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Finding 369982 (2023-003)
Significant Deficiency 2023
Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; Lehigh is aware ...
Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; Lehigh is aware of the 15-calendar day requirement and we have always met the deadline. Failure to report Pell Grant disbursements within 15 days in August of 2022 was the result of a well-documented Ellucian defect that denied Lehigh the ability to obtain the required data from our Banner system. By the time Lehigh received a patch from Ellucian, we had missed the 15-day window. Ellucian acknowledged the bug and Lehigh accepted that it was an anomaly. Name of contact: Jennifer Mertz, Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: September 15, 2022
Finding 369979 (2023-002)
Significant Deficiency 2023
Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Enrollment Reporting; Finding Type: Significant Defic...
Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Enrollment Reporting; Finding Type: Significant Deficiency; The training of new staff is always a priority, but this finding is the result of unusually high turnover in the registrar’s office during FY23. Staff have since been hired and are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes. Name of contact: Jennifer Mertz, Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: November 15, 2023
Finding 369978 (2023-001)
Significant Deficiency 2023
Federal Agency: U.S Department of Education; Program Name: COVID-19: Higher Education Emergency Relief Fund; Assistance Listing Number: 84.425F; Federal Award Year: Funding periods between April 28,2020 through June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; ...
Federal Agency: U.S Department of Education; Program Name: COVID-19: Higher Education Emergency Relief Fund; Assistance Listing Number: 84.425F; Federal Award Year: Funding periods between April 28,2020 through June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; Lehigh notes that this finding is the result of staff oversight. We are committed to strengthening our training and supervision of staff entrusted with compliance. The University will coordinate with HEERF regarding resubmission of the FY23 expense reports using the correct reporting template to accurately present all required information. Name of contact person: Dominic Wallitsch is responsible for reporting. Cynthia Kane, AVP of Research and Sponsored Programs is Mr. Wallitsch’s direct supervisor. Steven Crouch is the University Controller. Completion date: This will be complete when the FY24 annual reporting opens, which we expect before March 31, 2024
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported...
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure student enrollment is submitted to NSLDS in a timely manner, additional changes have been established. Students who have completed their degrees in a prior term (for example, summer/fall term), but with an award date in the next term (for example, September for summer term or January for the fall term), will be updated prior to the first of term enrollment file. This change will decrease potential errors as the terms are updated in the appropriate order and we can address any enrollment issues in the appropriate timeframe. Planned completion date for corrective action plan: January 31, 2024 Name(s) of the contact person(s) responsible for corrective action: Natalie Durant, Registrar at 860-768-5565.
Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Management of the University agrees with the finding. We do have policies and procedures in regards to re...
Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Management of the University agrees with the finding. We do have policies and procedures in regards to recordkeeping and retention of Perkins loan documents. Active, Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files with Heartland ECSI. The cancellation and deferment request for each Perkins loan made are electronically kept in our borrower files with Heartland ECSI. We typically retain original or true and exact copies of Master Promissory Notes (MPN). In some cases, the MPN may have been returned to the student during their entrance counseling. The Perkins loan program expired September 30, 2017. We are currently in the process of Assigning the remaining borrowers to close out our Perkins Loan Program. We are working as quickly and efficiently as possible. Staff availability will determine the completion date for this process. Planned completion date for corrective action plan: March 31, 2024 University Contact: Diane Purcell, Bursar Senior Accountant, (860) 768-4361
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting requirements to the Department if Education in respects to these requirements. Explanation...
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting requirements to the Department if Education in respects to these requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated the Department of Education Federal Student Aid website with the proper URL, effective January 23, 2024. Name(s) of the contact person(s) responsible for corrective action: Katherine Presutti, Director of Student Financial Aid at 860-768-4300.
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University designate an individual to oversee the information security function and work to update the Universities written security program to ensure ...
Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University designate an individual to oversee the information security function and work to update the Universities written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The University conducted a thorough gap assessment of our current GLBA procedures and the impending changes to the legislation that took effect in 2023. The assessment revealed the need to develop a comprehensive information security program that encompasses all nine elements of the GLBA Safeguards Rule. Our roadmap incorporates both existing practices and new measures to ensure that the resulting program meets the updated legislation's requirements. We are committed to ensuring the safety and security of our institution's sensitive information. Planned completion date for corrective action plan: April 15, 2024 Name(s) of the contact person(s) responsible for corrective action: Gregory Freidline, Director of Technology Services at 860-768-4272
Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corre...
Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future, the school corporation’s management will ensure a clause will be added to all contractor’s contracts stating they are following all Davis-Bacon wage laws when federal funds are being used to fund the project. Anticipated Completion Date: 02/16/2024
Finding 369697 (2023-002)
Significant Deficiency 2023
2023-002: Written Internal Control Policies and Federal Grant Award Procedures Finding Condition - The Town did not have written internal controls and Federal grant award policies in place. Corrective Action Plan - The Town will develop a written internal control policy and Federal grant award proc...
2023-002: Written Internal Control Policies and Federal Grant Award Procedures Finding Condition - The Town did not have written internal controls and Federal grant award policies in place. Corrective Action Plan - The Town will develop a written internal control policy and Federal grant award procedures in the coming months to comply with this finding.
Views Responsible Officials and Planned Corrective Actions: We concur with the observations and recommendations as placed forth by our auditors – KCM. We experienced personnel related issues and did not adequately have bench strength in place to compensate. To address: 1. We will file the outstandi...
Views Responsible Officials and Planned Corrective Actions: We concur with the observations and recommendations as placed forth by our auditors – KCM. We experienced personnel related issues and did not adequately have bench strength in place to compensate. To address: 1. We will file the outstanding reports. 2. Have initiated a review and update of a ministry-wide master deliverables schedule to ensure compliance with timely filings. 3. Will ensure multiple team members are familiar with and capable of completing the filing.
U.S. Department of Education 2023-001: NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that a student’s correct enrollment status and effective date was not reported to NSLDS. Recomme...
U.S. Department of Education 2023-001: NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that a student’s correct enrollment status and effective date was not reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College agrees with the recommendation to evaluate the procedures and policies related to reporting status changes to the Department of Education’s National Student Loan Data System (NSLDS). For many years, Carroll has contracted with the National Student Clearinghouse (NSC) for their comprehensive enrollment and graduate reporting services. They become an authorized agent, providing status updates to the NSLDS on our behalf. Carroll has begun a review, using the NSC and their resources and tools, to better understand why the student’s graduate status was not transmitted from the NSC to the NSLDS. Carroll staff will review the resources to ensure our procedures and processes meet the NSC expectations. Additionally, at the end of each term, the College will randomly select three students with status changes to verify that the reporting process to the NSLDS is accurate and timely. Name(s) of the contact person(s) responsible for corrective action: Mr. Gregg Bricca, Director of Institutional Effectiveness. Planned completion date for corrective action plan: 6/30/24
INDING 2023-002 – DAVIS-BACON COMPLIANCE – Significant Deficiency Planned corrective action: The School through the education services provider agreement with Entrepreneurial Ventures in Education (EVE) will train operations and business office staff on thecompliance requirements under Davis-Bacon t...
INDING 2023-002 – DAVIS-BACON COMPLIANCE – Significant Deficiency Planned corrective action: The School through the education services provider agreement with Entrepreneurial Ventures in Education (EVE) will train operations and business office staff on thecompliance requirements under Davis-Bacon to ensure construction contracts are entered into with qualified contractors and obtain and retain appropriate certified payroll documenta􀆟on during the construction period. Responsible officers: Carlo Hershberger, Director of Finance and Accounting; Javier Dimas, Vice- President of Operations; Martha Arellano, Procurement Manager and Buyer Estimated completion date: March 15, 2024
FINDING 2023-001 – DOCUMENT RETENTION – Significant Deficiency Planned correcive action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will provide additional training to school staff that are responsible for maintaining records that i...
FINDING 2023-001 – DOCUMENT RETENTION – Significant Deficiency Planned correcive action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will provide additional training to school staff that are responsible for maintaining records that identify the poverty levels of students enrolled. Additionally, EVE shall conduct an internal audit to ensure that documents are being collected and stored appropriately. Responsible officers: Lili Cruz-Gilbes, Regional Director of Compliance and State Reporting Estimated completion date: March 15, 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to firsttime borrowers to ensure they are in compliance with the Department of Education's regulations. Explanation of disagreement with audit finding:...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to firsttime borrowers to ensure they are in compliance with the Department of Education's regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We hold all first-time freshman loan funds for 30 days after the start to ensure we are not paying anyone early. Additionally, we will run an entrance term report prior to the start of the semester/term. From this report we can identify all first-time borrowers and tag them in populi. Prior to batching federal funds, the financial aid office will pull a report by said tag and ensure disbursements dates are 30 days from the start of the term/semester. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have created a Stale check policy & procedure. The financial aid department will work in concert with student accounts and accounts payable to ensure compliance. The process has checkpoints starting at 30, 60 up to 180 days. 60 days before a check reaches 240 days. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch, Kelly Reyes, Michael Warner, Christy Krahn and Vikki Straw. Planned completion date for corrective action plan: November 2023
View Audit 290967 Questioned Costs: $1
tudent Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disa...
