Corrective Action Plans

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Finding 387723 (2023-001)
Significant Deficiency 2023
Recommendation: We recommend the College evaluate its policies and procedures for identifying and reporting enrollment status changes to ensure that all changes are reported to NSLDS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding....
Recommendation: We recommend the College evaluate its policies and procedures for identifying and reporting enrollment status changes to ensure that all changes are reported to NSLDS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The College has recently updated their Student Information System (SIS) to a less manual program. Formerly, the College used SONIS, but as of February 2023 has moved to Jenzabar One (J1). The J1 system is more robust than the SONIS system and is interfaced with the Financial Aid Management (FAM) system the College uses – PowerFAIDS. With the capability of the systems communicating with each other, the College can implement real-time internal reconciliation that can quickly identify issues with the dates, amounts, etc. and will allow the departments to work quickly to resolve exceptions found related to compliance of the dates, amounts, etc. Since the change-over to J1, the reconciliation process has been more efficient and has allowed for quick resolution of discrepancies identified. Name(s) of the contact person(s) responsible for corrective action: Daphne Parks, Vice President of Processing at FAS; Stephanie Knight, Director of Enrollment Services & Financial Aid, Beacon College; Carrie Santaw, Registrar, Beacon College Planned completion date for corrective action plan: Completed.
Finding 387722 (2023-002)
Significant Deficiency 2023
Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In Beacon’s previous student bill...
Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In Beacon’s previous student billing system (Sonis, in use until February 2023), Beacon had recuring difficulties posting certain transactions to student accounts, causing Financial Aid staff or the Jenzabar program administrator to work behind the scenes to get transactions entered. Since our conversion to Jenzabar J1, we have not encountered these difficulties. Secondly, a schedule of posting transactions to the student accounts has been established depending upon when the transaction is received from Financial Aid. This schedule should ensure that posting of transactions is performed timely and predictably. Name(s) of the contact person(s) responsible for corrective action: Daphne Parks, Vice President of Processing at FAS; Stephanie Knight, Director of Enrollment Services & Financial Aid, Beacon College Planned completion date for corrective action plan: Completed.
Corrective Action Plan - Online Purchases. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that supporting documentation is maintained for all online purhases. Anticipated Completion Date - Within the next fiscal year.
Corrective Action Plan - Online Purchases. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that supporting documentation is maintained for all online purhases. Anticipated Completion Date - Within the next fiscal year.
View Audit 299775 Questioned Costs: $1
Corrective Action Plan - Unauthorized ACH Payments. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that all ACH payments are adequately documented and approved. Anticipated Completion Date - Within the next fiscal year.
Corrective Action Plan - Unauthorized ACH Payments. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that all ACH payments are adequately documented and approved. Anticipated Completion Date - Within the next fiscal year.
View Audit 299775 Questioned Costs: $1
Beginning 11/1/2023, Sustainable Food Center began allocating all benefits based upon the allocation of employee’s time assigned to each department and or grant on an actual basis monthly. This is completed by identifying each component of benefits by person in an excel file and then using the % of ...
Beginning 11/1/2023, Sustainable Food Center began allocating all benefits based upon the allocation of employee’s time assigned to each department and or grant on an actual basis monthly. This is completed by identifying each component of benefits by person in an excel file and then using the % of time applied to each department or grant for the corresponding month. The controller enters the information into the excel spreadsheet and is viewed by the CFO for correctness. The CFO will be responsible for implementing the corrective action plan above.
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 2023-004 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 2023-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires Independent School District No. 283 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements. The District did not have sufficient controls 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 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 – Patricia Magnuson, Director of Business Services. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Patricia Magnuson, Director of Business Services, will assure appropriate controls are in place, and will review internal control procedures relating to suspension and debarment to ensure they are in line with the Uniform Guidance requirements.
Business Services Staff will ensure that financial account balances are thoroughly reviewed and supported by appropriate documentation. Prior to any report submittal, an administrator will verify documentation fo raccuracy. This will create a system for verification of supporting records that will f...
