Corrective Action Plans

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February 24, 2023Audit Response to Federal Grants Audit (A-133) - Enrollment reporting to National Student ClearinghouseAnalysis:Robert Morris University (University) attributes the delay in reporting changes of student enrollment status (withdrawal, graduated, less than half time, etc.) to the Nati...
February 24, 2023Audit Response to Federal Grants Audit (A-133) - Enrollment reporting to National Student ClearinghouseAnalysis:Robert Morris University (University) attributes the delay in reporting changes of student enrollment status (withdrawal, graduated, less than half time, etc.) to the National Student Clearinghouse (NSC) to the implementation of a new student information system conversation (Banner) that occurred in June 2021. Banner replaced a legacy system that the University had used for decades that had reliable processes and reporting controls that accurately reported information to the NSC.The identified exceptions can be categorized into the following two general categories:Off-Cycle GraduationOne group of exceptions related to students who had degrees conferred but the University had not updated their status to "graduated" in the NSC. Upon further review, the University determined extenuating circumstances (i.e. completion of all paperwork, and assignments, incomplete grade(s), etc.) existed for these students' and their graduation date fell outside of the normal graduation date of their peers for that semester cohort. Because of the off-cycle graduation timing, these students were not captured in the new graduate reporting process in Banner at the end of each semester. This resulted in the students not being reported to the NSC.Fall 2021 Status ChangesThe final group of exceptions occurred due to the University's new student information system conversion (Banner) in June 2021. Due to the specific requirements and customized nature of the clearinghouse file, the University's first electronic submission for Fall 2021 was delayed as errors/issues were being resolved in conjunction with the NSC. During that time frame, there were students who had fully withdrawn and/or status changes from the University, but due to the delay and file parameters, they were inadvertently excluded in the first submission and/or their status change wasn't reported in a timely manner.
February 24, 2023Audit Response to Federal Grants Audit (A-133) - Return of Title IV Aid (R2T4)Analysis:Robert Morris University ("University") attributes the isolated delay in refunding Title IV funds in excess of the required 45-day window following the student's complete withdrawal to a student i...
February 24, 2023Audit Response to Federal Grants Audit (A-133) - Return of Title IV Aid (R2T4)Analysis:Robert Morris University ("University") attributes the isolated delay in refunding Title IV funds in excess of the required 45-day window following the student's complete withdrawal to a student information system conversation (Banner) that occurred in June 2021. Banner replaced a legacy system that the University had used for decades. Specifically, customized reporting in Banner was needed in order to provide additional visibility so that the University could timely fulfill R2T4 obligations. As a result of the above, the University enacted several measures and safeguards to strengthen controls around the R2T4 process.Response:The University implemented the following control measures:-In September 2022, the University Registrar performed a retraining for all individuals who process complete withdrawals from the University. This training included a detailed walk through of all the steps required to timely and accurately process a complete withdrawal in Banner.-The University's IT department developed custom reports showing complete withdrawals from the University, which are generated and distributed to the Financial Aid office who reviews this report on a weekly basis to make sure withdrawals are completed timely and the appropriate financial aid adjustments are reflected on the students account.-On a monthly basis, the Senior Director of Student Financial Services now performs a double check review of a withdrawal report and alerts Financial Aid of any additional withdrawals that may meet the criteria for a return.Conclusion:The University deems that the control measures in place listed above are adequate and will prevent any future instances of untimely R2T4 funds. Overall, although the refunds were issued in excess of 45 days, the Department of Education did receive all required refunds in full and no amounts were outstanding at the time of the audit procedures.Keith A. RoeperChief Accounting Office and Controller and Assistant Treasurer
2022-009 Special Tests and Provisions – The Gramm-Leach-Bliley Act (GLBA) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leac...
2022-009 Special Tests and Provisions – The Gramm-Leach-Bliley Act (GLBA) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University began engagement with AIS, an IT Managed Service Provider in May 2022 and hired a Director of IT in November 2023. The University is working with AIS and Cowbell to develop and implement a Cybersecurity policy, as well as to provide training for all employees, the Board of Governors, and students. The University has also deployed Cloud Storage backup solutions for all data. Name(s) of the contact person(s) responsible for corrective action: Scharvin Wilson, Director of IT, AIS, IT Managed Services Provider, E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Planned completion date for corrective action plan: June 30, 2024
Finding 401562 (2022-007)
Significant Deficiency 2022
2022-007 Reporting – Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and ...
