Corrective Action Plans

Finding 370659 (2023-003)

Significant Deficiency 2023

MI

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

Condition: The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. There were three errors identified that attributed to this finding. 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) T...

Condition: The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. There were three errors identified that attributed to this finding. 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates Planned Corrective Action: The errors have been corrected and the university has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings as well as all required cash management compliance issues. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2023

View Audit 292382

Finding 370633 (2023-002)

Significant Deficiency 2023

Tippecanoe Valley School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Correcti...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024

View Audit 292331

Finding 370604 (2023-002)

Significant Deficiency 2023

Graceland University and Subsidiary

IA

Questioned Costs Student Financial Aid Special Tests & Provisions

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financ...

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financial Services

View Audit 292289 Questioned Costs: $1

Finding 370551 (2023-001)

Significant Deficiency 2023

Lakeland University and Affiliate

WI

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with...

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of all students who received Title IV aid to ensure enrollment data is accurate. Name(s) of the contact person(s) responsible for corrective action: Debra Buffington Planned completion date for corrective action plan: 06/30/2024

View Audit 292250

Finding 370527 (2023-001)

Significant Deficiency 2023

Colton Joint Unified School District

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the...

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the rationale behind charging a substitute to Title I. Additionally, backup documentation will be collected to bolster the support for the allowability of these activities. This proactive plan aims to maintain continuous compliance with Title I guidelines.

View Audit 292192 Questioned Costs: $1

Finding 370508 (2023-001)

Significant Deficiency 2023

Logan University

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ...

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. At the start of each trimester, the calendar will be reviewed to verify any break of 5 days or more are accounted for within the R2T4 calculation setup.

View Audit 292105 Questioned Costs: $1

Finding 370491 (2023-002)

Significant Deficiency 2023

Hamline University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are b...

Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.

View Audit 292076

Finding 370459 (2023-002)

Significant Deficiency 2023

East Porter County School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service...

Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service Manager or Director of Food Service will prepare the reimbursement claim and the Director of Business Affairs and HR or Treasurer will review and initial the claims. This will ensure the accuracy of the reimbursement claim. Anticipated Completion Date: This Corrective Action was put into place in September 2022 following our prior audit. The Claim that was not signed for this Audit was from October 2021.

View Audit 292036

Finding 370430 (2023-002)

Significant Deficiency 2023

Bloomfield College

NJ

Student Financial Aid Reporting Significant Deficiency

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with t...

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-002 Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.268 & 84.063 Recommendation: We recommend that the College strengthen its policies and procedures toensure that student disbursement records are submitted accurately to the COD within 15 dayof disbursements being made to students’ accounts, and that the College maintain clear evidence that a secondary review is performed to verify that the submission was made timelyAction taken in response to finding: The error was identified prior to the end of the award year and the student’s award was corrected. The award was posted and disbursed prior to the return of the revised ISIR into the system. To ensure that accurate information is being used for awards, the Financial Aid office will strengthen its process to review changes and updates to a student’s FASFA prior to disbursing funds. This will ensure that disbursements are submitted accurately to COD with 15 days of the disbursements being made to the student’s accounts. Immediate processing and policy changes with the staff have been implemented. Contact person responsible for corrective action: Quincina Littlejohn, Director of Financial Aid973-748-9000 ext. 1211 Planned completion date for corrective action plan: The corrective action date was December 2023. The new procedures were put into effect immediately.

View Audit 292012

Finding 370428 (2023-001)

Significant Deficiency 2023

Bloomfield College

NJ

Student Financial Aid Special Tests & Provisions Eligibility

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with t...

Bloomfield College and Affiliates respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.268 & 84.063 Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS at least every 60 days, or more often, as determined to be appropriate. The College also should ensure that student Published Program Length Measurements are listed in years and that the Published Program Lengths are calculated in years as recommended by the NSLDS Enrollment Reporting Guide so that the Published Program Length calculation is accurate to the true length of the program for each student. Action taken in response to finding: The College has updated its policies and procedures in overseeing submissions to NSLDS by the third-party servicer “National Student Clearinghouse.” The Registrar’s office, Enterprise Information Services, and the Financial Aid office will work together to ensure that relevant information is reported accurately and timely by “NSC” in accordance with applicable regulations. Contact persons responsible for corrective action: Aylin Solu-Brandon, University Registrar, 973-655-7525 Planned completion date for corrective action plan: We implemented the corrective action in January 2024. Following a discussion with the staff about the finding, new processing procedures were promptly implemented. The College will ensure that student Published Program Length Measurements are listed in years and that the published Program Lengths are calculated in years.