Business Services Staff will ensure that financial account balances are thoroughly reviewed and supported by appropriate documentation. Prior to any report submittal, an administrator will verify documentation fo raccuracy. This will create a system for verification of supporting records that will facilitate accurate tracking of balances during reporting periods.
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no ...
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The university completed phase one of the corrective action plan with the practice of matching the program begin date to the term date for new students last year. Accuracy is monitored with reports. No repeat findings found on this population of students. The audit recommendation focuses on continuing students. The university is now in the process of completing phase two, continuing students. Existing active programs will be manually updated by the Registrar’s Office; steps for resolution are already in progress. Using reports to capture students, the team will update the student information system, NSLDS, and NSC, correcting the program begin date to match the term date. This process change will align our reporting procedures with required regulations prior to the close of the 2023 fiscal year (July 2024). 2) The Registrar’s team will provide ongoing instruction to all personnel who have access to process program changes in the student information system. The instructions will direct users to match the begin date of the new program with the term; exceptions will be addressed in the communication. Changes will be monitored by the Registrar’s Office with daily reports. Repeat finding, see 2022-003, item 2. CAP phase 2 focuses on continuing students and is still in process, this involves identifying continuing students with mis-matched data and making the appropriate corrections. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: July 2024
Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with ...
Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university is researching ways to ensure accuracy in the data entry of withdrawal dates into the system of record. The current process is manual data entry by advising staff creating an opportunity for human input error. Options are being reviewed and could include an integration between the system of record and the eForm the data is collected on or a report that will compare the withdrawal date entered into the system to the source data. Repeat finding, see 2022-002: CAP Completed. Prior year finding had to do with manual data entry directly into the R2T4 calculation. No repeat findings were found in this area of data entry. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: December 2023
View Audit 299743 Questioned Costs: $1
Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basin...
Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basing program length by weeks. With respect to the program change date record retention issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include retraining of staff to reinforce the necessity of retaining the records, providing adequate secure storage facilities for paper records and conducting regular quality control exercises to ensure that this issue does not re-occur. Proposed completion date: June 30, 2024
Finding 387659 (2023-001)
Significant Deficiency 2023
Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Lo...
Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Loans ended September 30, 2017. Middlebury has not lent Perkins Loans to borrowers since the 2017-18 academic year, thus not creating any new Perkins Loan promissory notes.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year findings 2022-004, 2021-005, 2020-006 and 2019-006) (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23, FY22, FY21, FY20 and FY19 Pass-through: All applicable M...
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year findings 2022-004, 2021-005, 2020-006 and 2019-006) (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23, FY22, FY21, FY20 and FY19 Pass-through: All applicable Management comments: Management is working with IT to implement enhancements to the ERP system to address improvements to the remeasurement process. We are targeting implementation of daily exchange rates in our ERP system by June 30, 2024. To address issues related to the translation of functional currency balances and transactions from SAP into PII’s reporting currency management is developing a new methodology within the BPC consolidation system which will be effective for FY24 closing. In parallel, management is reviewing the financial manual to provide additional guidance on the correct treatment of foreign exchange transactions including the translation from functional currency to presentation currency in line with US GAAP Accounting Standards. The system changes and updates to the manual will be accompanied by training to be rolled out to all relevant staff to ensure that the revised guidance is understood and adhered to. (Corrective actions introduced in FY24 will be project planned and reviewed through the FY24 year-end close to a final resolution with an anticipated closure by 30 June, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)
Ref 2023-003: Classification, completeness, and accuracy of bank accounts (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23 Pass-through: All applicable Management comments: Management is aware of the importance of maintaining complete ...
