Corrective Action Plans

Finding 390452 (2023-003)

Significant Deficiency 2023

Wyandot, Inc.

KS

Cash Management Eligibility Significant Deficiency

Corrective Actions Taken or Planned: Going forward for payments, under the direction of the Executive Director, Rachel Erpelding, the Kim Wilson Housing Staff will sign-off on the access database check request sheets and have the Executive Director provide her physical signature as written evidence ...

Corrective Actions Taken or Planned: Going forward for payments, under the direction of the Executive Director, Rachel Erpelding, the Kim Wilson Housing Staff will sign-off on the access database check request sheets and have the Executive Director provide her physical signature as written evidence of the review and approval process for housing payments. For drawdowns, beginning July 2023, the Director of Fiscal Services, Linnea Cullumber, implemented a monthly reconcile process between the housing check payment requests and grant billing drawdown support provided by the Kim Wilson Housing Staff. The accounting staff now reconcile the payment and drawdown support, then retain the email correspondence supporting the drawdown process providing confirmation of review and approval. Rachel Erpelding, Executive Director of Kim Wilson Housing, and Linnea Cullumber, Director of Fiscal Services are responsible for this corrective action plan. The anticipated completion date is 3/31/24.

View Audit 301243

Finding 390451 (2023-002)

Significant Deficiency 2023

Wyandot, Inc.

KS

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking

Corrective Actions Taken or Planned: Under the direction of the Executive Director, Rachel Erpelding, the Grant Specialist with Kim Wilson Housing is responsible for collecting data and tracking the grant match total in the housing access database. During the fiscal year ended June 30, 2023, there ...

Corrective Actions Taken or Planned: Under the direction of the Executive Director, Rachel Erpelding, the Grant Specialist with Kim Wilson Housing is responsible for collecting data and tracking the grant match total in the housing access database. During the fiscal year ended June 30, 2023, there wasn’t a 2nd level physical signature of approval on the match tracking documents. Going forward, the Grant Specialist will print and sign the match tracking document and the Executive Director will approve the printed tracking sheet from the housing database. Rachel Erpelding, Executive Director of Kim Wilson Housing, is responsible for this corrective action plan. The anticipated completion date is 3/31/24.

View Audit 301243

Finding 390445 (2023-004)

Significant Deficiency 2023

Oregon Tech

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement ...

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all student loan documentation is maintained per the U.S. Department of Education policies. Management will assign the respective loans back to the Department of Education as to be in compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390442 (2023-003)

Significant Deficiency 2023

Oregon Tech

OR

Significant Deficiency Internal Control / Segregation of Duties § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Explanation of disagreeme...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all required information is provided to the U.S. Department of Education. Additionally, Management will work to ensure that the required contract URL is provided the U.S. Department of Education, following the agency’s requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390441 (2023-002)

Significant Deficiency 2023

Oregon Tech

OR

Significant Deficiency Internal Control / Segregation of Duties § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures regarding stale-dated federal student financial aid outstanding checks. Management will implement additional procedures, returning checks issued directly by the University that stale-dated, similar to policies and procedures followed by the University’s third-party credit balance refund vendor. As part of this procedure, management will engage in student communication and outreach, similar to the University’s regular escheatment procedures. Management believes that a consistent practice between University-issued checks and third-party credit balance refund vendor-issued checks is in the best interest of students while also adhering to U.S. Department of Education timing requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390438 (2023-001)

Significant Deficiency 2023

Oregon Tech

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting i...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390424 (2023-007)

Significant Deficiency 2023

Delaware State University

DE

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

2023-007 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F - Reporting Recommendation: We recommend the University enhances its procedures, controls, and review policie...

2023-007 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F - Reporting Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Business & Finance will populate and upload the quarterly CARES HBCU and Institutional reports by the 10th day after the end of each calendar quarter. The Office of Student Accounts will create and upload the quarterly CARES Student Portion reports by the 10th day after the end of each calendar quarter. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II & Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: May 2024

View Audit 301226

Finding 390415 (2023-006)

Significant Deficiency 2023

Delaware State University

DE

Significant Deficiency Internal Control / Segregation of Duties

2023-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...