2022-007 Reporting – Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has begun to restructure all accounting and reconciliation functions. The University is implementing financial internal controls to improve the internal financial reporting process. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Finding 401561 (2022-006)
Significant Deficiency 2022
2022-006 Special Tests and Provisions – Return of Title IV Funding Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the docu...
2022-006 Special Tests and Provisions – Return of Title IV Funding Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
2022-005 Special Tests and Provisions – Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and within the...
2022-005 Special Tests and Provisions – Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and within the required time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has begun to restructure all accounting and reconciliation functions. The University is implementing financial internal controls to improve the internal financial reporting process. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Finding 401559 (2022-004)
Significant Deficiency 2022
2022-004 Special Tests and Provisions – Outstanding Checks over 240 Days Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being ...
2022-004 Special Tests and Provisions – Outstanding Checks over 240 Days Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has begun to restructure all accounting and reconciliation functions. The University is implementing financial internal controls to improve the internal financial reporting process. Name of the contact person responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Planned completion date for corrective action plan: June 30, 2024
View Audit 309593 Questioned Costs: $1
Finding 401558 (2022-003)
Significant Deficiency 2022
2022-003 Reporting – FISAP Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable campus revise procedures to ensure that the record retention requirements are met and supporting documentation agrees to the FISAP, including a...
2022-003 Reporting – FISAP Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable campus revise procedures to ensure that the record retention requirements are met and supporting documentation agrees to the FISAP, including a supervisory review by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has begun to restructure all accounting and reconciliation functions. The University is implementing financial internal controls to improve the internal and external financial reporting process. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024
Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Ag...
Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000071546, C000073444, C000075689, C000075284, C000080637, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Condition/Context: The County’s December 31, 2022 Single Audit was not completed and submitted within the required time period. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Planned Corrective Action: Management understands that the organization receiving these funds receives a single audit also. We will continue to work with this agency ensuring that policies and procedures are understood and will follow the requirements. Name(s) of Contact Person(s) Responsible for Corrective Action: David Witchey, Chief Clerk Anticipated Completion Date: For the 2023 audit.
Finding 397881 (2022-006)
Significant Deficiency 2022
College will put controls in place between Registrar and Financial Aid to ensure enrollment status of students
College will put controls in place between Registrar and Financial Aid to ensure enrollment status of students
View Audit 306623 Questioned Costs: $1
Finding 397880 (2022-005)
Significant Deficiency 2022
Administration adjusted job responsibilities of current staff and made process changes to work with third party financial aid servicer to validate federal awards prior to submission
Administration adjusted job responsibilities of current staff and made process changes to work with third party financial aid servicer to validate federal awards prior to submission
View of Responsible Officials and Planned Corrective Actions - The primary Senior Accountant assigned for the day-to day accounting semi-retired, working reduced hours. The impact of COVID-19 continues to present challenges in staffing required to accomplish all the tasks in a timely manner. A repla...
View of Responsible Officials and Planned Corrective Actions - The primary Senior Accountant assigned for the day-to day accounting semi-retired, working reduced hours. The impact of COVID-19 continues to present challenges in staffing required to accomplish all the tasks in a timely manner. A replacement senior accountant has been hired and has been in training by the semi-retired senior accountant to assume all of the day-to-day accounting duties. The workload of the senior accountant will be monitored to ensure future audits are issued in a timely basis.
Finding Number: 2022-008 Finding Title: LCTS Reporting Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Ann Ozan – Fiscal Supervisor II. Corrective Action Planned: Document the review of the public health, corrections, and school district quarterly...
Finding Number: 2022-008 Finding Title: LCTS Reporting Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Ann Ozan – Fiscal Supervisor II. Corrective Action Planned: Document the review of the public health, corrections, and school district quarterly reports. Review is being done when the state report is prepared, but not currently documented. Anticipated Completion Date: December 31, 2023.
Finding Number: 2022-002 Planned Corrective Action: This finding was expected, as it is a continuation of the same finding as the prior year in 2021. The 2022 year was already well underway before the issue was initially identified following the 2021 year. In June of 2022, in conjunction with it’s...
