Corrective Action Plans

Finding 386579 (2023-012)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

Department of Education 2023-012 Direct Loan Exit Counseling Student Financial Aid Cluster – Assistance Listing No. 84.268 Auditors' Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations all schools that part...

Department of Education 2023-012 Direct Loan Exit Counseling Student Financial Aid Cluster – Assistance Listing No. 84.268 Auditors' Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations all schools that participate in the Federal Student Aid programs are required to provide exit counseling to student borrowers who withdraw from school. This requirement is outlined in 34 CFR section 685.304. Specifically, exit counseling must be provided within 30 days after the school learns that the student borrower has withdrawn from school. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The R2T4 process has been updated to include better communication between the Director of Financial Aid and the University Registrar to monitor enrollment status changes and ensure that the information used for the R2T4 calculations is accurate. The Director of Financial Aid will review the staff members' processing of R2T4 calculations to ensure accuracy. Name of the contact person responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the Department of Education has questions regarding this plan, please contact Ozie Ratcliff at 601-979-3347.

View Audit 298874

Finding 386575 (2023-011)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

Department of Education 2023–011 Outstanding Student Refund Checks Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal ...

Department of Education 2023–011 Outstanding Student Refund Checks Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that have not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. CLA recommends that the University review the requirement and implement a monitoring control to monitor the checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a policy to address the following: Returned or unclaimed Title IV Refunds will be successfully delivered to recipients (students or parents) or returned to the appropriate federal agency after 180 days outstanding. Additional attempts may be made to contact recipients; however, all unclaimed funds will be returned to the appropriate aid program no later than 240 days after the initial disbursement. The Accounting Office will maintain an “Outstanding Title IV Refund Checks/EFT Returns” list that will be provided to the Bursar’s Office every month. The Bursar’s Office will review the “Outstanding Title IV Refund Checks/EFT Returns” list every month and follow the procedures below regarding the outstanding checks/EFT returns.  The Bursar’s Office will use all reasonable means to locate the student or parent whose Title IV refund checks or returns have become 120 days old.  If all attempts are not successful, any outstanding Title IV refunds checks that have become stale dated (over 180 days) will be voided. The Bursar’s Office will make an entry, after a check has been voided, debiting the student account, and crediting a designated account that the Accounting’s Office will specify. This entry will then be interfaced to the Finance General Ledger debiting Student AR and crediting “Unclaimed Title IV Account”.  The Bursar’s Office will then send an e-mail notice to the Financial Aid Office containing the student’s name, student ID number, Title IV program(s), aid year and dollar amount that has been credited to the “Unclaimed Title IV Account”.  Based on the information provided, funds will be returned to the appropriate aid program within 210 – 240 days.  The Financial Aid Office will make the appropriate change(s) to the Fiscal Operations Report and Application to Participate (FISAP).  The Accounting’s Office will reconcile the “Unclaimed Title IV Account” every month. Name(s) of the contact person(s) responsible for corrective action: Charlette Mock, Director of Accounting and Lucreta Tribune, Associate Vice President for Finance Planned completion date for corrective action plan: This plan will be implemented no later than April 2024, with ongoing review of the process. This process should be completely in effect by the end of the current fiscal year, June 30, 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672.

View Audit 298874

Finding 386573 (2023-010)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency § 200.303

Department of Education 2023-010 NSLDS Enrollment Reporting (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal f...