Ref 2023-003: Classification, completeness, and accuracy of bank accounts (significant deficiency) Federal Agency: All Program: All Assistance Listing: All Award #: All Award year: FY23 Pass-through: All applicable Management comments: Management is aware of the importance of maintaining complete and accurate list of bank accounts. During FY24, Management will implement the following changes: 1. The Global Finance Manual will be updated to ensure that there is an appropriate level of review of bank opening and closing at CO, RH and GH level, specifically addressing the point around receiving a formal closure letter from the bank when accounts are closed. 2. A new SAP report which generates a list of all bank accounts including opening and closing dates and account name and number will be developed during FY24. The new report will include a consolidated bank reconciliation for all bank accounts which will have the effect of simplifying the review at CO, RH and GH level. 3. Global Hub has been working with the Global Assurance team to implement an internal review of the bank reconciliation, listing and confirmation of the balances with Banks to ensure accuracy, completion, and existence of bank balances. (Corrective actions introduced in FY24 will be project planned and reviewed through the FY24 year-end close to a final resolution with an anticipated closure by 30 June, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the neces...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the necessary procedures for returning Title IV funds. Implementation Date: 6-23-23
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submittin...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submitting NSLDS reports. Implementation Date: In Progress
The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring ...
The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring and summer sessions. We have identified the multiple start dates as a primary challenge with timely reporting and have initiated corrective actions to synchronize program dates more closely with the standard academic calendar. This includes the phasing out of a summer header student cohort to prevent similar issues in the 2024-2025 academic year. A bi-weekly reconciliation report has been created to review activity and identify early discrepancies to maintain better internal controls. During the 2021-2022 aid years, the Financial Aid office had four Financial Aid directors with different approaches to aid awarding strategy. The current Director is focused on refining processes to enhance internal controls. Additionally, the College recognized a need for staff professional development and training and engaged a Financial Aid consultant to review our systems and processes. The Financial Aid consultant now conducts quarterly assessments to help us maintain our setups and provides ongoing training for our team. These steps are in line with best practices and are part of our commitment to minimizing errors and conducting timely financial aid reporting. The College has made significant improvements. The number of selected records failing the 15-day COD reporting window decreased from 15 in FY22 to 4 in FY23.
Recommendation: The Academy should develop procedures to have the financial aid and financial accounting information systems reconciled monthly. Corrective Action: A policy to review and reconcile the FISAP data between Financial Aid and Finance departments, prior to submitting the FISAP to the Depa...
Recommendation: The Academy should develop procedures to have the financial aid and financial accounting information systems reconciled monthly. Corrective Action: A policy to review and reconcile the FISAP data between Financial Aid and Finance departments, prior to submitting the FISAP to the Department of Education, will be implemented. Person Responsible for Corrective Action: Eric Pryor, President and CEO
Recommendation: The Academy should review and revise its controls over compliance to ensure that the School Account Statement reconciliations are performed monthly. Corrective Action: A procedure to reconcile School Account Statements monthly will be implemented. Person Responsible for Corrective Ac...
Recommendation: The Academy should review and revise its controls over compliance to ensure that the School Account Statement reconciliations are performed monthly. Corrective Action: A procedure to reconcile School Account Statements monthly will be implemented. Person Responsible for Corrective Action: Eric Pryor, President and CEO Anticipated Completion Date for Corrective Action: The Corrective Action will be immediately implemented in response to the auditor’s recommendation.
Action taken in response to finding: NCLE will: 1) Run a list (through Paychex) of employees that have been terminated and/or hired within the last pay period prior and the current pay period 2) Identify names on list with any employee who is currently receiving pay within the current pay period. 3...
