Corrective Action Plans

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Finding 371143 (2023-001)
Significant Deficiency 2023
Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are retur...
Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate the current refund process and make revisions to process to ensure any credit balances of Title IV aid are returned within the required timeframe. The university’s goals is to automate the refund process to reduce the chance of human error, and placing the refund process on a schedule to ensure refunds are processed within the appropriate window of time. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: September 9, 2024 – first rounds of Fall 2024 refunds
Finding 371140 (2023-002)
Significant Deficiency 2023
2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement w...
2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.
Finding 371135 (2023-001)
Significant Deficiency 2023
2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 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 Educatio...
2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 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 finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024
Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagre...
Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will notify the Vice President of Operations of disbursements and verifications, and the Vice President will complete a secondary review. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.
Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as suppo...
Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.
Finding 371070 (2023-002)
Significant Deficiency 2023
2023-002 Suspension and Debarment Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit findi...
2023-002 Suspension and Debarment Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A signed debarment letter is now a required document for vendors greater than $25,000. This letter is verified by our University procurement office before the item is purchased.   Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/6/2023
Finding 371066 (2023-001)
Significant Deficiency 2023
Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has upd...
Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has updated the WISP to include all of the required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated WISP to include all required elements. Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/19/2023
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete R2T4s. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not real...
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
Finding 371022 (2023-004)
Significant Deficiency 2023
2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period com...
2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 35 students that received all failing grades in a term, we tested five students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: The Provost’s Office has drafted a memo to faculty explaining the requirement to enter the last day attended for any student receiving a failing grade.  The Registrar’s Office has added this requirement to their routine reminders to faculty about entering grades.  The Clerk of the Faculty has agreed to bring this change in policy to the faculty to add to the Faculty Handbook in section 3.1.10 Reading Day, Final Examinations, and Course Grades.  Plan for auditing effectiveness of corrective action: The Register’s Office is turning on the requirement in Bannerweb (student system) that any F or NC grade cannot be entered in the system without a last date of attendance. An audit report will be able to be generated on this data. Responsible Party: Provost, Registrar, and Faculty, under the supervision of the Provost is responsible for implementing this corrective action plan and ensuring compliance. Point of Contact: Maria Rosales, Provost, mrosales@guilford.edu, 336-316-2205 Expected date of correction: April 2024
Finding Number: 2023-002 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Contact Person: Norine Bowers, Federal Programs Director and Jennifer Bosch, Finance Director Anticipated Completion Date: December 31, 2024 Planned Corre...
Finding Number: 2023-002 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Contact Person: Norine Bowers, Federal Programs Director and Jennifer Bosch, Finance Director Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District does not believe that an internal control issue exists but does acknowledge that procedures will be implemented in order to maintain adequate backup supporting documentation for grant programs in the future.
2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no d...
2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024
2023-003 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 disagree...
2023-003 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 are working with IT to allow for the auditing of uncashed checks to be an action that can be fulfilled with minimal human resource used. We have resumed the monthly audit of student uncashed Title IV resources. Name of the contact person responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: February 29, 2024
View Audit 292587 Questioned Costs: $1
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit ...
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and 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: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Data Coordinator o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Kurt Jarvi, Systems Analyst Based on the previous audit, adjustments were made to the timing of the Clearinghouse enrollment submissions. This has been accomplished with enrollment being reported every month on the same date to enable automated submissions. As we tried to systematize graduation reporting, we encountered multiple technical issues. These issues involved both Information Technology and the Clearinghouse, which resulted in a delay in the reporting of graduates from May through August 2023. Additional training has been provided by the Clearinghouse and other sources which have been viewed by those involved in Clearinghouse reporting. We have also sought the advice from other institutions who report to the Clearinghouse. Our corrective action will involve several parts. • First, we will add more graduation only submissions to our Clearinghouse schedule to ensure they are getting reported in a timely manner. • Second, we will investigate where our Clearinghouse reports are pulling the graduation date form our Student Information System (Banner) to ensure those fields are accurate. • Third, we will review our process for determining degree conferral dates to ensure it aligns with our reporting schedule. • Fourth, over this past summer (2023) we worked with staff to clarify student withdrawal procedures. We will continue to do that. • Fifth, we will continue to take advantage of Clearinghouse training and other related training opportunities. • Sixth, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2024
Finding 370857 (2023-001)
Significant Deficiency 2023
A recalculation of the student financial aid was completed using the corrected spring semester start date. The corrected financial aid was credite to the student's account.
A recalculation of the student financial aid was completed using the corrected spring semester start date. The corrected financial aid was credite to the student's account.