Department of Education 2023-010 NSLDS Enrollment Reporting (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have made significant changes during fiscal year 2024 in the Office of Student Records to address controlled and non-compliance Title IV regulations. While significant changes were made, we recognize that additional improvements are needed. The Registrar will implement internal controls to ensure all Title IV requirements are met regarding enrollment reporting. In addition, the Registrar will create a student enrollment procedures manual and implement a monitoring process to ensure that enrollment statuses are reported accurately and timely to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kisha Bond Planned completion date for corrective action plan: The planned completion date for this corrective action will be August 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672. 2023-010 NSLDS Enrollment Reporting (JSU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Jackson State University has an established and published academic calendar which guides the day-to-day academic operations and functions of the University. In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report. To alleviate the untimely submission of the Enrollment Report, different practices have been established to aid students in completing their registration before the published deadline and subsequently ensuring the Enrollment file is submitted by the deadline. The University will adhere to published deadlines to prevent delays in reporting and error resolution. The University will enhance semester onboarding by: • Begin purge process earlier in the semester to ensure timely enrollment verification for each semester. • Increase communications between Office of the Registrar and Office of Financial Aid to weekly checks to discover and resolve resolutions within a 5-day window. This ensures we will meet the 10-day resolution deadline. Name(s) of the contact person(s) responsible for corrective action: Ozie Ratcliff, Director of Financial Aid and Lekesha Tubbs, University Registrar. Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the U.S. Department of Education has questions regarding these plans, please call Ozie Ratcliff at 601-979-3347. 2023-010 NSLDS Enrollment Reporting (UMMC) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Enrollment Management worked with DIS to create a supplement report (UMC RPT ST Student Academic Program Status Withdrawn, Dismissed or LOA-V2) to capture students whose enrollment status changes but is not picked up through monthly clearinghouse submissions. This report will run in tandem with our monthly clearinghouse report and any student with a status change not pulled on the clearinghouse report will be manually updated within the National Student Clearinghouse database by our Associate Director of Enrollment Services. These updates will then be reported to NSLDS, along with our monthly enrollment report. Name of the contact person responsible for corrective action: Dr. Emily Cole, Executive Director of Enrollment Management Planned completion date for corrective action plan: Effective immediately. The Office of Enrollment Management will begin utilizing the new report with the March enrollment file submitted to clearinghouse. If the U.S. Department of Education has questions regarding these plans, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386572 (2023-009)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency § 200.303

Department of Education 2023–009 Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the ...

Department of Education 2023–009 Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the student ledgers. Auditors’ Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner. CLA recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office will conduct bi-weekly reviews of enrollment changes, including university withdrawals. In addition, bi- weekly reviews of adjustment completion will be done to ensure banner adjustments are sent to COD within 10-14 business days. Name of the contact person responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the Department of Education has questions regarding this plan, please call Ozie Ratcliff at 601-979-3347.

View Audit 298874

Finding 386571 (2023-008)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Reporting Significant Deficiency Equipment & Real Property Management § 200.303

Department of Health and Human Services 2023-008 Head Start Program – Assistance Listing No. 93.600 Condition: The University filed the Real Property Status Report SF-429 after the deadline. Recommendation: We recommend the institutions review and revise its current reporting procedures and review r...

Department of Health and Human Services 2023-008 Head Start Program – Assistance Listing No. 93.600 Condition: The University filed the Real Property Status Report SF-429 after the deadline. Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that the reports are submitted accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi State University will review and revise the current reporting procedures for the SF 429: Real Property Status Report to ensure reports are submitted in accordance with established deadlines. Name(s) of the contact person(s) responsible for corrective action: Tucker, Director Sponsored Programs Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Jonathan Tucker at 662-325-1930.

View Audit 298874

Finding 386570 (2023-007)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

Department of Health and Human Services 2023-007 FFATA Reporting – Reports filed past the deadline – Assistance Listing No. 93.211 Condition: FFATA reporting was not submitted timely Auditors’ Recommendation: We recommend the institution strengthens their understanding of the reporting requirements ...

Department of Health and Human Services 2023-007 FFATA Reporting – Reports filed past the deadline – Assistance Listing No. 93.211 Condition: FFATA reporting was not submitted timely Auditors’ Recommendation: We recommend the institution strengthens their understanding of the reporting requirements established by the grant and ensure reports are filed timely Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The respective Supervisor of Post-Award Accounting or the Accounting Specialist position which handles this responsibility reviews a fully executed sub-agreement and they identify or determine if the applicable award, whether new or an amendment, meets the FFATA threshold. If the award meets the prescribed threshold, essential data are compiled from each applicable sub-agreement(s) via an internal Post-Award sub-award tracking spreadsheet for entry into the FSRS.gov. Effective September 2023, the above stated process is being completed no more frequently than weekly, and no less frequently than monthly. Once all data has been successfully entered and uploaded, the Supervisor, Accounting Specialist, or designee will confirm that the report has been successfully submitted via an email. Beginning March 2024, submitted reports are saved on the shared drive in a FFATA folder organized by fiscal year and month. The submission date will be incorporated into the name of the file to specifically identify the date the report was successfully submitted. Effective March 2024, once the FFATA reporting process is complete, notification is also made via email to the appropriate management personnel regarding the completion of this entire process as an additional internal control and to ensure compliance of this reporting requirement as identified in 2 CFR Part 170. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: March 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386541 (2023-001)

Significant Deficiency 2023

Balsz Elementary School District No. 31

AZ

Special Tests & Provisions Significant Deficiency

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Aracely Soto, Director of Finance Anticipated Completion Date: July 1, 2024 Planned Corrective Acti...