View Audit 292012

Finding 370401 (2023-001)

Significant Deficiency 2023

St. Catherine University

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure all status changes are updated with the appropriate timef...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure all status changes are updated with the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When we learned that the procedures didn't accurately explain the terms that needed to be reported, we updated them. We will include students who graduated from the prior term as well as the current term when needed, to ensure all graduates are included. Name(s) of the contact person(s) responsible for corrective action: Kerri Vickers Planned completion date for corrective action plan: October 2023

View Audit 291976

Finding 370363 (2023-009)

Significant Deficiency 2023

City of Detroit, Michigan

MI

Subrecipient Monitoring Significant Deficiency

Finding Number: 2023‐009 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Condition: Original Finding Description: The City did not provide a formal report on monitoring performed for three of their subrecip...

Finding Number: 2023‐009 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Condition: Original Finding Description: The City did not provide a formal report on monitoring performed for three of their subrecipients. Contact Person Responsible for Corrective Action: Denise Fair Razo (DHD) and Angelique Tomsic (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review its subrecipient monitoring policy during the AFCAP process and implement additional controls to ensure an end to end process is in place that includes timely communication of the reports.

View Audit 291959

Finding 370310 (2023-002)

Significant Deficiency 2023

Chinle Unified School District No. 24

AZ

Reporting Significant Deficiency

Finding Number: 2023-002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Priscine Jones, Business Manager Anticipated Completion Date: The Business Manager will work with the Federal Programs Director to ensure that categorie...

Finding Number: 2023-002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Priscine Jones, Business Manager Anticipated Completion Date: The Business Manager will work with the Federal Programs Director to ensure that categories of expenses are correctly reported on the next ESSER reporting cycle. The Business Manager will work with the Federal Programs Director effective immediately January 18, 2024 to obtain correct funding codes in writing. Planned Corrective Action: The Business Manager and Federal Programs Director worked with ADE ESSER grants program staff, and the Arizona Auditor General’s office on ESSER and COVID Reporting. When we completed the initial ESSER reports, we did not understand from guidance that we were supposed to match the categories of expenditures we were reporting to the Accounts Payable Expense reports used for reimbursement requests. We had been reporting based on actual expenditures to date, not the snapshots for the given window of time represented by the Accounts Payable Expense reports used for reimbursement requests. For the most recent reporting cycle, we did gain a clear understanding of the expectations for these reports we are supposed to match to. We do carefully monitor expenditures to ensure that they are aligned to our grant and allowable uses for our ESSER funds. Now that we understand which reports we have to match to, we will be able to match the categories of expenditures to the Accounts Payable Expense reports accurately. Currently, The District has expended ESSER I and II completely. We only have ESSER III to report on which will simplify the ESSER reporting requirements to the Arizona Department of Education. In regard to ESSER I & II salary and benefits expenditures, the District had retention stipends written into both ESSER II and III for specified years and recruitment stipends written only in ESSER III. A misunderstanding caused a payment to be posted to the wrong grant. Upon discovery and to process the correction, the District executed a journal entry to assign the expense to the right grant. In the meantime, we had already processed a reimbursement request for the original and erroneously posted expense. This caused the financial reports to appear as if the expense occurred twice; once in F336 and once in F346 in the future, the Business Manager will get a written approval from the Federal Programs Director on which funds were approved for Recruitment and Retention payments and for specified years.

View Audit 291943

Finding 370305 (2023-001)

Significant Deficiency 2023

Chinle Unified School District No. 24

AZ

Special Tests & Provisions Procurement, Suspension & Debarment Significant Deficiency

Finding Number: 2023-001 Program Names/Assistance Listing Titles: Education Stabilization Fund, Impact Aid Assistance Listing Number: 84.425, 84.041 Contact Person: Priscine Jones, Business Manager Anticipated Completion Date: The Business Manager will work with the current construction vendor ...