2023-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Business & Finance will review the procedures and work collaboratively with teams to investigate, research, and resolve any outstanding refunds. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: June 2024

View Audit 301226

Finding 390414 (2023-003)

Significant Deficiency 2023

Metropolitan Community College Area

NE

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

COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds ...

COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds have been spent and reports are posted on the website. No additional reports will need to be posted. Name(s) of the contact person(s) responsible for corrective action: Brenda Schumacher Planned completion date for corrective action plan: Prior to Summer 2023

View Audit 301214

Finding 390410 (2023-002)

Significant Deficiency 2023

Metropolitan Community College Area

NE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC SAP policy has been corrected and updated to meet federal requirements on calculating the pace a student must progress through their educational program. Moving forward Financial Aid Management will review their policies and procedures annually to ensure that we are meeting all Department of Education SAP requirements. Name(s) of the contact person(s) responsible for corrective action: Kelsey Scott Planned completion date for corrective action plan: Spring 2024

View Audit 301214

Finding 390407 (2023-002)

Significant Deficiency 2023

Hunters Point Boarding School, Inc.

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: ...

Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: April 30, 2024 Planned Corrective Action: Business Manager did get clarification from auditors and BIE around prevailing wage rates documentation. Projects completed did not have sufficient documentation showing wage rates and Business Manager now knows exactly what kind of documentation is needed to justify wage rates. BIE has assisted the Business Manager in where to get current wage rates on Sam.gov. All construction projects moving forward will have correct documentation for wage rates.

View Audit 301207

Finding 390406 (2023-003)

Significant Deficiency 2023

Hunters Point Boarding School, Inc.

AZ

Reporting Significant Deficiency Program Income

Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Busines...

Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Business Manager has corrected the dates for the SF‐425 reporting. SF‐425 reports are turned in on time and all current SF‐425 reports have correct dates.

View Audit 301207

Finding 390305 (2023-002)

Significant Deficiency 2023

Memphis Housing Authority

TN

HUD Housing Programs Significant Deficiency Special Tests & Provisions

March 29, 2024 U.S. Department of Housing and Urban Development The Memphis Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2023. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit peri...

March 29, 2024 U.S. Department of Housing and Urban Development The Memphis Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2023. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit period: July 1, 2022 - June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARDS 2023-002 Special Tests and Provisions - Waiting List Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of 40 applicants that were selected from the waiting list for testing, 14 lacked documentation to show their current status and whether they were given the opportunity to be housed. In addition, there were difficulties obtaining any historical waiting lists for the Public Housing properties. Auditor’s Recommendations: The Authority should implement archiving procedures for its historical waiting lists on a routine basis. In addition, the Authority should document for proper auditing purposes, those given the opportunity to be housed from the waiting list and their current status. The Authority should provide proper training for all staff at the properties to ensure procedures and policies are being followed consistently across all of the Authority’s Public Housing properties. Action Taken: • MHA will ensure we have a saved copy of all public housing site-based waiting lists. LaTonia Young, Director of Asset Management, will save copies of the waiting list for all Public Housing sites on a monthly basis effective March 28, 2024. Tomecia Brown, Director of Compliance and Training will ensure that all site staff are trained on how to pull from the waiting list during the monthly site staff meeting effective April 23, 2024.

View Audit 301166

Finding 390304 (2023-001)

Significant Deficiency 2023

Memphis Housing Authority

TN

HUD Housing Programs Eligibility Significant Deficiency

2023-001 Eligibility Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of an approximate population of 2,083 tenants, 44 tenant files were tested and the following def...

