Corrective Action Plans

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U.S. Department of State U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no dis...
U.S. Department of State U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing
U.S. Department of Health and Human Services and U.S Department of State Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organizati...
U.S. Department of Health and Human Services and U.S Department of State Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing
Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This revi...
Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN’s Office of Grants and Contracts Po...
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN’s Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) to review expenses and avoid this issue in the future. CSN Office of Grants & Contracts Post-Award Management will continue to advise the departments that expenses associated with canceled events will be removed from the grant, unless the sponsor allows the costs to remain on the grant. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will maintain communication with PIs and employees to identify any costs associated with canceled events and ensure only necessary and reasonable costs are charged to the grant. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of du...
Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in questi...
Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in question. GBC is very willing to enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. o GBC has strengthened internal controls over payroll expenditures charged to federal grants to ensure documented review and segregation of duties, particularly for terminated employees. o Documented evidence of review and approval will be retained within the payroll/grants file to ensure a clear audit trail. o Human Resources and Grants Accounting staff have been reminded of federal documentation requirements specific to grant-funded payroll expenditures. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Quarterly internal reviews of payroll expenditures charged to federal grants, with specific review of terminated employees. o Retention of documented approval evidence in electronic grant files. o Review during annual fiscal year-end grant reconciliations. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and Director of Business Operations are responsible for oversight of grant compliance. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review ...
Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On...
Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on al...
Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the...
Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the r...
Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Auditor Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. Corrective Action. The University will create a formal Banking Services Agreement with the Financial Institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Lack of Review and Timely Filing of Financial Status Reports (Repeat finding) Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission peri...
Lack of Review and Timely Filing of Financial Status Reports (Repeat finding) Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Auditor Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. Corrective Action. The University will establish and follow an internal controls policy that requires review and approval prior to submitting financial status report timely. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the Uni...
Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the University is out of compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked and no changes made without proper review and approval. Corrective Action. The University will implement a review process to ensure that all student budgets are reviewed and locked. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester s...
Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. As a result of this condition, the University is not in compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Bienestar (Wellbeing) For All; ESNMS: Title V DOE Grant (Ensuring Success for the New Majority Student) – Assistance Listing No. 84.031S Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarmen...
Bienestar (Wellbeing) For All; ESNMS: Title V DOE Grant (Ensuring Success for the New Majority Student) – Assistance Listing No. 84.031S Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University implemented a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, effective May 2025, outlines roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: Completed
Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSL...
Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSLDS, especially around graduated enrollment information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed
Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no dis...
Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend 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 disagre...
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend 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 taken in response to finding: Augsburg University will update its Written Information Security Program to: * More fully document the processes and procedures to dispose of customer information securely * Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. Names of the contact persons responsible for corrective action: Scott Krajewski Planned completion date for corrective action plan: May 31, 2026
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 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 disagreeme...
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 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 audit finding. Action taken in response to finding: Student Financial Services is working with the Registrar to update our reporting practices for students with student teaching requirements. The registrar has connected with the Clearinghouse to confirm and utilize a separate file type for this population, which should resolve the reporting date issue. Name of the contact person responsible for corrective action: Catherine Maun Planned completion date for corrective action plan: May 31, 2026
Corrective Action Plan: The Division will implement a review process to ensure the accuracy of the inventory management and reporting process. Anticipated Date: April 2026 Name of Person Responsible for Implementation: Al Agpoon, Controller
Corrective Action Plan: The Division will implement a review process to ensure the accuracy of the inventory management and reporting process. Anticipated Date: April 2026 Name of Person Responsible for Implementation: Al Agpoon, Controller
2025-001 Finding – Significant Deficiency in Internal Controls over Cash Management Context and Cause – It was noted during the audit that there was not a documented review of the selected cash draws for the program tested. Internal controls should be designed to include a documented supervisory rev...