tudent Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will review all student award packages at the midpoint of each semester to ensure no overawards exist. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch, and Kelly Reyes Planned completion date for corrective action plan: May 2024
View Audit 290967 Questioned Costs: $1
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disa...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely 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: After an analysis of the auditor's finding, ACU's director of financial aid, AVP of institutional effectiveness, and associate director of institutional research concluded that a misunderstanding of the National Clearinghouse's process for summer enrollment reporting was the cause of the finding. During the summer months of June, July, and August, ACU has been submitting enrollment reports, including withdrawals, only for students enrolled in summer terms. Withdrawals of students enrolled in the spring term were not being reported until after the fall term commenced. To remedy this finding, the Department of Financial Aid (FA) and the Office of Institutional Effectiveness (OIE) has coordinated with the National Student Clearinghouse (NSC) to identify which reporting method would ensure that all withdrawn students are accounted for and reported between the spring and fall terms. It was determined we would send custom files that include all withdrawn students in early June and July. The report will be uploaded through the NSC's secure file upload system at least once between May 30th and August 30th, with no more than 60 days between any two enrollment file submissions. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: May/June 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit fi...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The incorrect date was for a student who received the Pell Grant. When we batch Pell student awards in COD; and return funds at the same time, this will often cause a shortage in our Pell G5 account. This will delay the disbursement date on the school side. Although COD releases the disbursement, the funds are not available in G5 until days later and in some cases weeks later. The first step is to not process returns and draw downs at the same time. This will ensure the funds are in the Pell G5 acount so disbursment dates will match. The second piece is to audit the disbursement dates at the end of each semester to ensure we match. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023
The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting ...
The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting requirements and notify departments of upcoming submission deadlines.
Finding 369567 (2023-003)
Significant Deficiency 2023
#2023-003 – Significant Deficiency and Other Non-Compliance. Condition and context: Sampling of internal controls over payroll revealed 7 of the 240 transactions did not have timesheets approved by the employee’s supervisor, and for 2 of the 240 transactions, the employee was paid the incorrect am...
#2023-003 – Significant Deficiency and Other Non-Compliance. Condition and context: Sampling of internal controls over payroll revealed 7 of the 240 transactions did not have timesheets approved by the employee’s supervisor, and for 2 of the 240 transactions, the employee was paid the incorrect amount.. Recommendation: Reemphasize current policies and procedures to review timesheets, and payroll transactions. Planned corrective action: Current policies and procedures will be reviewed, and alternative approval procedures will be identified for instances when the employee’s direct supervisor is unavailable for timely approval. Implement additional audits during rollover process to correct administrative gap, which resulted in 2 payment amount errors. Responsible officers: James Dworkin, Chief Financial Officer and Martin Winchester, Chief Human Assets Officer Estimated completion date: March 31, 2024
View Audit 290922 Questioned Costs: $1
Finding 369473 (2023-003)
Significant Deficiency 2023
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhan...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhancing the documentation and reporting of our internal security audits. Person Responsible for Corrective Action Plan: Sean Gordon, Director of Information Technology Operations and Software Development Anticipated Date of Completion: June 30, 2024
Finding 369472 (2023-002)
Significant Deficiency 2023
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to trac...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024
View Audit 290692 Questioned Costs: $1
Finding 369428 (2023-004)
Significant Deficiency 2023
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid personnel will implement Return to Title IV FSA calculation spreadsheet for additional backup support in determining if banner has calculated return amounts correctly. Additionally, financial aid will require all R2T4 calculations to be secondarily reviewed and confirmed in RHACOMM. The scheduled breaks for each semester will be determined by the Director of Financial Aid and given to the Registrar to be input into banner module SOATBRK. These breaks are what banner then uses for Return to Title IV purposes. Update procedures to reflect additional actions. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
View Audit 290586 Questioned Costs: $1
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Univers...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Check Pell Calculation settings in banner and adjust, if needed, to achieve maximum accuracy based on student criteria (COA, EFC/SAI, Enrollment Status). Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
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