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Aracely Soto, Director of Finance Anticipated Completion Date: July 1, 2024 Planned Corrective Action: All bids that include laborers and mechanics employed by contractors or subcontractors to work on construction contracts must include language requiring prevailing wage rates, and the vendor must agree to provide copies of certified payrolls for all funded construction projects upon request. The District is not planning to use the Education Stabilization Fund for any future construction.

View Audit 298837

Finding 386537 (2023-006)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revis...

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revised ESSER data report to DOE. Anticipated Completion Date: Completed as of the date of this report.

View Audit 298830

Finding 386533 (2023-004)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

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

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur...

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO and Associate Superintendent will send a memo to principals and registrars defining documentation that must be maintained for mobility purposes. Anticipated Completion Date: 6/30/24

View Audit 298830

Finding 386522 (2023-002)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corre...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

View Audit 298830 Questioned Costs: $1

Finding 386517 (2023-001)

Significant Deficiency 2023

Howard County

MD

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

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was ...

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was focused on effectively managing the COVID funding during that time to help keep residents safely housed; therefore, the monitoring tasks for HOME-assisted TBRA were not completed as required. The Department is creating additional Standard Operating Procedures (SOPs) to ensure all steps are being taken to meet monitoring requirements, even if current personnel changes so the process can continue effectively and on time. Action taken in response to finding: The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). 1. Completion of a HOME/HOME-ARP Training Plan 2. Completion of a HOME/HOME-ARP Monitoring Completion Plan 3. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 4. Completion of an SOP for current and future continuity of function Regarding HOME-ARP funds: the rental units must comply with the same requirements as HOME per 24 CFR 92.251 for (a) new construction, (b)rehabilitation projects, (c)(1) and (2) acquisition of standard housing, (e) manufactured housing, and (f) on-going property condition standards. 1. These requirements are being added to the HOME/HOME-ARP Reports, as part of the Monitoring Completion Plan 2. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 3. Completion of an SOP for current and future continuity of function Name of contact person (s) responsible for the corrective action plan: Kim Zanti, Division Chief, Community Planning and Grants

View Audit 298820

Finding 386496 (2023-032)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the ALA staff recommendations. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386464 (2023-010)

Significant Deficiency 2023

State of Arkansas

AR

Subrecipient Monitoring Student Financial Aid Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: We agree with the auditor’s finding and recommendations, and the following corrective action will be taken to improve the situation: • The Director of Computing Services will oversee the review subsections of 16 CFR 314 to ensure complian...

Views of Responsible Officials and Planned Corrective Action: We agree with the auditor’s finding and recommendations, and the following corrective action will be taken to improve the situation: • The Director of Computing Services will oversee the review subsections of 16 CFR 314 to ensure compliance with requirements. o Perform a more thorough GLBA Risk Assessment, which will be used to improve the institution’s security policy and posture. This is outlined in 16 CFR 314(b). o Improve safeguards and more frequent testing to improve system security and threat transparency will be added, including email security and log file monitoring, in addition to other controls as outlined in 16 CFR 314(c) and (d). Several quotes have been acquired and are in the process of being reviewed. o Conduct a review of policies and training, as outlined in 16 CFR 314(e), and mitigate deficiencies in awareness training and policies. o Improve documentation around third-party service providers to ensure compliance with 16 CFR 314(f). o All response plans are to be reviewed and improved as needed because of the Risk Assessment and other monitoring activities to ensure appropriate activities are included and tested at regular intervals. o The institution will develop a compliance document to record efforts according to each section of 16 CFR 314, including those areas that are already compliant. It is the goal of SEARK College to remain in a state of continuous improvement and in compliance with required regulations. The Director of Computing Services will work with the Senior Leadership Team to ensure that appropriate resources are made available, and that activities occur in a timely manner. Anticipated Completion Date: The indicated reviews and assessments are already in progress, with a goal of June 30, 2024, to have fully integrated the stated improvements into our systems and procedures. Contact Person: Name: JoAnn Dupra Title: Director of Computing Services Agency: Southeast Arkansas College Address: 1900 Hazel St City, State, Zip: Pine Bluff, AR 71603 Phone Number: (870) 543-5993 Email Address: jdupra@seark.edu

View Audit 298801

Finding 386459 (2023-009)

Significant Deficiency 2023

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR...

