Corrective Action Plans

Finding 387663 (2023-001)

Significant Deficiency 2023

FL

Questioned Costs Student Financial Aid Significant Deficiency

Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with ...

Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university is researching ways to ensure accuracy in the data entry of withdrawal dates into the system of record. The current process is manual data entry by advising staff creating an opportunity for human input error. Options are being reviewed and could include an integration between the system of record and the eForm the data is collected on or a report that will compare the withdrawal date entered into the system to the source data. Repeat finding, see 2022-002: CAP Completed. Prior year finding had to do with manual data entry directly into the R2T4 calculation. No repeat findings were found in this area of data entry. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: December 2023

View Audit 299743 Questioned Costs: $1

Finding 387661 (2023-001)

Significant Deficiency 2023

Marymount Manhattan College

NY

Student Financial Aid Special Tests & Provisions Eligibility

Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basin...

Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basing program length by weeks. With respect to the program change date record retention issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include retraining of staff to reinforce the necessity of retaining the records, providing adequate secure storage facilities for paper records and conducting regular quality control exercises to ensure that this issue does not re-occur. Proposed completion date: June 30, 2024

View Audit 299742

Finding 387659 (2023-001)

Significant Deficiency 2023

Middlebury College

VT

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Lo...

Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Loans ended September 30, 2017. Middlebury has not lent Perkins Loans to borrowers since the 2017-18 academic year, thus not creating any new Perkins Loan promissory notes.

View Audit 299732

Finding 387601 (2023-004)

Significant Deficiency 2023

Plan International Inc.

NY

Reporting Significant Deficiency

Ref 2023-004: Foreign exchange translation methodology (repeat of prior year findings 2022-004, 2021-005, 2020-006 and 2019-006) (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23, FY22, FY21, FY20 and FY19 Pass-through: All applicable M...

Ref 2023-004: Foreign exchange translation methodology (repeat of prior year findings 2022-004, 2021-005, 2020-006 and 2019-006) (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23, FY22, FY21, FY20 and FY19 Pass-through: All applicable Management comments: Management is working with IT to implement enhancements to the ERP system to address improvements to the remeasurement process. We are targeting implementation of daily exchange rates in our ERP system by June 30, 2024. To address issues related to the translation of functional currency balances and transactions from SAP into PII’s reporting currency management is developing a new methodology within the BPC consolidation system which will be effective for FY24 closing. In parallel, management is reviewing the financial manual to provide additional guidance on the correct treatment of foreign exchange transactions including the translation from functional currency to presentation currency in line with US GAAP Accounting Standards. The system changes and updates to the manual will be accompanied by training to be rolled out to all relevant staff to ensure that the revised guidance is understood and adhered to. (Corrective actions introduced in FY24 will be project planned and reviewed through the FY24 year-end close to a final resolution with an anticipated closure by 30 June, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)

View Audit 299718

Finding 387600 (2023-003)

Significant Deficiency 2023

Plan International Inc.

NY

Reporting Significant Deficiency

Ref 2023-003: Classification, completeness, and accuracy of bank accounts (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23 Pass-through: All applicable Management comments: Management is aware of the importance of maintaining complete ...

Ref 2023-003: Classification, completeness, and accuracy of bank accounts (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23 Pass-through: All applicable Management comments: Management is aware of the importance of maintaining complete and accurate list of bank accounts. During FY24, Management will implement the following changes: 1. The Global Finance Manual will be updated to ensure that there is an appropriate level of review of bank opening and closing at CO, RH and GH level, specifically addressing the point around receiving a formal closure letter from the bank when accounts are closed. 2. A new SAP report which generates a list of all bank accounts including opening and closing dates and account name and number will be developed during FY24. The new report will include a consolidated bank reconciliation for all bank accounts which will have the effect of simplifying the review at CO, RH and GH level. 3. Global Hub has been working with the Global Assurance team to implement an internal review of the bank reconciliation, listing and confirmation of the balances with Banks to ensure accuracy, completion, and existence of bank balances. (Corrective actions introduced in FY24 will be project planned and reviewed through the FY24 year-end close to a final resolution with an anticipated closure by 30 June, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)