2025-001 Finding – Significant Deficiency in Internal Controls over Cash Management Context and Cause – It was noted during the audit that there was not a documented review of the selected cash draws for the program tested. Internal controls should be designed to include a documented supervisory review of cash draw requests to ensure accuracy, proper authorization, and compliance with program requirements and the Code of Federal Regulations 200.303. PYB is aware of our Policy for a documented review, but due to competing priorities and impact on workload, the Fiscal Director did not consistently perform the control during the time period that was tested. Auditor Recommendation – Kern & Thompson recommend that PYB re-implement the procedure noted in the prior year, where a supervisor’s initials and date of review was documented on the support for each cash draw, prior to draw down of federal funds. Action Taken – PYB implemented a similar, improved review procedure effective with the October 2025 draw, submitted December 17, 2025. The new procedure uses email to provide documents for review and to document approval of the draw. The Fiscal Director is responsible for submitting cash draws and must send the email to both the Executive Director and the Accountant for review. Each month's emailed documentation includes the DOL income statement for the month (showing the amount for reimbursement); a confirmation that supporting documentation has been attached to the draw request; and a draw confirmation confirming the date of submission, the amount, the date funds should be deposited to PYB’s account, and the justification required for the payment. The Fiscal Director also includes information about the amount of funds remaining on the grant award. After reviewing the documents, the Executive Director replies with approval.
Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over f...
Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with applicable laws, regulations, and the terms and conditions of the award. Effective internal control includes appropriate independent review of reports to ensure accuracy prior to submission. During our testing over the report submissions for the fiscal year, we noted there was not an independent review completed over the quarterly expenditure report. Responsible Individuals: Michael Pollock, CFO and Debbie Dice, Director, Financial Reporting, Audit/Compliance Corrective Action Plan: There was transition in several of the key roles during the fiscal year, causing the review not to be completed over the quarterly submissions that will be rectified during 2025-26. Internal controls will be updated with the following steps: 1) Quarterly federal expenditure reports will be prepared by the an assigned Accountant II member and reviewed by a the Director of Financial Reporting, Audit and Compliance prior to submission to the granting agency; 2) Obtain evidence of the independent review, including reviewer sign-off and date of review, will be documented and retained with the report submission records; 3) The College will update written internal control procedures governing federal grant reporting to formally incorporate the independent review requirement; and 4) The Director of Financial Reporting, Audit and Compliance will monitor adherence to the review process and ensure that documentation is maintained for audit purposes. Anticipated Completion Date: June 2026
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(...
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Responsible Individuals: Frankie Everett, Director, Financial Aid Corrective Action Plan: The College implemented a new ERP system in the current year that caused delays in notifying students of their loan disbursements. PowerFAIDS allows documenting the email sent to students in the Communication Log, but a box has to be checked when the email batch is sent. This step was inadvertently missed in several batches so we cannot confirm the email was sent. The Department is working to automate the emails with a college-hired consultant. In the meantime, the Financial Aid Operations Coordinator (Jessica Jones) is double-checking that disbursement emails are going out each week. Anticipated Completion Date: June 2026
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate report...
Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the students’ last date of attendance did not agree to the students’ withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Rogue Community College has implemented corrective actions to strengthen internal controls and ensure the accurate reporting of student enrollment statuses to the National Student Loan Data System (NSLDS). The College now utilizes withdrawal reports to systematically identify students who have withdrawn from all enrolled courses. These reports are reviewed to verify each student’s official withdrawal date prior to submission to NSLDS. For students who receive non-passing grades, the College reviews and reports the last date of attendance, when applicable, to ensure accurate determination of the student’s withdrawal date. As additional internal control, the College conducts term-end audits of withdrawal dates and last dates of attendance to confirm that enrollment status changes have been reported accurately and in accordance with federal requirements. Any discrepancies identified through this review process are corrected promptly. Additionally, the College utilizes graduation reports to verify that students who have completed all program requirements within their declared major are appropriately reported to NSLDS with an enrollment status of Graduated. Through these enhanced monitoring and verification procedures, Rogue Community College is confident that enrollment status changes are reported accurately and in compliance with the requirements outlined in 34 CFR 690.83(b)(2) and 34 CFR 685.309. Anticipated Completion Date: October 2025
The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a stand...
The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a standard process is to be completed for every calculation. The District will implement a mandatory secondary review of all Return to Title IV calculations prior to processing returns or post-withdrawal disbursements.
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