Corrective Action Plans

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Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.
2024-002 Significant Deficiency Identified: During our audit, we noted that LASP did not meet the adjusted PAI requirement of $278,524. Management’s Response to Finding: LASP acknowledges that it did not meet the Private Attorney Involvement (PAI) spending requirement for the fiscal year, with actua...
2024-002 Significant Deficiency Identified: During our audit, we noted that LASP did not meet the adjusted PAI requirement of $278,524. Management’s Response to Finding: LASP acknowledges that it did not meet the Private Attorney Involvement (PAI) spending requirement for the fiscal year, with actual expenditures totaling $204,348, resulting in a shortfall of $74,176. This shortfall occurred due to errors in the reporting of the prior year’s PAI waiver request. LASP is committed to compliance with all PAI requirements and has taken immediate corrective actions to improve the accuracy of its reporting processes. While this reporting oversight led to a shortfall, it is important to note that PAI spending increased by 23% over the previous year, rising from $165,785 in fiscal year-end 2023 to $204,348 in fiscal year-end 2024. This improvement continues a positive trend and reflects LASP’s dedication to expanding PAI-related activities and strengthening private attorney involvement. Further, LASP’s recently appointed Pro Bono Director has already made significant improvements in the tracking and reporting of eligible PAI hours, including those contributed by law student interns and management-related projects. These efforts provide a more accurate reflection of actual expenditures and strengthen LASP's compliance with PAI requirements. Corrective Actions Implemented: 1. Improved Tracking and Monitoring: LASP has implemented monthly tracking procedures to monitor actual PAI spending against established requirements. This approach will ensure that any discrepancies are identified promptly, allowing for timely corrective measures to meet PAI targets. 2. Waiver Documentation and Approval: The $74,176 shortfall has been documented for inclusion in next year’s PAI requirement. LASP has received approval from the Legal Services Corporation (LSC) to carry forward the unmet spending requirement to the next fiscal period. 3. Enhanced Training Programs: LASP has implemented training programs for staff involved in PAI reporting, covering the latest PAI requirements and reporting best practices. The Pro Bono Director will oversee the training program to ensure staff are accurately tracking and reporting PAI expenditures. 4. Strengthened Oversight and Internal Controls: Additional layers of review have been integrated into the PAI reporting process to enhance the accuracy and completeness of reports, helping to prevent future errors and fostering a culture of compliance. Commitment to Improvement: LASP Management is committed to addressing the identified significant deficiency and reinforcing internal controls over PAI compliance. The corrective actions are intended to prevent future oversights and ensure the accurate and timely reporting of PAI expenditures. The effectiveness of these initiatives will be closely monitored with further adjustments made as needed to maintain compliance with LSC and auditing standards. LASP is dedicated to fulfilling its mission through the effective use of PAI resources and is confident that these measures will enable the organization to meet and exceed PAI requirements in future reporting periods.
Finding 504386 (2024-002)
Significant Deficiency 2024
Corrective Steps Taken –The School District will direct personnel to oversee the compliance of the Career and Technical Education grants and verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all...
Corrective Steps Taken –The School District will direct personnel to oversee the compliance of the Career and Technical Education grants and verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all employees paid through federal grants.
Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the total number of meals. Therefore, if the number of total meals is typed incorrectly, the difference automatically adds or subtracts to the number of full-paid meals. The S...
Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the total number of meals. Therefore, if the number of total meals is typed incorrectly, the difference automatically adds or subtracts to the number of full-paid meals. The School District does not currently have a control for the secondary review and approval of the meal counts entered into the MiND system. This reporting risk could result in the School District inaccurately reporting meals for reimbursement. Planned Corrective Action: After initial claim submission, the Student Nutrition Director will provide the MiStar back up along with the claim summary to the District Accountant. The District Accountant will then review the claim for accuracy. If any issues are identified, the District Accountant will notify the Student Nutrition Director, who will then need to amend the claim. Any claim amendment will be submitted back to the District Accountant for review. Documentation of this review and the related reports will be maintained each month. Contact person responsible for corrective action: Rachel Bois, CFO Anticipated Completion Date: 11/1/2024
Finding 504301 (2024-006)
Significant Deficiency 2024
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the re...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the need to enhance our documentation of internal controls to ensure testability and maintain compliance with federal reporting standards. While our existing internal processes ensured data accuracy, timeliness, and submission compliance, we acknowledge that documentation of the review process is beneficial. Moving forward, the Contract Review Officer (CRO) will review FFATA reports submitted by another team member. When the CRO submits the report, her supervisor or an OSP employee will perform the review. Each review instance will be documented with the reviewer’s name and date to reinforce control transparency and testability, aligning our process more closely with compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Sarah Martonick, Director, Office of Sponsored Programs, 208-885-2145. Planned completion date for corrective action plan: October 31, 2024
Finding 504300 (2024-005)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Expla...
Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a weekly report for all communications. We also reviewed the populations selection. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: 12/31/24
Finding 504296 (2024-003)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with aud...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College 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: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024
Finding 504292 (2024-004)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Aid updated our auto packaging policy. Name(s) of the contact person(s) responsible for corrective action: This was a part of our aid year rollover process and planning. Planned completion date for corrective action plan: April 2024
View Audit 326827 Questioned Costs: $1
Finding 504291 (2024-002)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are adjusting our corrective action. Last year we tested several out of cycle enrollment adjustments each term to ensure our processes were working. We didn’t find any issues. This year we will be comparing all the students were not reported to the Clearinghouse with the list reported to the Clearinghouse to ensure all students who need to be reported are properly reported. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: We ran our first comparison on 9/19/2024 and we will be running every month we do the Clearinghouse reporting.
Finding 504290 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation ...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the auditors’ recommendations of corrective action needed to ensure unclaimed Title IV federal funds are resolved within 240 days of disbursement date. The University has reviewed existing processes and identified improvements that will be made to internal procedures to ensure proper compliance is met. Name(s) of the contact person(s) responsible for corrective action: Delora Shoop & Amanda Bauer. Planned completion date for corrective action plan: December 2024
Finding 2024‐002 Federal Agency Name: Direct Program – Department of Education Assistance Listing Number: P063P237884, P268K247884, P033A239207, P007A239207 Program Name: Student Financial Assistance Cluster Finding Summary: The College implemented new software functionality that automated sen...
Finding 2024‐002 Federal Agency Name: Direct Program – Department of Education Assistance Listing Number: P063P237884, P268K247884, P033A239207, P007A239207 Program Name: Student Financial Assistance Cluster Finding Summary: The College implemented new software functionality that automated sending notifications to students upon loan disbursement. The notifications of student financial aid disbursements were not sent timely due to the process being ran in simulation mode and this was not immediately identified by the College staff. Students were notified of their financial disbursement when this error was noticed by the College staff during the fiscal year 2024, however it was not within the 30 days outlined above. The College was able to correct the process for the summer 2024 disbursements, in which the 30-day time frame was met. Corrective Action Plan: The Assistant Director of Financial Aid will automatically receive an emailed report of all disbursement notifications that are emailed students each time email notifications are processed. The Assistant Director of Financial Aid will run a communication verification report each week to ensure that all disbursed loans correspond to disbursement emails sent to students. Any missing emails will be sent within the required time frame and meetings will occur with the responsible staff person as needed. The Executive Director Financial Aid reviews this communication verification report each month. Responsible Individuals: Jeneé Snyder, Executive Director Financial Aid Michelle Haviland, Assistant Director Financial Aid Anticipated Completion Date: Change in control process implemented July 1, 2024.
Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: For the special tests and provisions compliance requirement testing, of the ...
Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: For the special tests and provisions compliance requirement testing, of the 49 disbursements tested, eleven payments were made outside of the 30-day requirement. Responsible Individuals: Denise Albertson, ESG Administrator Amy Eldridge – Director of Rental Housing Development Corrective Action Plan: The ESG Administrator will track the days between receipt and disbursement to be able to meet the 30-day requirement. Anticipated Completion Date: September 30, 2024
Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: In three instances, the amount reimbursed to subrecipients were paid out bas...
Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: In three instances, the amount reimbursed to subrecipients were paid out based on the persons paycheck stub showing allocation of hours which did not match backup provided for hours worked under the program, Responsible Individuals: Denise Albertson, ESG Administrator Amy Eldridge – Director of Rental Housing Development Corrective Action Plan: The ESG Administrator will review the timesheet information to ensure the hours and amounts for payroll costs are correctly allocated by the subrecipient to the program. Any differences in the allocation between the timesheets and paycheck stubs will be reviewed prior to disbursements. Anticipated Completion Date: September 30, 2024
Condition: Of the thirty-seven employees charged to the grant, two employees did not have semiannual certifications available. The Academy was able to provide alternative support for the allowability of these costs through review of the activities performed as compared to activities included in the...
Condition: Of the thirty-seven employees charged to the grant, two employees did not have semiannual certifications available. The Academy was able to provide alternative support for the allowability of these costs through review of the activities performed as compared to activities included in the approved grant budget. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure semi-annual certificated are completed and are reviewed for each employee being charged to the Title 1 grant. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
Condition: Of the thirty-six employees charged to the grant, five employees did not have semiannual certifications available. The Academy was able to provide alternative support for the allowability of these costs through review of the activities performed as compared to activities included in the ...
Condition: Of the thirty-six employees charged to the grant, five employees did not have semiannual certifications available. The Academy was able to provide alternative support for the allowability of these costs through review of the activities performed as compared to activities included in the approved grant budget. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure semi-annual certificates are completed and reviewed for each employee being charged to the Title 1 grant. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
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