Finding Number: 2023-001 Program Names/Assistance Listing Titles: Education Stabilization Fund, Impact Aid Assistance Listing Number: 84.425, 84.041 Contact Person: Priscine Jones, Business Manager Anticipated Completion Date: The Business Manager will work with the current construction vendor and have this reorganization be completed by February 29, 2024 and ensure the vendor turns in their payroll certifications. Planned Corrective Action: The District had started a corrective action plan in 2023 with the current construction vendor. In the past, the District would receive the payroll certifications by email. This method didn’t meet the requirements of the weekly payroll certifications. Therefore, the vendor moved forward to set-up links by project with vendor folders in the links. This was not well organized so, the District had to manually go through each folder to find updated payroll certifications. This method still didn’t meet the requirements of the weekly payroll certifications. As of January 18, 2024, the District has communicated in writing to the vendor about the organizational structure of the links and recommended a modification of folders from vendor to weeks. This request seems feasible since not all subcontractors will be on site through the duration of the project. This reorganization should be completed by February 29, 2024. In addition, the vendor was informed they need to ensure their subcontractors turn in their payroll certifications weekly.

View Audit 291943

Finding 370294 (2023-001)

Significant Deficiency 2023

Family Health Services of Erie County

OH

Eligibility Significant Deficiency Program Income

Finding Number: 2023-001 Anticipated Completion Date: May 2024 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization provided 2,682 self-pay encounters to be audited for the year ended May 31, 2023. Out of the 2,682 self-pay encounters, 20 were identified for fu...

Finding Number: 2023-001 Anticipated Completion Date: May 2024 Responsible Contact Person: David Tatro, CEO Planned Corrective Action: The Organization provided 2,682 self-pay encounters to be audited for the year ended May 31, 2023. Out of the 2,682 self-pay encounters, 20 were identified for further review. Two self-pay accounts were identified with issues which resulted in this finding. The first issue was attributed to a patient inaccurately placed on a slide level, and the other patient account did not have an updated sliding fee scale application completed on file. This issue has been resolved as of November 2023 by reviewing all sliding fee scale applications for accuracy. The Organization will continue to monitor the sliding fee scale amounts applied to ensure ongoing compliance with the requirements. The Organization will review five sliding fee scale applications each week to ensure eligibility determination, billing and collection follows the Sliding Fee Discount Program. This will go through May 2024 with a reassessment at that point, based on the results of the internal review.

View Audit 291926

Finding 370261 (2023-002)

Significant Deficiency 2023

Ave Maria University, Inc. and Subsidiaries

FL

Subrecipient Monitoring Eligibility Reporting § 200.328 § 200.329

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of ...

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

View Audit 291876

Finding 370252 (2023-004)

Significant Deficiency 2023

Association House of Chicago

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

Action taken in response to finding: Management will ensure authorizations are reflected on monthly expenditure reports. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Name of contact person responsib...

Action taken in response to finding: Management will ensure authorizations are reflected on monthly expenditure reports. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370251 (2023-003)

Significant Deficiency 2023

Association House of Chicago

IL

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person respons...

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370243 (2023-001)

Significant Deficiency 2023

Simpson Housing Services, Inc.

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Simpson management hired additional staff to allow management the additional time necessary to prepare and review internal financial statements in a timely and efficient manner so that the audit can begin and be completed in a timely and efficient manner. Management believes their processes are prop...

Simpson management hired additional staff to allow management the additional time necessary to prepare and review internal financial statements in a timely and efficient manner so that the audit can begin and be completed in a timely and efficient manner. Management believes their processes are properly designed to ensure timely filing of the Single Audit Reporting Package in future years.

View Audit 291844

Finding 370240 (2023-002)

Significant Deficiency 2023

Lutheran Social Service of Minnesota and Affiliates

MN

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement wit...

Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures and systems will be adjusted to maintain report approval submissions, along with additional reviews to ensure that documentation is maintained. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson, Controller Planned completion date for corrective action plan: 01/31/2024

View Audit 291833

Finding 370237 (2023-001)

Significant Deficiency 2023

Curry College

MA

Student Financial Aid Reporting Significant Deficiency

Finding 2023-001 Enrollment Reporting: Contact person(s) responsible for corrective action: Stephanny Elias, Associate Vice President of Financial Aid Robert Loconto, Director of Financial Aid June Koukol, Registrar Anticipated completion date:February 2024 Context and Corrective Action: In th...