Action taken in response to finding: NCLE will: 1) Run a list (through Paychex) of employees that have been terminated and/or hired within the last pay period prior and the current pay period 2) Identify names on list with any employee who is currently receiving pay within the current pay period. 3) Any employee on the list whether new hire and/or terminated verify that the amount being paid to the employee is correct. 4) Termed employee may still have ELT (Earned Leave Time) accrued and is due payment within the current pay period. The termed employee may have worked partial hours within the current pay period. Salary termed employee is due full payment within the last pay period the employee worked. 5) A new hire employee who is salaried will receive a pro-rated rate of pay for the first payroll. 6) Upon termination and/or new hire being enacted Management will forward termination and/or new hire notices to the Human Resource Department. 7) Human Resource Department will be entering (into Paychex) termination and/or new hire data as soon as they are received from management Names of the contact persons responsible for corrective action: Sue Firkus, CFO and Tim Nolan CEO Planned completion date for corrective action plan: Approved by our Board and Policy Council on February 26, 2024. Will be implemented immediately following this approval. The full current year within which we are operating as well as each upcoming fiscal year will be covered by this plan.
View Audit 299674 Questioned Costs: $1
Department of Health and Human Services BRHC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 through June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered con...
Department of Health and Human Services BRHC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 through 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 U.S. Department of Health and Human Services 2023-001 Provider Relief Funding – Assistance Listing No. 93.498 Recommendation: We recommend the Organization review calculations to ensure that the proper amounts are used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Blue Ridge’s inventory system reports item prices based on average purchase price. Blue Ridge’s materials management staff has a process in place to update inventory item prices on an as-needed basis. In the event a price is in error, the issuance price is manually updated with a credit given to the department where expense was incorrectly reported. For future reporting of inventory issuance costs, an additional level of review will be added to validate cost reported are accurate. Name(s) of the contact person(s) responsible for corrective action: Pat Moll, Chief Financial Officer Planned completion date for corrective action plan: 03/27/2024 If the Department of Health and Human Services has questions regarding this plan, please call Pat Moll, CFO at 828-580-5003.
View Audit 299640 Questioned Costs: $1
Finding 387414 (2023-003)
Significant Deficiency 2023
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Respo...
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We are working to formalize this process by creating a written participant file review policy and procedure. Anticipated Completion Date: March 31, 2024
Finding 387391 (2023-001)
Significant Deficiency 2023
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible...
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We will be updating our cash receipts process as part of an overall review of our accounting and financial policies and procedures that will include improvements in our internal control system. Anticipated Completion Date: Updated accounting and finance policies and procedures will be completed and implemented by the end of FY24.
Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expe...
Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expenditure approval process, as well as the process for maintaining records supporting all transactions. The policies in place require WISH management to approve all expenditures utilizing a requisition request form which includes a signature field for the initiator, a supervisor, and the Executive Director. WISH management will mandate that all requisition forms are signed (physically or digitally) to ensure compliance with the policy. In order to ensure compliance, WISH will conduct sessions to review the policies with staff and assign a team member to monitor adherence to the policies. Additionally, WISH policies require expenditure support for each transaction including physical and digital receipts and invoices. WISH management will conduct sessions to ensure knowledge of the existing procedures with staff. WISH will assign a team member to review compliance on a monthly basis to ensure compliance. Proposed Completion Date: June 30, 2024
Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clea...
Condition: The University did not report certain students' status changes timely to the National Student Loan Data System (NSLDS). Planned Corrective Action: Management has implemented a change in the reporting timeline to ensure that there is adequate time between reporting to National Student Clearinghouse and their reporting to NSLDS. In addition, University management will monitor reporting of status changes to NSLDS. Contact person responsible for corrective action: Robert Kubat, Assistant Vice President of Enrollment Management and University Registrar Anticipated Completion Date: 06/30/2024
2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The colleg...
2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The college disagrees with this finding, related to the reporting of five graduate files to NSLDS. The finding states the five files were reported 12 days late of the 60-day reporting requirement. Per section 4.4.2 of the NSLDS Reporting Guide, it is not required that an update be received by NSLDS within two months of the Enrollment Status Effective Date, but rather in the next scheduled enrollment submission. Evidence the graduation status was reported in the next scheduled enrollment submission was provided to the auditors. Action taken in response to finding: The College will continue to closely monitor NSC/ NSLDS reporting schedule and check for transmission errors to ensure compliance with reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24
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