Corrective Action Plans

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Responsible Contact Person(s): Steve Hanoka, Information Security Officer Corrective Action Planned: Third-party Management that will cover ensuring all deliverables required are part of a procedure and work instruction. In addition, to specifically address the points in the finding, ISO will ensure...
Responsible Contact Person(s): Steve Hanoka, Information Security Officer Corrective Action Planned: Third-party Management that will cover ensuring all deliverables required are part of a procedure and work instruction. In addition, to specifically address the points in the finding, ISO will ensure that the work instructions cover obtaining a confirmation on the geographic location of sensitive data monthly and vulnerability scan results at least every 90 days.  During this procedure implementation, ISO will also work to specifically obtain these deliverables from the vendor in question.  Estimated Completion Date: 3/31/2025
Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: Language has been added to the Conduent contract renewal for option years 1 and 2 to require the SOC 1 Type II. The renewal is in the process of being reviewed and executed to go into effect July 1, 2025...
Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: Language has been added to the Conduent contract renewal for option years 1 and 2 to require the SOC 1 Type II. The renewal is in the process of being reviewed and executed to go into effect July 1, 2025. Language added to contract renewal: Contractor Internal Controls Reports The Contractor shall provide the Department, at a minimum; annual, unredacted reports from its independent external auditor on the effectiveness of the Contractor’s internal controls conducted in accordance with the AICPA Statement on Standards for Attestation Engagements. If the reports disclose deficiencies in internal controls, the Contractor shall include management’s corrective action plans to remediate the deficiency. The Contractor shall provide the following reports: · SOC 1 Type 2 Report that reports on the controls at the service organization which are relevant to the user entities’ internal control over financial reporting · SOC 2 Type 2 Report covering all five Trust Services Criteria (Security, Availability, Processing Integrity, Privacy and Confidentiality) The contractor shall provide the Department with these internal control reports within 30 days of the report’s issue date. Reports shall cover a period of 12 months beginning from the end date of the prior audit period with the first report covering a period of 12 months from the execution date of this contract. The contractor shall provide unredacted SOC 1 Type 2 and/or SOC 2 Type 2 reports as described above for any subservice organizations which provide a service to the Contractor that may impact the Department’s financial, program operations, or data security as determined by the Department. Estimated Completion Date: 7/1/2026
Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additio...
Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additionally, DSS will create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. Estimated Completion Date: 12/31/2025
Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 3/15/2025
Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 3/15/2025
Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additio...
Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additionally, DSS will create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. Benefit Program is working with appropriate parties to resolve outstanding errors. Estimated Completion Date: 6/30/2025
Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office...
Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office of Purchasing and General Services, and Office of Financial Management. Employees responsible for managing grants and subrecipients will receive training on the new process. Estimated Completion Date: 12/31/2025
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: The Financial Aid Office and Controller's Office will jointly review the current reconciliation process for federal assistance programs. This will include identifying ...
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: The Financial Aid Office and Controller's Office will jointly review the current reconciliation process for federal assistance programs. This will include identifying all steps involved in the reconciliation process, documenting the roles and responsibilities of each office, and pin pointing areas where communication breakdowns have occurred in the past. Step 2: Based on the review, the offices will enhance the reconciliation procedures to address identified weaknesses. This will include developing standardized templates for reconciliations, establishing clear timelines for each step of the process, defining specific procedures for investigating and resolving reconciling differences, and implementing a system of checks and balances to ensure accuracy. Step 3: Formalize communication protocols between the Financial Aid Office and the Controller's Office to facilitate timely and effective information sharing related to federal assistance programs. This will include designated points of contact in each office, regular meetings and reminders for discussing reconciliation issues, and a shared folder for archiving reconciliation working paper and supporting documents. Estimated Completion Date: 6/30/2025
Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the Direct Loan Notification Process will be sent out timely to all students with Direct Loan disbursements. Additional personnel have been named back-up to...
Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the Direct Loan Notification Process will be sent out timely to all students with Direct Loan disbursements. Additional personnel have been named back-up to ensure notifications are submitted timely. The Student Accounts Office will notify the NSU department via email when disbursement of aid occurs. Calendar notifications can be created to ensure notifications are sent out timely. Estimated Completion Date: 8/31/2025
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implem...
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implement corrective actions to ensure that the University reports accurate and timely student enrollment status changes to the National Student Loan Data System. - Management will consider implementing a quality control review process to monitor the accuracy of campus and program-level batch submissions, such as implementing regularly scheduled self-audits of NSC data. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: The University has developed detailed procedures to improve reporting to NSLDS. These procedures include reviewing and updating Colleague system processing, designating staff members in both the Registrar and Financial Aid Offices to process, review and resolve reporting issues, and continued monitoring and verification of reports transmitted to NSLDS from the National Student Clearinghouse. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Angelique Robinson, College Registrar Zina Jemison, Associate College Registrar Corrective Action Planned: Step 1: College Registrar (CR) and Associate College Registrar (ACR) will review National Student Loan Data System trainings, documentation, and initiate training sessions with appropriate NSLDS staff to answer any outstanding questions about the system. Step 2: CR and ACR will review important NSLDS deadlines and incorporate lessons learned from the trainings to set the tone for internal deadline processing changes so that the semi-automated graduation process can be performed in a faster manner. The CR and ACR will also determine which additional team members within the College Records Office will assist in the completion of record updating and reporting requirements within NSLDS, outlining the specific tasks that will need to be done by each participating member and the information system queries that will be used for internal auditing purposes. Step 3: CR and ACR will consult with Financial Aid staff to finalize new internal record adjustment processing deadlines to ensure that the changes in procedures are made in a timely manner and in support of Financial Aid processes. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Carrie John, University Registrar Corrective Action Planned: The University is taking corrective action to ensure accurate and timely reporting of student enrollment changes to NSLDS. Corrective actions include enhancing procedures, providing additional training, and improving internal reviews. Estimated Completion Date: 6/30/2026 RU Responsible Contact Person(s): Katie Piper, Registrar Corrective Action Planned: The Registrar's Office has met and completed initial planning and timelines to address procedural changes needed to report the loan data timely. Estimated Completion Date: 12/31/2025 UVA Responsible Contact Person(s): Steve Kimata, Associate Vice President for Enrollment and University Registrar Corrective Action Planned: The University will implement additional controls to ensure the accuracy and timeliness of enrollment data reported to NSLDS. This includes working collaboratively with Student Financial Services and Information Technology Services to monitor and report late withdrawals, review and update the information system process for creating enrollment files, and implement a quality control review to check student status change batches for accuracy and timeliness. Estimated Completion Date: 6/30/2025 VSU Responsible Contact Person(s): Nedra Jones, University Registrar Corrective Action Planned: 1) VSU has implemented an automated alert system to notify staff of upcoming reporting deadlines, cross-referenced information system data with the SCHEV Degree Inventory Report, and are actively collaborating with SCHEV to resolve discrepancies. These items are complete. 2) Additionally, VSU is in the process of implementing the following additional corrective actions: A.) A comprehensive review of current enrollment reporting processes; B.) Closer collaboration with VSU third-party service provider to streamline and improve the enrollment reporting; C.) Designating an individual within the Registrar's Office to oversee National Student Clearinghouse (NSC) and NSLDS reporting duties; and D.) establishing a quality control process to include monthly random sample audits of enrollment data. Additionally, VSU will reconcile student addresses between the information system and NSLDS for Federal Direct Loan borrowers. Estimated Completion Date: 12/31/2025
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Review and update the FISAP Completion Documentation to clearly identify sources of data. This will include notating the specific data points for reporting enrollment and total tuition and fe...
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Review and update the FISAP Completion Documentation to clearly identify sources of data. This will include notating the specific data points for reporting enrollment and total tuition and fees from VCCS provided reports and reviewing the FISAP for accuracy before submitting. Estimated Completion Date: 8/30/2025
NSU Responsible Contact Person(s): Sandra Riggs, University Bursar Corrective Action Planned: To prevent delays in the processing of student refunds the University will review the refund process and ensure procedures are distributed to departments that are a part of the refund process. Student Accou...