View Audit 299718

Finding 387592 (2023-002)

Significant Deficiency 2023

Palomar Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the neces...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the necessary procedures for returning Title IV funds. Implementation Date: 6-23-23

View Audit 299712

Finding 387586 (2023-001)

Significant Deficiency 2023

Palomar Community College District

CA

Student Financial Aid Period of Performance Reporting

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submittin...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submitting NSLDS reports. Implementation Date: In Progress

View Audit 299712

Finding 387578 (2023-001)

Significant Deficiency 2023

College of Mount Saint Vincent

NY

Student Financial Aid Reporting Significant Deficiency

The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring ...

The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring and summer sessions. We have identified the multiple start dates as a primary challenge with timely reporting and have initiated corrective actions to synchronize program dates more closely with the standard academic calendar. This includes the phasing out of a summer header student cohort to prevent similar issues in the 2024-2025 academic year. A bi-weekly reconciliation report has been created to review activity and identify early discrepancies to maintain better internal controls. During the 2021-2022 aid years, the Financial Aid office had four Financial Aid directors with different approaches to aid awarding strategy. The current Director is focused on refining processes to enhance internal controls. Additionally, the College recognized a need for staff professional development and training and engaged a Financial Aid consultant to review our systems and processes. The Financial Aid consultant now conducts quarterly assessments to help us maintain our setups and provides ongoing training for our team. These steps are in line with best practices and are part of our commitment to minimizing errors and conducting timely financial aid reporting. The College has made significant improvements. The number of selected records failing the 15-day COD reporting window decreased from 15 in FY22 to 4 in FY23.

View Audit 299699

Finding 387569 (2023-003)

Significant Deficiency 2023

Pennsylvania Academy of the Fine Arts

PA

Student Financial Aid Reporting Significant Deficiency

Recommendation: The Academy should develop procedures to have the financial aid and financial accounting information systems reconciled monthly. Corrective Action: A policy to review and reconcile the FISAP data between Financial Aid and Finance departments, prior to submitting the FISAP to the Depa...

Recommendation: The Academy should develop procedures to have the financial aid and financial accounting information systems reconciled monthly. Corrective Action: A policy to review and reconcile the FISAP data between Financial Aid and Finance departments, prior to submitting the FISAP to the Department of Education, will be implemented. Person Responsible for Corrective Action: Eric Pryor, President and CEO

View Audit 299686

Finding 387568 (2023-002)

Significant Deficiency 2023

Pennsylvania Academy of the Fine Arts

PA

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

Recommendation: The Academy should review and revise its controls over compliance to ensure that the School Account Statement reconciliations are performed monthly. Corrective Action: A procedure to reconcile School Account Statements monthly will be implemented. Person Responsible for Corrective Ac...

Recommendation: The Academy should review and revise its controls over compliance to ensure that the School Account Statement reconciliations are performed monthly. Corrective Action: A procedure to reconcile School Account Statements monthly will be implemented. Person Responsible for Corrective Action: Eric Pryor, President and CEO Anticipated Completion Date for Corrective Action: The Corrective Action will be immediately implemented in response to the auditor’s recommendation.

View Audit 299686

Finding 387556 (2023-001)

Significant Deficiency 2023

National Centers for Learning Excellence, Inc.

WI

Questioned Costs Allowable Costs / Cost Principles Reporting

Action taken in response to finding: NCLE will: 1) Run a list (through Paychex) of employees that have been terminated and/or hired within the last pay period prior and the current pay period 2) Identify names on list with any employee who is currently receiving pay within the current pay period. 3...