2023-001 Eligibility Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of an approximate population of 2,083 tenants, 44 tenant files were tested and the following deficiencies were noted: • 1 file was missing the support packet for the fiscal year 2023 recertification including but not limited to income support, third party verification, and flat rent sheet, • 3 files had late recertifications, • 2 files were missing support of inspection, • 1 file was missing tenant wage support, and • 1 file was missing a valid 9886 form. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: • 1 file was missing the support packet for the fiscal year 2023 recertification LaTonia Young, Director of Asset Management, lyoung@memphisha.org, 901-544-1129, is working with the new Community Manager to make the corrections for the missing information no later than April 30, 2024. Going forward Tomecia Brown, Director of Compliance and Training, tbrown1@memhisha.org, 901-544-6402, will continue to conduct file reviews to ensure that the required documentation is in the file. •3 files had late recertifications. We will ensure that all recertifications are completed within 30 – 120 days of the effective date. Tomecia Brown, Director of Compliance and Training, will complete a recertification due review on a monthly basis effective April 1, 2024. • 2 file was missing support of inspection. LaTonia Young, Director of Asset Management, will ensure that all units are inspected on an annual basis. In our monthly site staff meeting, Asset Management will inform staff to ensure that all inspections are in the file. • 1 file was missing tenant wage support. We will have the new Community Manager verify wages and make corrections by April 5, 2024. MHA will be sending the owner a non-compliance letter no later than April 30, 2024. Tomecia Brown, Director of Compliance and Training, will continue to complete file reviews on a monthly basis and train staff on the Public Housing process. • 1 file was missing a valid 9886 form. Tomecia Brown, Director of Compliance and Training, will continue to conduct file reviews to ensure that the HUD 9886 form is in the file for all Public Housing sites effective April 23, 2024.

View Audit 301166

Finding 390280 (2023-007)

Material Weakness 2023

Commonspirit Health

IL

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

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Find...

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 3 of 30 students selected for disbursement testing for direct loans within 30 days of funds being disbursed. CHI Health School of Radiologic Technology did not send loan notifications to 14 of 14 students for disbursement testing with direct loans within 30 days of funds being disbursed. Corrective Action Plan: This finding has been corrected for Good Samaritan. As of May 2023, for April 2023 loan disbursements, compliance is verified monthly through internal audit of student disbursements. A sample of disbursements is checked for proper and timely notifications. Timeliness of notifications is checked and verified by the Compliance Oversight Committee monthly. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator CHI Health School of Radiologic Technology Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390276 (2023-010)

Significant Deficiency 2023

Commonspirit Health

IL

Special Tests & Provisions Eligibility Reporting § 200.303

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Tech...

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science and CHI Health School of Radiologic Technology did not have internal controls over enrollment reporting. Corrective Action Plan: This finding has been corrected for Good Samaritan as of April 2023. Enrollment reporting to the National Student Clearinghouse is conducted 5 times per year and reconciled monthly with loan borrowers to ensure active enrollment. Additional Status Update: The Dean of Enrollment Management validates and reports to the oversight committee regarding the monthly reporting. Monthly reporting to the GSC Compliance committee has verified completion since May 2023 and has been timely thereafter. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator, CHI Health School of Radiologic Technology Expected Completion: April 2023 (Good Samaritan) and June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390236 (2023-003)

Significant Deficiency 2023

National University

CA

Procurement, Suspension & Debarment Eligibility Significant Deficiency

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assuran...

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assurance team will oversee a weekly review of the cost of attendance to ensure financial aid packages align with approved budgets, enabling early identification of discrepancies for prompt correction. Based on these reviews, individual and group coaching will be implemented to address areas of concern. A refresher training and updated tools and guidance will be completed to reinforce best practices and align with institutional policy and procedure for calculating the cost of attendance. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390231 (2023-003)

Significant Deficiency 2023

Rider University

NJ

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

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

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Recognizing the importance of resolving this finding the University intends to adjust policies and procedures around reviewing the third-party servicer processes around regulations and compliance items therein. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/26/2024

View Audit 301124

Finding 390230 (2023-002)

Significant Deficiency 2023

Rider University

NJ

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

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: T...

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: In addition to the University’s automated procedures, Financial Aid and the Registrar will reconcile the finalized listing of graduates for each semester to confirm that all students are receiving exit counseling requirements and ensure proper counseling is provided to students. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/19/2024

View Audit 301124

Finding 390228 (2023-001)

Significant Deficiency 2023

Rider University

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the ...