Finding 2023-001 Enrollment Reporting: Contact person(s) responsible for corrective action: Stephanny Elias, Associate Vice President of Financial Aid Robert Loconto, Director of Financial Aid June Koukol, Registrar Anticipated completion date:February 2024 Context and Corrective Action: In the final Spring 2023 enrollment certification to the National Student Clearinghouse (NSC), 11 students were identified not having been reported as graduated to NSC. Six of these students were brought to the attention of the Registrar’s Office by the Auditors in December 2023/January 2024. An internal review by the Registrar on January 22, 2024 revealed five additional students. The separate DegreeVerify transmission, which serves as a backup process and updates the graduation status for any student who did not get coded as such via the NSC enrollment transmission, also did not generate a graduated status for these students. The Registrar’s Office has concluded that this is the result of an error within the SOPLCCV Banner process when it was run for these students. This process is run during degree conferral and aligns curriculum information between the student’s academic record and the degree conferral record. The SOPLCCV process didn’t produce the intended result for the impacted students, and their degree records in Banner were manually updated to correct discrepancies that would normally be updated via the process. Unbeknownst at the time was that the initial discrepancy and subsequent manual update impacted the reporting of the degree conferral to NSC in the relevant transmission, due to a data mismatch between NSC’s curriculum information and the degree conferral information. The December 2023 degree conferral has since taken place, and the Registrar’s Office confirmed that the SOPLCCV process worked properly for all December graduates. The Registrar’s Office also manually checked each December graduate in NSC on January 22, 2024 and confirmed that all 56 December graduates with Fall 2023 enrollment were reported appropriately to NSC as graduated in the December degree transmission. The Registrar’s Office is consulting with Curry College ITS to develop a report to consolidate and display data from the text files generated via the Banner NSC transmission into a readable Excel format, to easily check and identify graduates and how they are being reported to NSC in the transmission. In the interim, the Registrar’s Office will continue to manually check each graduate in the NSC degree file to confirm that degree conferral is reported appropriately to NSC. This review will take place within two weeks of degree conferral, after the degree transmission has been processed by NSC.

View Audit 291830

Finding 370236 (2023-001)

Significant Deficiency 2023

Southeastern Community Action Partnership, Inc.

NC

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Finding: 2023-001 Name of Contact Person: Tiffany Anthony, Housing Director Corrective Action Plan: The PHA will implement procedures to ensure that all unit inspections and re-inspections are performed in a timely manner. Proposed Completion Date: Immediately

View Audit 291827

Finding 370217 (2023-002)

Significant Deficiency 2023

Woodbury University

CA

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

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Def...

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency In Internal Control Over Compliance. Corrective Action: The University has updated the status of all students in our latest batch send. That includes and is not limited to all students selected In the Single Audit. Steps/Policies Implemented to avert problem: The process for reporting information to NSLDS through the Clearinghouse works efficiently. The problem in this case, is that the University has always had two individuals with access to the upload data into the Clearinghouse. When one of the individuals responsible for uploading's position was eliminated, authorization was not given to anyone else as a backup. So, when the then Registrar resigned, no one on-site was authorized to upload the already prepared "send". That issue has been resolved and there will always be, once again, two individuals with access to upload. Although the process to resolve this Issue was extremely timely, permission to access the Clearinghouse site was eventually provided. Contact Person: The Registrar, Verletta Jackson is the responsible person. Her contact information is, Verletta Jackson, email Verletta.Jackson@woodbury.edu, phone 818 252 5277. Anticipated Completion Date: Completed as of 10.15.2023

View Audit 291795

Finding 370216 (2023-002)

Significant Deficiency 2023

Lewis-Clark State College

ID

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

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit find...

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370200 (2023-002)

Significant Deficiency 2023

Independent School District No.15

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance With Federal Suspension and...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 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 special education cluster. Condition – The District did not have sufficient controls or documentation in place within its special education cluster 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 – The District’s Director of Business Services, Ron Meyer. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – There is no disagreement with the finding. Plan to Monitor – The District’s Director of Business Services, Ron Meyer, 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.

View Audit 291778

Corrective Action Plans

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