Corrective Action Plans

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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
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 review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Request a formal count of all graduates from Registrar at the end of each semester and review the number of exit counseling notifications sent from financial aid to ensure notifications are sent to all appropriate graduating students. Update procedures to reflect additional review. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
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 that the Col...
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 that the College review the updated GLBA requirements and ensure their WISP includes all required elements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024
Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division...
Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division (ASD) has processed the OPR for return of the $10,958 to the Department of Health. ALTSD will implement training for agency directors and other leaders who oversee and implement grant projects. This training will include the process for development of the initial budget allocations to appropriate categories grant procedures for requesting changes to the budget categories from the funder. The training will also include a process for streamlined communication between the director or manager and the ASD grant staff responsible for the financial controls. Timeline of Corrective Actions: Perform first training to any programmatic grant manager or involved staff by January 1, 2024. This will be ongoing any time a new grant award is received by the agency. Responsible Party(ies): Chief Financial Officer
U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individu...
U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate
View Audit 290553 Questioned Costs: $1
US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement...
US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The University is already utilizing Visual Compliance to assess all vendors for suspension and debarment but will obtain and document the review of the SOC 2 report for Visual Compliance annually. Name(s) of the contact person(s) responsible for corrective action: Scott Schlotthauer, Chief Procurement Officer. Planned completion date for corrective action plan: Immediately.
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU OKC: The Director of Financial Aid, Registrar, and Sr Director of Institutional Effectiveness developed a new process on reporting first of term, end of term, updates to enrollment, and processing errors in a timely manner. In addition, the Director of Financial Aid also added a step to the current OSU OKC R2T4 process. Financial Aid counselors will also be checking NSLDS on all students who populate on our R2T4 listing. Monthly, the Director of Financial Aid will select a small population to R2T4 and audit the information reported in NSLDS to ensure the new process is working correctly. OSUIT: OSUIT will shorten the dates for reporting to the NSLC to make sure the NSLC has sufficient time to report to NSLDS. Name(s) of the contact person(s) responsible for corrective action: OSU OKC: Elizabeth Lucas, Director of Financial Aid and Scholarships; Hank Lankford, Registrar; and Nick Irby, Senior Director of Institutional Effectiveness and Accreditation. OSUIT: Matt Short, Director of Financial Aid and Scholarships; and Crystal Palacioz, Registrar. Planned completion date for corrective action plan: OSU OKC: The completion date for the enrollment reporting has been implemented since the end of September 2023. The additional financial aid processes were implemented in October 2023 and will be fully completed by December 1, 2023. OSUIT: December 1, 2023.
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