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Registrar's Office can confirm the National Student Clearing House (NSC) enrollment history for all two students is accurate. It appears that there have been challenges with the National Student Loan Data System (NSLDS) receiving current data from NSC in a timely manner. We take action to ensure that we will work with Financial Aid and crossreference the Registrar's monthly submission report and/or weekly Withdrawal Report with an NSLDS' report provided by Financial Aid to address any discrepancies. We will also work with the NSC audit team to ensure if there are any other processes, that we can implement on our end to better oversee the submission with our third-party servicer (NSC). Name(s) of the contact person(s) responsible for corrective action: Justina Nicita, Assistant Registrar, and Miranda Cole, Director of Financial Aid. Planned completion date for a corrective action plan: 3/19/2024.

View Audit 301124

Finding 390227 (2023-003)

Significant Deficiency 2023

Do Good Multnomah

OR

Reporting Significant Deficiency Internal Control / Segregation of Duties

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that invoices can be prepared by someone other than the approver. In the immediate interim, invoices will be reviewed and signed by the CEO before submission by th...

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that invoices can be prepared by someone other than the approver. In the immediate interim, invoices will be reviewed and signed by the CEO before submission by the CFO.

View Audit 301123

Finding 390226 (2023-002)

Significant Deficiency 2023

Do Good Multnomah

OR

Allowable Costs / Cost Principles Cash Management Reporting

We have implemented additional levels of approval and oversight for point-of-sale and invoice spending to ensure that receipts are captured and retained correctly, and that at invoices are reviewed and approved before payment. We have also provided additional training for spenders on best practices ...

We have implemented additional levels of approval and oversight for point-of-sale and invoice spending to ensure that receipts are captured and retained correctly, and that at invoices are reviewed and approved before payment. We have also provided additional training for spenders on best practices of recording and maintaining records. We have since also consolidated our supply chain so that spenders are able to procure most supplies through one vendor, which will have reporting and tracking capabilities. We will also be making significant changes to how mileage reimbursement is documented and approved.

View Audit 301123

Finding 390216 (2023-003)

Significant Deficiency 2023

Enlace Chicago

IL

Reporting Significant Deficiency

Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There ...

Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago is committed to timely completion of report submissions. Enlace Chicago has continued to review and approve reports prior to submission as required by the state agency. We will continue to put forth best efforts to take a step further and document preparation and review on the report form to satisfy the internal process requirement. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Finance Planned completion date for corrective action plan: June 30, 2024.

View Audit 301111

Finding 390197 (2023-004)

None 2023

College Dreams, INC

OR

Reporting Significant Deficiency

Finding # 2023-004: Significant deficiency over preparation of schedule of expenditures of federal awards (SEFA). 93.677 Social Services Block Grant Department of Health and Human Services Finding: The Organization should have systems in place to prepare a complete and accurate SEFA. The Organizati...

Finding # 2023-004: Significant deficiency over preparation of schedule of expenditures of federal awards (SEFA). 93.677 Social Services Block Grant Department of Health and Human Services Finding: The Organization should have systems in place to prepare a complete and accurate SEFA. The Organization did not identify all federal awards and adjustments were made to the SEFA prepared by management. Recommendation: The Organization should implement additional procedures and controls to accurately capture all activity under federal awards in preparing the SEFA. Corrective Action: The Executive Director and Business Manager will use a grant and contract tracking log to ensure they are aware of all federal awards. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390196 (2023-003)

Significant Deficiency 2023

College Dreams, INC

OR

Reporting Significant Deficiency

Finding # 2023-003: Significant deficiency over reporting Immaterial noncompliance over reporting U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: An annual report is due within 90 days after end of the budget period. The annual performance report was not ...

Finding # 2023-003: Significant deficiency over reporting Immaterial noncompliance over reporting U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: An annual report is due within 90 days after end of the budget period. The annual performance report was not submitted timely. Recommendation: Management should keep track of due dates for reports to avoid late submission. Corrective Action: We will have the Executive Director, Business Manager and College+ Program Manager monitor and ensure reports are remitted timely. Anticipated Completion Date: June 30, 2024

View Audit 301101

Corrective Action Plans

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