Finding 370808 (2023-004)
Significant Deficiency 2023
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University has a procedure in place for the Director of Information Technology and the rest of the Technology team to review and update our Security and Incident response plans to ensure compliance with GLBA standards bi-annuall...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University has a procedure in place for the Director of Information Technology and the rest of the Technology team to review and update our Security and Incident response plans to ensure compliance with GLBA standards bi-annually. In addition, we will work with our information security provider quarterly to ensure all our assets and vendors meet security standards. Person Responsible for Corrective Action Plan: Matt Wilson, Director of Information Technology Anticipated Date of Completion: Effective Immediately, February 15, 2024
Finding 370807 (2023-003)
Significant Deficiency 2023
Incorrect Pell Calculations Planned Corrective Action: The University will provide oversight and review of Pell calculations on a weekly basis. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February...
Incorrect Pell Calculations Planned Corrective Action: The University will provide oversight and review of Pell calculations on a weekly basis. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February 15, 2024
View Audit 292492 Questioned Costs: $1
Finding 370805 (2023-002)
Significant Deficiency 2023
Inaccurate Return of Title IV Funds Calculations Planned Corrective Action: The University will work with FA Solutions weekly to ensure funds are calculated correctly and timely returns of IV Funds are processed. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Ser...
Inaccurate Return of Title IV Funds Calculations Planned Corrective Action: The University will work with FA Solutions weekly to ensure funds are calculated correctly and timely returns of IV Funds are processed. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February 15, 2024
Condition: There was a lack of timely account reconciliations performed by the Organization to ensure all withdrawals from the replacement reserve account had proper HUD approval and all required monthly deposits were made. During the year ended June 30, 2023, withdrawals of $4,202 and $4,025 were m...
Condition: There was a lack of timely account reconciliations performed by the Organization to ensure all withdrawals from the replacement reserve account had proper HUD approval and all required monthly deposits were made. During the year ended June 30, 2023, withdrawals of $4,202 and $4,025 were made from the replacement reserve without HUD authorization, and the Organization failed to increase the monthly reserve from $1,723.67 to $2,249.54 for May and June of 2023. Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance and is implementing measures to improve this internal control over compliance. The underfunded amount of $9,279 was deposited to the reserve for replacement account on July 28, 2023. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: July 28, 2023
Condition: The University did not return Title IV funds within the required time frame for certain students who required a post withdrawal disbursement. Planned Corrective Action: In response to identified delays in returning Title IV funds within the stipulated time frame for post withdrawal disbur...
Condition: The University did not return Title IV funds within the required time frame for certain students who required a post withdrawal disbursement. Planned Corrective Action: In response to identified delays in returning Title IV funds within the stipulated time frame for post withdrawal disbursements, an immediate corrective action plan has been initiated. This plan involves a thorough review of internal processes to identify and rectify procedural gaps contributing to the delays. Staff training sessions are being conducted to reinforce understanding and compliance with Title IV regulations, with a particular emphasis on the importance of timely disbursements. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: December 2022
Finding 370779 (2023-006)
Significant Deficiency 2023
After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit suppor...
After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit support to further explore this scenario and determine what would need to be changed with field mapping and review, if anything. Anticipated Completion Date: June 1, 2024 Person Responsible for Corrective action: Cecil (Rock) McCaskill, Associate Registrar Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370778 (2023-005)
Significant Deficiency 2023
The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks....
The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks. Student Financial Services staff will communicate with students who have outstanding checks as a proactive measure to decrease the volume of uncashed stale-dated checks. Anticipated Completion Date: October 31, 2023 Person Responsible for Corrective action: Rebecca Pruitt, Director of Student Financial Services Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370777 (2023-004)
Significant Deficiency 2023
The Office of Student Financial Aid will engage with the Office of Internal Audit (IA) to review the FISAP, and if any errors are found, will make corrections during the allotted time in December. Supporting schedules are centrally stored and will be made available to IA. Anticipated Completion Date...
The Office of Student Financial Aid will engage with the Office of Internal Audit (IA) to review the FISAP, and if any errors are found, will make corrections during the allotted time in December. Supporting schedules are centrally stored and will be made available to IA. Anticipated Completion Date: December 1, 2023 Person Responsible for Corrective action: Elizabeth Milam, Director of Financial Aid Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370776 (2023-003)
Significant Deficiency 2023
We will continue to proactively monitor for system data irregularities and take corrective action as needed. We have implemented a weekly review of Banner to COD data for Pell disbursement activity to quickly identify and resolve discrepancies. A senior staff member completes this review with findin...
We will continue to proactively monitor for system data irregularities and take corrective action as needed. We have implemented a weekly review of Banner to COD data for Pell disbursement activity to quickly identify and resolve discrepancies. A senior staff member completes this review with findings reported to management to determine if further action is required. Anticipated Completion Date: Tested plan of action, applied corrections and verified successful resolution as of March 1, 2023. Corrective action plan implemented March 9, 2023. Person Responsible for Corrective action: Elizabeth Milam, Director of Financial Aid Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370770 (2023-002)
Significant Deficiency 2023
The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person ...
The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person Responsible for Corrective action: Karen Robbins, Director of Financial Compliance Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
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