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR 314 elements and financial aid data. As with our 2021 Risk Assessment, our plan will be reviewed and accepted by our Chancellor. We intend to have the Risk Assessment updated and reviewed by June 30, 2024. We will also coordinate the risks identified with the extensive list of controls and policies that currently protect student’s financial aid information. These include: Acceptable Use Policy_V7_3.pdf Antivirus and Malware Policy_V2_1.pdf Cloud Services Policy_V1_2.pdf Confluence Screenshots Of Contact Information For Critical Systems (1).pdf Data Classification Policy_V1_2.pdf Data Encryption Policy_V7_1.pdf Data Management Use Protection Policy_V7_2.pdf Data Protection Policy_V7_2 Data Protection Policy_V7_2.pdf Disaster Recovery Business Continuity System Recovery Prioritization List_V1_2.pdf Disaster Recovery Procedure_V1_5.pdf Drive Data Deletion Policy_V7_2.pdf E-Learning Policies_V7_1.pdf Email and Digital Communication Policy_V8_2.pdf Email and Digital Communication Policy_V8_2.pdf Employee Data Deletion Policy_V7_2.pdf Encryption of Sensitive Data on Transmission Policy_V7_2.pdf Faculty Senate Legislation Reference_V6.1.pdf Firewall Blacklist and Whitelist Policy_V7_2.pdf Firewall Management Procedure_V7_2.pdf GLBA Risk assessment.docx Incident Response and Forensic Analysis Procedures_V7_5.pdf IT Employee Departure Procedures_V7_2.pdf IT Security Awareness and Competencies Policy_V1_5.pdf IT Services System Administration Privileged Access Management Policy_V7_2.pdf IT System Backup Procedures_V7_2.pdf IT System Patching Process_V7_3.pdf Lab / Classroom Administrative Rights Exception Request_V6_1.pdf Local Firewall Procedures for Workstations and Mobile Devices_V7_2.pdf Log Review Policy_V2_1.pdf Mobile Device Security - Remote Email Destruction Process_V1_1.pdf Mobile Device Security Policy_V2_1.pdf Multi-factor Authentication - Information Technology Services - UA Little Rock.pdf Network Patching Process_V1_1.pdf PCI Compliance _ Training Policy_V7_2.pdf Physical Security Policy_V1_3.pdf Retention of Records Policies_V7_2.pdf Security and Incident Response Team Policy_V1_3.pdf Security and IT System Access Policy_V1_2.pdf Student Account Deletion Policy_V7_2.pdf System Log Requirements_V8_2.pdf UALR Change Management Policy 2.2.pdf Vendor Remote Access Policy_V1_1.pdf Vulnerability Scan Policy_V7_2.pdf Wireless Network Guest Security Policy_V1_1.pdf Wireless Security Policy_V1_2.pdf Workstation Administrative Rights Exception Request_V6_1.pdf Anticipated Completion Date: June 30, 2024 Contact Person: Name: Gerald J. Ganz, Jr. Title: Vice Chancellor for Finance & Administration Agency: University of Arkansas at Little Rock Address: 2801 S. University Avenue City, State, Zip: Little Rock, AR, 72204 Phone Number: 501-916-5622 Email Address: GJGanz@ualr.edu

View Audit 298801

Finding 386455 (2023-005)

Significant Deficiency 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the controls the ALA staff recommended. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386447 (2023-002)

Material Weakness 2023

Franklin County Medical Center, A Component Unit of Franklin Countyid

ID

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Corrective action planned: Utilize a CPA experienced with federal award to review and ensure compliance with grant proposals and activities. Anticipated completion date: April 30, 2024 Contact person responsible for corrective action: Jalen Tollefson, Grant Director

View Audit 298791 Questioned Costs: $1

Finding 386440 (2023-004)

Significant Deficiency 2023

T.a. Lawson State Community College

AL

Subrecipient Monitoring Reporting Significant Deficiency § 200.328

Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024

View Audit 298782

Finding 386431 (2023-003)

Significant Deficiency 2023

Elkhart and St. Joseph Counties Head Start Consortium

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports h...

