office transmitting a file to the National Student Clearinghouse. The University Records’s Office will monitor student statuses in NSLDS by randomly sampling students reported through the National Student Clearinghouse to ensure the accuracy of data being reported to NSLDS. Kutztown University: We re-evaluated our reporting procedures and worked with the Registrar’s Office to further redefine our process(es). The Registrar’s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient.

View Audit 300242

Finding 388533 (2023-006)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Ch...

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Cheyney University signed an agreement with Financial Aid Services, LLC (FAS) to outsource many of the financial aid related functions. Return to Title IV (R2T4) was one of the functions outsourced. The process to begin outsourcing was started in December 2023. In addition to outsourcing R2T4, the Office of the Registrar will provide the Office of Student Financial Services (SFS) with a list of students who are not registered for each semester. This distribution will culminate with census reporting to PASSHE and allow SFS to notify about repayment and Return to Title IV processes. For students who apply for graduation for a particular semester, a distribution of names, identification numbers, and anticipated graduation semester, will be provided to SFS so that they can complete their exit counseling procedures.

View Audit 300242

Finding 388531 (2023-001)

Significant Deficiency 2023

Cornerstone Montgomery, Inc.

MD

Allowable Costs / Cost Principles Reporting Significant Deficiency

COVID 19 - Demonstration Programs to Improve Community Mental Health Services 93.829 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Explanation of disagreement with audit findi...

COVID 19 - Demonstration Programs to Improve Community Mental Health Services 93.829 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are in the process of re-evaluating the reporting process to ensure documentation is maintained to support the reporting requirements. Name of the contact person responsible for corrective action: Lisa Katz, Chief Program Officer Planned completion date for corrective action plan: Currently underway and planned to be completed by June 30, 2024.

View Audit 300238

Finding 388520 (2023-004)

Significant Deficiency 2023

City of Richmond

VA

Reporting Subrecipient Monitoring Significant Deficiency § 200.303

Recommendation: We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Explanation of disagreement ...

Recommendation: We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: HCD has made it part of a dedicated staff member to input the data into the FSRS system on a timely basis. HCD will also update their process so that all applicants must provide their UEI number. Name(s) of the contact person(s) responsible for corrective action: Sherrill Hampton Planned completion date for corrective action plan: 7/31/24

View Audit 300220

Finding 388519 (2023-003)

Significant Deficiency 2023

City of Richmond

VA

Questioned Costs Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

Recommendation: We recommend that the Department review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. A...

Recommendation: We recommend that the Department review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A correction will be made to reduce the request by the overstated (by 1 day) amount in the 3/31 payroll report. A credit was issued to FEMA for the amount of $19,871.26 on Monday March 13, 2023 in relation to the finding noted. Name(s) of the contact person(s) responsible for corrective action: Angelia Adediran, Deputy Director City of Richmond Fire and Emergency Services

View Audit 300220 Questioned Costs: $1

Finding 388512 (2023-003)

Significant Deficiency 2023

Dupage Housing Authority

IL

Allowable Costs / Cost Principles HUD Housing Programs Reporting

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron...

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron Corbett Completion Date: July 31, 2023

View Audit 300217

Finding 388511 (2023-002)

Significant Deficiency 2023

Dupage Housing Authority

IL

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that...

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that all accounting data is being recorded timely. This will allow us to submit timely financials to HUD. . Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2024

View Audit 300217

Finding 388469 (2023-004)

Significant Deficiency 2023

Saint Elizabeth University

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Cap...

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024

View Audit 300191 Questioned Costs: $1

Finding 388467 (2023-003)

Significant Deficiency 2023

Saint Elizabeth University

NJ

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 300191

Finding 388462 (2023-002)

Significant Deficiency 2023

Saint Elizabeth University

NJ

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are reme...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are remediated and brought into compliance. Some of these have already been remediated. We will work with other departments who administer third party vendor accounts to enforce MFA where there are gaps. A penetration test and the standing up of a tool to continuously monitor our network internally and those of third party vendors are already in startup phases Our information security program and risk assessment will be updated to reflect any recommendations offered by our auditors to fill any existing gaps in the 2023 audit. Person Responsible for Corrective Action Plan: Ron Loneker, Jr., Director, IT Special Projects Anticipated Date of Completion: May 31, 2024

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