Action taken in response to finding: NCLE will: 1) Run a list (through Paychex) of employees that have been terminated and/or hired within the last pay period prior and the current pay period 2) Identify names on list with any employee who is currently receiving pay within the current pay period. 3) Any employee on the list whether new hire and/or terminated verify that the amount being paid to the employee is correct. 4) Termed employee may still have ELT (Earned Leave Time) accrued and is due payment within the current pay period. The termed employee may have worked partial hours within the current pay period. Salary termed employee is due full payment within the last pay period the employee worked. 5) A new hire employee who is salaried will receive a pro-rated rate of pay for the first payroll. 6) Upon termination and/or new hire being enacted Management will forward termination and/or new hire notices to the Human Resource Department. 7) Human Resource Department will be entering (into Paychex) termination and/or new hire data as soon as they are received from management Names of the contact persons responsible for corrective action: Sue Firkus, CFO and Tim Nolan CEO Planned completion date for corrective action plan: Approved by our Board and Policy Council on February 26, 2024. Will be implemented immediately following this approval. The full current year within which we are operating as well as each upcoming fiscal year will be covered by this plan.

View Audit 299674 Questioned Costs: $1

Finding 387474 (2023-001)

Significant Deficiency 2023

Blue Ridge Healthcare Hospitals, INC

NC

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency

Department of Health and Human Services BRHC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 through June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered con...

Department of Health and Human Services BRHC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 through 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 Health and Human Services 2023-001 Provider Relief Funding – Assistance Listing No. 93.498 Recommendation: We recommend the Organization review calculations to ensure that the proper amounts are used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Blue Ridge’s inventory system reports item prices based on average purchase price. Blue Ridge’s materials management staff has a process in place to update inventory item prices on an as-needed basis. In the event a price is in error, the issuance price is manually updated with a credit given to the department where expense was incorrectly reported. For future reporting of inventory issuance costs, an additional level of review will be added to validate cost reported are accurate. Name(s) of the contact person(s) responsible for corrective action: Pat Moll, Chief Financial Officer Planned completion date for corrective action plan: 03/27/2024 If the Department of Health and Human Services has questions regarding this plan, please call Pat Moll, CFO at 828-580-5003.

View Audit 299640 Questioned Costs: $1

Finding 387414 (2023-003)

Significant Deficiency 2023

Change, Inc.

MN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Respo...

Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We are working to formalize this process by creating a written participant file review policy and procedure. Anticipated Completion Date: March 31, 2024

View Audit 299566

Finding 387391 (2023-001)

Significant Deficiency 2023

Change, Inc.

MN

Internal Control / Segregation of Duties Significant Deficiency

Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible...

Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We will be updating our cash receipts process as part of an overall review of our accounting and financial policies and procedures that will include improvements in our internal control system. Anticipated Completion Date: Updated accounting and finance policies and procedures will be completed and implemented by the end of FY24.

View Audit 299566

Finding 387390 (2023-001)

Significant Deficiency 2023

Women in Safe Homes, Inc.

AK

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expe...

Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expenditure approval process, as well as the process for maintaining records supporting all transactions. The policies in place require WISH management to approve all expenditures utilizing a requisition request form which includes a signature field for the initiator, a supervisor, and the Executive Director. WISH management will mandate that all requisition forms are signed (physically or digitally) to ensure compliance with the policy. In order to ensure compliance, WISH will conduct sessions to review the policies with staff and assign a team member to monitor adherence to the policies. Additionally, WISH policies require expenditure support for each transaction including physical and digital receipts and invoices. WISH management will conduct sessions to ensure knowledge of the existing procedures with staff. WISH will assign a team member to review compliance on a monthly basis to ensure compliance. Proposed Completion Date: June 30, 2024

View Audit 299565

Finding 387347 (2023-002)

Significant Deficiency 2023

The Pennsylvania State University

PA

Student Financial Aid Reporting Significant Deficiency

Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clea...

Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clearinghouse and their reporting to NSLDS. In addition, University management will monitor reporting of status changes to NSLDS. Contact person responsible for corrective action: Robert Kubat, Assistant Vice President of Enrollment Management and University Registrar Anticipated Completion Date: 06/30/2024

View Audit 299535

Finding 387327 (2023-005)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

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

2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The colleg...