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports have a documented, formal review of the reports before they are submitted to ensure the information submitted is accurate Anticipated Completion Date: April 2024

View Audit 298777

Finding 386404 (2023-001)

Significant Deficiency 2023

Municipality of San German

PR

Reporting Significant Deficiency

The Municipality of San Germán always issues the audit reports on time, the exception was on June 30, 2022 because this year the disaster of Hurricane Fiona passed for Puerto Rico. This complicated all the situation for the Municipality. For this year, the report will be filed on time.

View Audit 298745

Finding 386390 (2023-001)

Significant Deficiency 2023

Gleaners Food Bank of Indiana, INC

IN

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

U.S. Department of Agriculture 2023 - 003 Food Distribution Cluster – Assistance Listing No. 10.568, 10.569 Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Explanation of disagreement with audit finding: There i...

U.S. Department of Agriculture 2023 - 003 Food Distribution Cluster – Assistance Listing No. 10.568, 10.569 Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the process and procedures with department manager and new staff. Management will follow up quarterly to verify the process is completed accordingly. Names of the contact persons responsible for corrective action: Tiffany Stead and Joseph Slater Planned completion date for corrective action plan: 10/1/2023.

View Audit 298731

Finding 386386 (2023-001)

Significant Deficiency 2023

Fairleigh Dickinson University

NJ

Student Financial Aid Special Tests & Provisions Reporting

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Stude...

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Student Clearinghouse. To avoid any oversight in the future, the Office of Enrollment Services will enhance the edit report process and frequency. Effective immediately, the edit report will be generated every thirty days by the Compliance Officers to ensure all manual updates to a prior graduation are captured within the sixty-day requirement.

View Audit 298712

Finding 386309 (2023-005)

Significant Deficiency 2023

Marymount University

VA

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response ...

Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marymount University experienced high turnover in the Office of Financial Aid from the Director down to the counselor position in the 22-23 academic year. In that transition, Attain partners was contracted in late 2022 as interim staffing. For the one student in the finding that was found to have received a grade level 3 loan instead of level 2 based on the number of credits completed, research found that a rule setting in Ellucian Colleague caused the student to be auto-packaged at level 3 and it was accepted and disbursed in COD (Common Origination & Disbursement). Moving forward, Attain Partners will work with Marymount IT to update any rule settings to catch this issue and provide the Marymount Financial Aid office with internal controls that will catch any issues for the current aid year. Management notes that this issue arose due to a software programming error tied to an updated rule setting in Ellucian Colleague. Moving forward staff in Financial Aid will work in tandem with colleagues in Information Technology to review all updated rule setting in order to catch and address potential miscalculations. Name(s) of the contact person(s) responsible for corrective action: Meghan Sutton, Interim Director of Financial Aid, 703.284.1532 Planned completion date for corrective action plan: May 2024

View Audit 298705 Questioned Costs: $1

Finding 386305 (2023-004)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal...

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds will be processed weekly allowing enough time to correct any errors before the end of the 14 day period. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: March 2024

View Audit 298705

Finding 386304 (2023-003)

Significant Deficiency 2023

Marymount University

VA

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

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were a result of data entry or date errors. Moving forward the Registrar's Office will have a second staff member review files prior to submission to ensure the accuracy of the submission to the National Student Clearinghouse. The Registrar's Office will notify Financial Aid of NSC submission dates so the FA team can verify accuracy in NSLDS. Name(s) of the contact person(s) responsible for corrective action: Dr. Meghan Arias, University Registrar, 703-284-1526 Planned completion date for corrective action plan: 3/24/24 - date of next file submission

View Audit 298705

Finding 386303 (2023-002)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement wi...

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Acquired Isora GRC, a software tool to facilitate and document compliance with GLBA requirements and the corresponding NIST 800-171 information security framework. Management has also created an Enterprise Risk Management Committee which will incorporate compliance with GLBA as a top priority. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan by June 1, 2024, including decision regarding use of a third party or in-house resources to perform the risk assessment. Completion of 90% of action plan items within one year.

View Audit 298705

Corrective Action Plans

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