Corrective Action Plans

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Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implem...
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implemented. Title IV funds can no longer be disbursed for programs marked as ineligible. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Finding 387142 (2023-005)
Significant Deficiency 2023
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place befo...
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that procedures are in place to ensure the FISAP data has a review by a second person prior to submission. The hiring of the Director of Financial Aid will greatly assist in ensuring accuracy of reporting. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: September 2024 filing.
Finding 387136 (2023-004)
Significant Deficiency 2023
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the requ...
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College appointed an Information Technology Point of Contact in 2023. Tabor College contracted with Tenfold Security to assist with the requirements of the Gramm-Leach-Bliley Act (GLBA). A Risk Assessment was performed in April 2023 and the final report issued in May 2023. Penetration testing has been completed on a regular basis beginning March 27, 2023. Multi-factor Authentication (MFA) implementation began in June with full implementation with the return of students in August 2024. MFA has been fully implemented for all employees, students, and Board members. The significant undertaking of establishing required Policies and Procedures began in June 2023. A GLBA Committee has been recently been formed to help ensure compliance with all of the established policies and procedures. Tabor continues to work with Tenfold to ensure compliance with the GLBA requirements as of June 9, 2023. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: 2024 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.
Finding 387130 (2023-003)
Significant Deficiency 2023
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately re...
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately 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: Tabor College utilizes a clearing house for submitting student statuses. Enrollment is submitted on a monthly basis, at the beginning of the term, each month and then when the term has ended. Graduate students are reported at the end of the term. Tabor will ensure that all students statuses are filed accurately and timely. A Director of Financial Aid has been hired. This position had been filled by an interim person. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: April 2024
Finding 387124 (2023-002)
Significant Deficiency 2023
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure...
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. The two third-party collection agencies for Perkins were added to ECAR on October 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: March, 2024
Finding 387116 (2023-002)
Significant Deficiency 2023
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. Management response: From October 2022 to August 2023, the Registrar's Office was short staffed (we only had one employee in the office). We also switched email service providers in the second half of May 2023. The degree file reminder email from the National Student Clearinghouse was missed by the Registrar in the email transition period and because of the change in calendar systems, it was also missed on the Registrar's calendar. When the email migration was complete, the Registrar had thousands emails that were showing as unread. By the time the email cleanup was complete, and the Registrar realized she had not submitted the May 2023 degree file, the 60 day window had passed. The file was submitted in late July as soon as it was discovered that it hadn't gotten submitted (15 days past the 60 day window) Corrective Action Plan: The Summer 2023 and Fall 2023 degree files were submitted on time. The Registrar's office is once again fully staffed and our email and calendar systems are stable again as well. Responsible Person: Kendi Onnen, Registrar Implementation Date: 7/27/2023
Finding 387115 (2023-001)
Significant Deficiency 2023
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Management response: Timecard approval was completed by email notification. During 2022/23, a new email system was installed, and many emails related to timecards were lost. Corrective Action Plan: Starting in August 2023 all timecard approvals were documented in the payroll system (Paycor). HR prior to processing payroll requires all timecards be system documented as approved. Responsible Person: Kathleen Hermacinski, Human Resources Coordinator Implementation Date: August 2023
View Audit 299424 Questioned Costs: $1
2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023...
2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: The University Registrar will send a memorandum to all degree certifying officers at the University reminding them that degree certification must be completed by the appropriate date to be certain all students are included on the file that updates NSLDS with the graduation date. The Chancellor Unit registrars will be asked to send out reminders in the weeks leading up to the required submission date and to track the completion of degree certifications. A process will be developed to allow for the proper reporting of graduation information on the Program-Level Record to NSLDS even when the student remains currently enrolled at the University and is being reported as such on the Campus-Level Record. Anticipated Completion Date: The anticipated completion date for degree certifications is June 2024. The anticipated completion date for dual enrollment reporting statuses is January 2025.
The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We starte...
The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We started the process on 6/29/2022 to replace our Housing Inspector that left EHA 5/04/2022. The person that filled this Housing Inspector position started at EHA on 1/05/2023, completed training and began taking on an inspection workload in February 2023. • In March 2023, twenty-five (25) staff in EHA’s Housing Management Department attended an HQS inspections training. EHA Housing Management staff began completing initial and annual HQS inspections at EHA PBV properties on 7/01/2023. • EHA budgeted for a second Housing Inspector position in EHA’s FYE2023 budget. We started the process to hire the second Housing Inspector on 7/13/2023. The person that filled this second Housing Inspector position started at EHA on 9/19/2023, completed training and began taking on an inspection workload at the end of October 2023. • EHA budgeted for an Inspections Coordinator position in EHA’s FYE2023 budget. We started the process to hire the Inspections Coordinator on 8/14/2023. The person that filled the Inspections Coordinator position started on 11/06/2023. • On 10/30/2023, EHA’s Executive Director decided to add a third Housing Inspector to the EHA inspections team to assist with the backlog of biennial inspections. We started the process to hire the third Housing Inspector on 10/31/2023. The person that filled this third Housing Inspector position started in the position on 1/16/2024, completed training and began taking on an inspection workload in February 2024. • On 2/23/2024, an HCV Manager was appointed to supervise the inspections team (three Housing Inspectors and one Inspections Coordinator), to provide increased oversight over EHA’s inspections workload. The HCV Manager is responsible for monitoring progress towards addressing the biennial inspections backlog, delegating inspections workload to the inspections team, and providing guidance and support to the inspections team. The HCV Manager meets with the inspections team on a weekly basis as well as conducts individual check-ins with all inspections team members. Our increased inspections capacity has allowed us to make significant progress on addressing the pandemic-caused backlog of biennial inspections. Based on our expanded internal staffing resources, we expect to complete all late biennial inspections by 12/31/2024.