NSU Responsible Contact Person(s): Sandra Riggs, University Bursar Corrective Action Planned: To prevent delays in the processing of student refunds the University will review the refund process and ensure procedures are distributed to departments that are a part of the refund process. Student Accounts will work with the Financial Aid Office and Housing Office to ensure timely disbursement once all charges have been posted to a student's account. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Stephanie Jennelle, Associate Vice President for Budget and Financial Planning Corrective Action Planned: The University is taking corrective action to ensure credit balances are disbursed within the regulatory time frame. Corrective actions include training and cross training Bursar personnel, performing weekly audits to ensure credit balances are processed within the required timeframe, and increasing collaboration between the Bursar’s office and Financial Aid to ensure Title IV funds are released timely. Estimated Completion Date: 12/31/2025
Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also ...
Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also add a checklist item to the monthly reconciliation to confirm the new procedure is being followed. Estimated Completion Date: 4/1/2025
NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Additional training was provided to all relevant financial aid staff focusing on the accurate and timely calculation and return of unearned Title IV funds. This training emphasized the ...
NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Additional training was provided to all relevant financial aid staff focusing on the accurate and timely calculation and return of unearned Title IV funds. This training emphasized the importance of adhering to regulatory guidelines and utilizing the institution's Information System-generated Return to Title IV (R2T4) report. Step 2: Quality control process has been implemented. The Associate Director or Director of Financial Aid will conduct a thorough review and quality control check of all R2T4 calculations prior to the return of funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Stephanie Jennelle, Associate Vice President for Budget and Financial Planning Corrective Action Planned: The University is taking corrective action to ensure unclaimed aid is promptly returned. Corrective action includes enhancing procedures for processing unclaimed checks containing Title IV funds. These enhancements include modifying the timing and frequency of outreach and follow up due diligence to students to ensure unclaimed Title IV funds are returned timely. Estimated Completion Date: 12/31/2025 RU Responsible Contact Person(s): Allison Pratt, Director of Financial Aid Corrective Action Planned: The accounting, financial aid, and internal audit departments have met to plan corrective actions. As procedure updates were occurring through the fiscal year that was audited, Internal audit initially chose additional sampling periods to test. Procedures are being reviewed and will continue to be updated in accordance with the finding results and Internal Audits' findings. Estimated Completion Date: 6/30/2025
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To ensure guidelines are followed, a comprehensive plan of action will be implemented. This plan includes establishing a formal training structure with annual reviews of key procedures, rev...
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To ensure guidelines are followed, a comprehensive plan of action will be implemented. This plan includes establishing a formal training structure with annual reviews of key procedures, revision of in-person inquiries, and an internal quality assurance review that will be conducted on a monthly basis. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has taken steps to review all verification updates made to students who have been selected for verification. Once a student has been verified, tracking of that student’s correction will be made. A review of changes made will be conducted to ensure that all changes have been entered correctly into the system and that the correction has been imported correctly prior to releasing the tracking hold onto the account. Also, a sample of students will be randomly selected monthly to ensure students who have been selected for verification or who have an ISIR comment code that needs resolution are reviewed for accuracy. Estimated Completion Date: 8/31/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to ensure continued efficiency, accuracy, and adherence to federal regulations. Corrective actions include providing intensive training for new Financial Aid verification team members and annual training for all Financial Aid team members, implementing quality assurance reports, and increasing reviews throughout the verification cycle. The University is also exploring other tools to assist with the verification process. The three test cases identified during the audit have been reviewed and federal funds have been returned as warranted. Estimated Completion Date: 12/31/2025 VPISU/ID Responsible Contact Person(s): Nicci Ratcliff, Associate Director for Processing Operations Corrective Action Planned: VPISU/ID updated the system tracking group logic to ensure verification is requested timely and reviewed all 2023-24 verification files ensuring required documents were on file. The University will include a weekly random sample of files flagged for verification and confirm that documentation is complete prior to disbursement. The University will provide additional annual training and a documentation requirements checklist to improve Specialist completion of the verification process and ensure consistent handling and retention of all required documents. Estimated Completion Date: 7/31/2025
NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue....
NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue. A reinforcement of procedures for exporting disbursements and staff training will be maintained as well as ensuring that a back-up staff member is in place. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: Establish clear and documented communication protocols between the Financial Aid Office and the Controller's Office regarding student withdrawals and the return of unearned Title IV funds. This will include designated points of contact in each office, a standardized process for the Financial Aid Office to notify the Controller's Office of requiring a return of Title IV funds, confirming the return by the Controller’s Office, and regular meetings between the two offices to review procedures and address any issues. Step 2: Develop a written policy and procedure. This will include step-by-step instructions for processing the return of funds, including required documentation and timelines, Clear delineation of responsibilities between the Financial Aid Office and the Controller's Office, and contingency plans for staff turnover or absences. Step 3: Conduct periodic reviews and reconciliation of returned Title IV funds to ensure accuracy and timeliness. This will include reconciling returned funds with ED records and identifying any discrepancies or delays in the return of unearned funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to improve processes to ensure data accuracy and compliance with reporting requirements. Corrective actions include utilizing system functionality and enhancing Office of Student Financial Aid procedures. Differences totaling $325 that were identified during the audit have been returned to the Department of Education. Estimated Completion Date: 12/31/2025
NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (...
NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (Return of TIV Coordinator) and the University Registrar prior to the start of each semester. This process will be included in the annual financial aid set up process. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Ensure proper setup of academic and holiday calendars in the information system. This will include the Director of Financial Aid working closely with the Policy Planning Specialist to ensure the academic calendar and holiday calendars are set up properly in the information system to account for all breaks. Step 2: Improved communications during calendar and information system setups. This will include regular scheduled meetings between the Policy Planning Specialist, Associate Director of Financial Aid Information Systems, and the Director of Financial Aid to review the academic and holiday calendar setups in the information system. Make any appropriate updates to the academic calendar and financial aid setups in the information system. Step 3: Run VCCS Custom R2T4 Report and perform R2T4 calculations/adjustments based on the R2T4 policies and procedures. Estimated Completion Date: 6/30/2025
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To enhance and ensure the accuracy and timeliness of Return to Title IV (R2T4) calculations and processes, the Office of Student Financial Aid will implement several corrective actions. The...
GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To enhance and ensure the accuracy and timeliness of Return to Title IV (R2T4) calculations and processes, the Office of Student Financial Aid will implement several corrective actions. These include increasing personnel to ensure R2T4 calculations are completed promptly, collaborating closely with the Associate Director of Funds Management to ensure funds are returned in a timely manner, coordinating with the Office of the University Registrar to ensure student withdrawals are coded accurately and promptly, and making necessary adjustments to the schedule and review process for reports to ensure compliance. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Registrar’s Office has documented procedures for running report(s) to identify all students who withdraw within a specific timeframe. A schedule will be created to ensure that the report is run accurately and timely. This will allow timely processing and submission of data by the Financial Aid Office. The Financial Aid Office will utilize the schedule created by the Registrar to ensure that the list of withdrawn students is completed timely. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: The Associate of Financial Aid, R2T4, will provide additional training to staff member(s) responsible for performing R2T4 calculations and returns. This will include training on R2T4 guidelines, information system generated reports, and review of the college R2T4 policies and procedures. Step 2: Use VCCS Custom R2T4 Report to identify students who are subject to Title IV adjustments/returns. This will include the staff member responsible for R2T4s will use the VCCS Custom R2T4 to perform appropriate calculations and returns for all student identified. Step 3: The Director/Associate Director of Financial Aid, R2T4, will administer quality control of R2T4s. This will include reviewing the R2T4 report to identify outstanding R2T4s. Periodically running information system generated reverse R2T4 report to identify any R2T4s that were not processed. If any R2T4s are identified as unprocessed, the staff member responsible for R2T4s will promptly perform the R2T4 as outlined in the policies and procedures. Estimated Completion Date: 6/30/2025
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. ...
Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. This will include the Director of Financial Aid and the Associate Director of Financial Aid Information Systems who will set scheduled meetings to conduct periodic reviews of the information system Access each semester using a designated report. Step 2: The Associate Director of Financial Aid Information Systems will create a repository to store the designated reports, which will be accessible by the Director of Financial Aid. Step 3: The Director of Financial Aid and the Associate Director of Financial Aid Information Systems will review access. If changes are needed, the appropriate IT forms will be submitted to have staff members access updated appropriately. Estimated Completion Date: 6/30/2025
Responsible Contact Person(s): Ivan Gotay, College Information Security Officer Corrective Action Planned: 1.Oversight of Third-Party Service Providers: NVCC has implemented a written information security program that requires thorough vetting of third-party service providers. Additionally, NVCC ut...
Responsible Contact Person(s): Ivan Gotay, College Information Security Officer Corrective Action Planned: 1.Oversight of Third-Party Service Providers: NVCC has implemented a written information security program that requires thorough vetting of third-party service providers. Additionally, NVCC utilizes an external vendor to perform a detailed risk review of third-party service providers. The steps outlined below were reviewed and completed. Step 1: Developed procedures for overseeing third-party service providers. This contains a formal documentation of the NVCC's third-party risk management procedure, detailing vendor evaluation, review, and remedial processes. Step 2: Developed a plan for frequent reassessments to assure third-party service providers continuous compliance and security. Step 3: Provided further training for key people on implementing and maintaining third-party oversight procedures to guarantee consistency. 2.Data Protection: NVVC has identified the data protection findings and has promoted a project to begin in 2025. Step 1: NVCC will create a project plan to formally address data protection within the infrastructure. The plan will have estimates and milestones of completion to measure progress. Step 2: The extensive project will include data inventory classification and data retention. Step 3: The project will reference Virginia state policies. Step 4: A formal project review will be conducted in the second quarter of 2025 by the PMO. Step 5: Once the project has been completely resourced, it will be formally kicked off in the second quarter of 2025. Step 6: The effectiveness and progression of the project will be measured by the College Information Security Officer. Step 7: Final testing will be conducted by the IT Auditor and the College Information Security Officer. Estimated Completion Date: 7/1/2026
Responsible Contact Person(s): Paul Cormal, Chief Technology Officer Diane Carnohan, Chief Information Security Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE unde...
Responsible Contact Person(s): Paul Cormal, Chief Technology Officer Diane Carnohan, Chief Information Security Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 9/30/2025
Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: DSS has 15 plus applications that are in active oversight, IT Business Administration is in receipt of the required SOC 2, Type 2 reports. However, additional requirements to capture the SOC 1, Type 2 ...
Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: DSS has 15 plus applications that are in active oversight, IT Business Administration is in receipt of the required SOC 2, Type 2 reports. However, additional requirements to capture the SOC 1, Type 2 reports has not yet been accomplished. Estimated Completion Date: 12/31/2025
Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountabilit...
Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Joseph Bertram, Financial Operations Manager. Anticipated Completion Date: June 30, 2025.
Finding 525868 (2024-001)
Significant Deficiency 2024
UWI management identified the late reporting error during the year and made alternative arrangements with the grantor to come into compliance prior to fiscal year end. To assure compliance with federal grants, procedures are in place for grant reporting oversignt.
UWI management identified the late reporting error during the year and made alternative arrangements with the grantor to come into compliance prior to fiscal year end. To assure compliance with federal grants, procedures are in place for grant reporting oversignt.
The Organization began its audit for the year ended June 30, 2024 earlier than the prior year, allowing sufficient time to file the Organization's data collection form before its due date.
The Organization began its audit for the year ended June 30, 2024 earlier than the prior year, allowing sufficient time to file the Organization's data collection form before its due date.
Management agrees with the finding and is in the process of revising internal controls to address this issue.
Management agrees with the finding and is in the process of revising internal controls to address this issue.
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