Corrective Action Plans

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SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, 10.556, AND 10.553 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment R...
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, 10.556, AND 10.553 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Summary of Finding Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. Condition – The District did not have sufficient controls in place within its child nutrition cluster program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.
Finding 384694 (2023-007)
Significant Deficiency 2023
2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower ...
2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Action Taken: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline. Responsible Party: Lola Kennedy, Senior Director of Financial Aid and Sharon Murphy, Registrar Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) and Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: April 1, 2024
Finding 384693 (2023-006)
Significant Deficiency 2023
2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of ...
2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: July 2023
Finding 384692 (2023-005)
Significant Deficiency 2023
2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance ...
2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Action Taken: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting. Responsible Party: Sharon Murphy, Registrar Point of Contact: Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: August 2023
Finding 384691 (2023-004)
Significant Deficiency 2023
2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consec...
2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students.3. Institutional charges for the period used in the refund calculations included tuition and fee credits processed due to the withdrawal for two of the four students. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: August 1, 2023
Finding 384690 (2023-003)
Significant Deficiency 2023
2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. I...
2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: April 2024
Finding 384689 (2023-002)
Significant Deficiency 2023
2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to...
2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: January 2024
Finding Number: 2023‐004 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 COVID‐19 Education Stabilization Fund 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion ...
Finding Number: 2023‐004 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 COVID‐19 Education Stabilization Fund 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The School reported incorrect expenditures for one of four quarterly reports reviewed. Acknowledged that one of the quarterly SF‐425 reports did contain an error with the additional revenue and expenses of non‐federal monies included in the report. Future reports will be reviewed more closely to prevent such errors.
Finding Number: 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: During fiscal year 2022‐23, there was a change in staf...
Finding Number: 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: During fiscal year 2022‐23, there was a change in staffing in Human Resources and a delay occurred in the training and certification of the new HR person. Action has already been taken to complete the reinvestigations that were missed; a new schedule has been put in place to ensure that this issue does not repeat in the future.
2023-001 Non-Compliance. Significant Deficiency Name of Contact Person: Jeff Patterson, Chief Financial Officer-Client Schools Corrective Action: The School has put procedures in place to ensure that paraprofessionals meet the requirements of ESSA. Proposed Completion Date: Immedia...
2023-001 Non-Compliance. Significant Deficiency Name of Contact Person: Jeff Patterson, Chief Financial Officer-Client Schools Corrective Action: The School has put procedures in place to ensure that paraprofessionals meet the requirements of ESSA. Proposed Completion Date: Immediately with ongoing monitoring.
View Audit 297765 Questioned Costs: $1
Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District design and implement controls to ensure all student disbursements are reported to COD with in required timelines. Explanation of disagreement with a...
Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District design and implement controls to ensure all student disbursements are reported to COD with in required timelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WCTC has added additional internal controls specific to the disbursement process including multi-layered file review, and monthly reconciliations. These controls target the audit finding ensuring thorough file review and prompt rectification of any discrepancies. Name(s) of the contact person(s) responsible for corrective action: Justin Kehring, Director Financial Aid Planned completion date for corrective action plan: June 30, 2024
Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District review and update as necessary the written information security program(s) to include aspects required by regulations. Explanation of disagreement w...
Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District review and update as necessary the written information security program(s) to include aspects required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and has taken action to update internal policy documentation to appropriately address the required safeguards. Name(s) of the contact person(s) responsible for corrective action: Shannon Ford, Executive Director Information Technology Systems Planned completion date for corrective action plan: June 30, 2024
Finding No. 2023-002 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipm...
Finding No. 2023-002 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions
Finding No. 2023-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipm...
Finding No. 2023-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and rec...
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and reconcile bank accounts with the general ledger, particularly for training purposes and periods when there are staff vacancies. Financial resources are insufficient to hire the additional staff to allow for greater segregation of responsibilities. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process
Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on...
Finding Summary: One financial aid disbursement tested was not made within the allowable 15 day period. Responsible Individuals: Alicia Smith, Director of Financial Aid Cari Wilburn, Director of Finance Corrective Action Plan: We have worked together in both departments to ensure proper reporting on the financial aid systems and quick disbursements of all funds. Anticipated Completion Date: July 1, 2024
Historically, the Housing Authority obligated funds as they became available on a monthly basis, based on the five-year plan approved by HUD. The Housing Authority was not aware that drawdowns of Capital funds for operating, and construction costs have to be obligated when the expense is incurred, o...
Historically, the Housing Authority obligated funds as they became available on a monthly basis, based on the five-year plan approved by HUD. The Housing Authority was not aware that drawdowns of Capital funds for operating, and construction costs have to be obligated when the expense is incurred, or a contract entered into. This was corrected as of February 2024; however, CFP 2023 had already been fully obligated. The Housing Authority will implement this new procedure with the issuance of the 2024 CFP grant. The Housing Authority has put a process in place to make sure the operating funds are obligated in LOCCs only after a contract is executed and expenses have been incurred as part of our monthly procedures. The Comptroller, Jennifer Yager, will oversee this under the guidance of the CFO Consultant and the Capital Project Manager. This will be implemented with the issuance of CFP 24. Jennifer can be reached at 203-596-2640.