Finding 387003 (2023-004)
Significant Deficiency 2023
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.
Finding 387001 (2023-003)
Significant Deficiency 2023
Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 202...
Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. During the go-live in Spring 2023, the University experienced critical system reporting issues which were addressed a quickly as possible. The new system has several built in features that are supplemented with internal controls to ensure enrollment reporting requirements are completed in a timely fashion. In Spring 2024, Anthology provided the University with a audit tool to review data before uploading to promote efficiency and accuracy.
Finding 386999 (2023-002)
Significant Deficiency 2023
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that changes in students enrollment status that trigger a return of title IV funds are completed within the required 45 day time period. During the transition of systems the report used to look at students who might need to be a withdrawal and have a R2T4 calculation performed needed to be rebuilt for the new system. During this process the report did not always work correctly. Those flaws have been fixed the report is being worked on a weekly basis.
Finding 386998 (2023-001)
Significant Deficiency 2023
Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure financial aid is awarded correctly. The system automatically awards the student at full-time, the awards are then confirmed through a review process before sending out the award notification, and again before payment. The system compares the full-time award status with the actual enrollment and if they do not match the student will fail for payment and we will revise the award.
Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for...
Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for the program year ended June 30, 2023, we have taken immediate and strategic steps to address and prevent future occurrences. These include streamlining our data collection and reporting processes for greater efficiency, enhancing staff training on reporting responsibilities, and implementing robust internal monitoring to ensure adherence to reporting deadlines. These measures, designed to address both the immediate issue and bolster our overall reporting framework, demonstrate our commitment to transparency, accountability, and continuous improvement in our program operations. Contact person responsible for corrective action: Joanne Campbell Anticipated Completion Date: October 10, 2023
Finding 386970 (2023-001)
Significant Deficiency 2023
Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided ...
Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided on the University’s website. Completion Date: March 25, 2024 Contact Person: Donna Ferguson, Controller, and Carrie Stevens, Associate Vice President of Compliance
Finding Number: 2023-001 Condition: Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Planned Corrective Action: The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day...
Finding Number: 2023-001 Condition: Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Planned Corrective Action: The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement. Contact person responsible for corrective action: Betty McKain, Sr Director Research Administration Anticipated Completion Date: 06/30/2024
2023-002 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...
2023-002 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The School Department has reviewed the finding and is in the planning process with corrective actions. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: NPS has completed the first of two required Time and Effort Certifications for FY24. We will add managerial review of the completed certifications as an additional level of oversight for both the first and second certifications this year and continue this practice henceforth.
Corrective Action Plan Finding number 2023-001 Reporting Head Start FFATA Compliance - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Diane Castelbuono Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-...
Corrective Action Plan Finding number 2023-001 Reporting Head Start FFATA Compliance - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Diane Castelbuono Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-400-6242 View of Responsible Officials and Planned Corrective Action The School District of Philadelphia concurs with the finding and recommendations. The District has implemented a systematic process for reporting Fiscal Year 2024 subawards under the Federal Head Start Program which is required to report under FFATA. Moving forward, the process is established to ensure reporting will be maintained.
Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of ...
Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092 Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from the school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024.
Finding 386833 (2023-002)
Significant Deficiency 2023
The Finance Department has made several additions to its staff as a part of its reorganization
The Finance Department has made several additions to its staff as a part of its reorganization
Finding 386833 (2023-002)
Significant Deficiency 2023
efforts, within the last year. The additions included a Chief Accountant, a Principal Accountant,
efforts, within the last year. The additions included a Chief Accountant, a Principal Accountant,
Finding 386833 (2023-002)
Significant Deficiency 2023
three Senior Accountants, an Accountant, a Principal Administrative Analyst, an Administrative
three Senior Accountants, an Accountant, a Principal Administrative Analyst, an Administrative
Finding 386833 (2023-002)
Significant Deficiency 2023
Analyst, and accounting clerks. All professional level accounting staff are assisting in the
Analyst, and accounting clerks. All professional level accounting staff are assisting in the
Finding 386833 (2023-002)
Significant Deficiency 2023
completion of monthly account reconciliations. All completed account reconciliations, prepared
completion of monthly account reconciliations. All completed account reconciliations, prepared
Finding 386833 (2023-002)
Significant Deficiency 2023
within the Department of Finance, are reviewed by the principal accountants responsible for
within the Department of Finance, are reviewed by the principal accountants responsible for
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