2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The college disagrees with this finding, related to the reporting of five graduate files to NSLDS. The finding states the five files were reported 12 days late of the 60-day reporting requirement. Per section 4.4.2 of the NSLDS Reporting Guide, it is not required that an update be received by NSLDS within two months of the Enrollment Status Effective Date, but rather in the next scheduled enrollment submission. Evidence the graduation status was reported in the next scheduled enrollment submission was provided to the auditors. Action taken in response to finding: The College will continue to closely monitor NSC/ NSLDS reporting schedule and check for transmission errors to ensure compliance with reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387321 (2023-004)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no d...

2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will monitor Dear Colleague Letters and the Federal Student Aid Handbook to ensure compliance with disclosures and reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387315 (2023-003)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

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

2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with ...

2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will conduct a manual review of all refund holds to ensure they are removed to allow timely pay of Title IV credit balances. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387309 (2023-002)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

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

2023-002 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: There i...

2023-002 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will closely monitor submission dates and work quickly to resolve technology or other discrepancies that result in delays in file transfer to COD within 15 days of the disbursement date. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387303 (2023-001)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the Col...

2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the College has updated the WISP with all required elements and will incorporate into board policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name(s) of the contact person(s) responsible for corrective action: Linda Andres Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387195 (2023-001)

Significant Deficiency 2023

Idaho Housing and Finance Association

ID

HUD Housing Programs Reporting Significant Deficiency

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors ...

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors selected a sample of 60 applications. Of the 60, one instance of the required documentation for the applicant was not available by the property manager. Responsible Individuals: Cory Phelps, VP Project Finance Corrective Action Plan: IHFA Compliance staff will send a memo to all owner/agents in the Project Based Section 8 program that wait list applications must be retained. IHFA will further explain that failure to have proper documentation in the maintained will result in a deficiency on the Management and Occupancy Review. Anticipated Completion Date: December 30, 2023

View Audit 299469

Finding 387194 (2023-001)

Significant Deficiency 2023

University of St. Thomas

MN

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

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanatio...

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Recognizing the importance of resolving this finding the University of St Thomas intends to leverage its Internal Audit function in review of its relationship with UAS and the regulations and compliance items therein. Name of the contact person responsible for corrective action: Wade Holmberg Planned completion date for corrective action plan: 6/1/2024

View Audit 299468

Finding 387179 (2023-001)

Significant Deficiency 2023

Jackson College

MI

Reporting Significant Deficiency Internal Control / Segregation of Duties

Auditor Description of Condition and Effect. Six students received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing ...

Auditor Description of Condition and Effect. Six students received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing funds. Auditor Recommendation. We recommend that the College implement policies and procedures, including designating an individual to oversee this reporting requirement, to ensure information is submitted to the Common Origination and Disbursement in a timely manner. Corrective Action. After recognizing the changes in Federal Regulations, financial aid went through structural changes and moved personnel around. Transitions allowed for a staff member to become the processing specialist. This individual is responsible for running the process of sending files to COD. These transactions happen every week as outlined in written procedures. Responsible Person. Andrew Spohn, Director of Financial Aid. Anticipated Completion Date. July 2023.

View Audit 299446

Finding 387169 (2023-006)

Significant Deficiency 2023

Fresno Pacific University and Subsidiaries

CA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: A CIS Risk Assessment, Implementation Goup 1 (IG I), has been completed and a detailed plan with 25 Action Items is being worked on which includes a step-by-step plan to obtain full GLBA compliance. The estimated schedule for addr...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: A CIS Risk Assessment, Implementation Goup 1 (IG I), has been completed and a detailed plan with 25 Action Items is being worked on which includes a step-by-step plan to obtain full GLBA compliance. The estimated schedule for addressing the GLBA compliance items specifically called out in the finding is as follows:  Written Information Security Program - Q2 2024  Risk Assessment and safeguards - Risk Assessment is complete, Q2 2025 to address 25 Action Items  Vendor management policies - Q3 2024  Incident response plan - Q2 2024  Written Annual Report to the board - Q4 2024 Person Responsible for Corrective Action Plan: Brad Barker, Chief Information Officer Anticipated Date of Completion: Q2 2025 for Full GLBA Compliance

View Audit 299440

Corrective Action Plans

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