This finding was identified during the HUD QAD review in 2022. The Comptroller, Jennifer Yager, and the Director of Leased Housing Programs, Dana Serra, implemented a quarterly review of the electronic submission of form HUD-52681-B and the general ledger. The Housing Authority has completed this re...
This finding was identified during the HUD QAD review in 2022. The Comptroller, Jennifer Yager, and the Director of Leased Housing Programs, Dana Serra, implemented a quarterly review of the electronic submission of form HUD-52681-B and the general ledger. The Housing Authority has completed this review for the first two quarters of FY2024. Both Dana and Jennifer can be reached at 203-596-2640.
As of February 2024, the Housing Authority has implemented, into the invoice process, to obtain certified payrolls for all restoration, maintenance, and rehabilitation services with a cost of $2,000 or more. The Comptroller, Jennifer Yager corrected this finding in February 2024. Jennifer can be rea...
As of February 2024, the Housing Authority has implemented, into the invoice process, to obtain certified payrolls for all restoration, maintenance, and rehabilitation services with a cost of $2,000 or more. The Comptroller, Jennifer Yager corrected this finding in February 2024. Jennifer can be reached at 203-596-2640.
Finding 384532 (2023-001)
Significant Deficiency 2023
Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Offi...
Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Persons Responsible for Corrective Action The corrective action plan will be completed by Walter Rankin, Vice Provost for Graduate Continuing and Professional Studies and Danielle Quilligan, University Registrar. Completion Date Initial corrective action was completed by Lynn Kohrn, University Registrar and Allison Henderson, Assistant Registrar in October, 2023 with the submission of a graduates only enrollment report to the third-party service provider NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.
Finding 2023-003 - Special Provisions and Testing - Residual Receipts Account Federal Agency Name: Department of Housing and Urban Development Program Name: Supportive Housing for Persons with Disabilities Federal Assistance Listing/CFDA #14.181 Finding Summary: The Corporation did not deposit proj...
Finding 2023-003 - Special Provisions and Testing - Residual Receipts Account Federal Agency Name: Department of Housing and Urban Development Program Name: Supportive Housing for Persons with Disabilities Federal Assistance Listing/CFDA #14.181 Finding Summary: The Corporation did not deposit project funds in a federally insured account within 60 days of the fiscal year end. The Corporation did not have the deposit amount determined timely enough to have the project funds deposited within 60 days of the fiscal year end. Corrective Action Plan: We will implement controls to ensure the required amount of project funds are deposited within 60 days following the end of the fiscal year. Responsible Individuals: Josh Plecity, Finance Director Anticipated Completion Date: 6/30/2024
2023-003 – REPORTING – PERFORMANCE REPORTING Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Choice Voucher Program AUDITEE’S RESPONSE AND CORRECTIVE ACTION TAKEN The Authority will ensure that adequate supporting documentation is retaine...
2023-003 – REPORTING – PERFORMANCE REPORTING Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Choice Voucher Program AUDITEE’S RESPONSE AND CORRECTIVE ACTION TAKEN The Authority will ensure that adequate supporting documentation is retained on a go forward basis. The contact person for this finding is John McKeown, Executive Director, and can be reached at 781-293-3088. Anticipated completion date of corrective action is March 2024.
2023-002 – ACTIVITIES ALLOWED OR UNALLOWED AUDITEE’S RESPONSE AND CORRECTIVE ACTION TAKEN Management reviewed the authorized signatories on all accounts, updating them and retired the manual stamp prior to the printing of this response. Additionally, the Authority has (5) new authorized signers on t...
2023-002 – ACTIVITIES ALLOWED OR UNALLOWED AUDITEE’S RESPONSE AND CORRECTIVE ACTION TAKEN Management reviewed the authorized signatories on all accounts, updating them and retired the manual stamp prior to the printing of this response. Additionally, the Authority has (5) new authorized signers on the account(s). This will ensure that all disbursements have two signatures before processing the payment. The contact person for this finding is John McKeown, Executive Director, and can be reached at 781-293-3088. Anticipated completion date of corrective action is March 2024.
Corrective Action Plan For the year Ended June 30, 2023 Section II - Financial Statement Findings None reported. Section III – Federal Award Findings and Questioned Costs Significant Deficiency Finding 2023-001 Internal Control Over Compliance-Public and Indian Housing Name of Contact Person: Wil...
Corrective Action Plan For the year Ended June 30, 2023 Section II - Financial Statement Findings None reported. Section III – Federal Award Findings and Questioned Costs Significant Deficiency Finding 2023-001 Internal Control Over Compliance-Public and Indian Housing Name of Contact Person: William Bobbitt, Executive Director Corrective Action: We will review our intake and recertification procedures. We will also review our tenant file monitoring procedures. Proposed Completion Date: Management will implement the above procedure immediately.
Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, & 84.268 Recommendation: We recommend the District review and update as necessary written information security program(s) to include aspects required by regulations. Explanation of disagreement with audit finding: There i...
Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, & 84.268 Recommendation: We recommend the District review and update as necessary written information security program(s) to include aspects required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While SWTC has implemented practices to ensure the safeguards are in place, the appropriate documentation had not yet been updated for certain safeguards. SWTC has completed the recommended revisions as required by the standards. Name of the contact person responsible for corrective action: Kelly Kelly, Controller Planned completion date for corrective action plan: June 30, 2024
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