Finding Number: 2022-002 Planned Corrective Action: This finding was expected, as it is a continuation of the same finding as the prior year in 2021. The 2022 year was already well underway before the issue was initially identified following the 2021 year. In June of 2022, in conjunction with it’s Program Review, the U.S. Department of Education identified inadequacies in EGCC’s Return to Title IV Policy which were contributing factors in this finding. As a result of this identification, EGCC updated its Title IV financial aid recalculation and return policies and procedures. The updates serve to ensure that unofficial withdrawals are identified in a timely fashion, and that title IV funds are returned accurately and within proper timeframes. In July of 2022, EGCC completed and approved these policy updates, as well as published a related addendum to its academic catalog. Anticipated Completion Date: 07/21/2022 Responsible Contact Person: Kurt Pawlak – AVP Financial Aid
Finding Number: 2022-001 Planned Corrective Action: This finding was expected, as it is a continuation of the same finding as the prior year in 2021. The 2022 year was already well underway before the issue was initially identified following the 2021 year. EGCC has determined the root cause of the...
Finding Number: 2022-001 Planned Corrective Action: This finding was expected, as it is a continuation of the same finding as the prior year in 2021. The 2022 year was already well underway before the issue was initially identified following the 2021 year. EGCC has determined the root cause of the issue. For unknown reasons, and without directive to do so, EGCC’s previous Registrar (who is no longer employed by EGCC) stopped producing enrollment updates for NSLDS. Our current Registrar is working with The National Clearinghouse to update historical records for students who previously attended or are currently attending EGCC. As of June 2023, records up to and including the Fall 2021 semester have been updated, and updates for the Spring 2022 semester are in progress. EGCC expects to be current with enrollment updating by August 2023. Anticipated Completion Date: 08/31/2023 Responsible Contact Person: Ken Rupert – Registrar
Finding 393488 (2022-003)
Significant Deficiency 2022
In response the supervisor will review the data that is collected to complete the reports for accuracy. Upon completion of the report, the Dean of Student Services will review it before submission. Records of all documents and any communications related to the reports will be maintained for review p...
In response the supervisor will review the data that is collected to complete the reports for accuracy. Upon completion of the report, the Dean of Student Services will review it before submission. Records of all documents and any communications related to the reports will be maintained for review purposes. The Financial Aid Administrator will cross reference the accuracy of the report with the Finance Departments data/figures. Report deadline timelines will be created to allocate sufficient time for review and revisions to address any identified issues. Ongoing training will be provided for all staff involved in these reports.
Finding 393487 (2022-002)
Significant Deficiency 2022
In response the college will require the Financial Aid Administrators supervisor to approve the completed treatment of Title IV funds when a student withdraws. This ensures accountability and oversight in the R2T4 process. The Financial Aid Aministrator will maintain detailed documentation of the R2...
In response the college will require the Financial Aid Administrators supervisor to approve the completed treatment of Title IV funds when a student withdraws. This ensures accountability and oversight in the R2T4 process. The Financial Aid Aministrator will maintain detailed documentation of the R2T4 process, including withdrawal dates, calculations, approvals, and any other relevant information. Proper recordkeeping is essential for audit purposes and demonstrating compliance. Stone Child College will seek comprehensive training for all staff involved in administering Title IV Funds, including supervisors and management. This will ensure the R2T4 process complies with all relevant regulatory requirements, including thouse outlined by the U.S. Department of Education. Stone Child College management will emphasize the importance of timely and accurate processing of R2T4 calculations and disbursements to all staff involved.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a loan disbursement is made. This will be fully functional in fiscal year 2025.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a loan disbursement is made. This will be fully functional in fiscal year 2025.
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institutions due to this being a fai...
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institutions due to this being a fairly new process/requirement. This process will be corrected going forward.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a Graduation Fee is charged. This will be fully functional in fiscal year 2025.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a Graduation Fee is charged. This will be fully functional in fiscal year 2025.
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institutions due to this being a fai...
The University concurs with finding. All students were reported to the National Student Clearinghouse (NSC) as to what their status was for those terms. The updates were not updated in the NSLDS side. According to the audit staff, this is a common finding amongst institutions due to this being a fairly new process/requirement. This process will be corrected going forward.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to refine that all withdrawn students are included in the Summary Level Report. This will be fully functional in fiscal year 2025.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to refine that all withdrawn students are included in the Summary Level Report. This will be fully functional in fiscal year 2025.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a withdrawal date is entered. This will be fully functional in fiscal year 2025.
The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a withdrawal date is entered. This will be fully functional in fiscal year 2025.
The University’s Office of Financial Aid is currently integrating a new SAP Policy for fiscal year 2025 and will be implementing the required controls in their general ledger accounting system that will ensure SAP is monitored for each student in a timely and accurate manner.
The University’s Office of Financial Aid is currently integrating a new SAP Policy for fiscal year 2025 and will be implementing the required controls in their general ledger accounting system that will ensure SAP is monitored for each student in a timely and accurate manner.
Management’s Corrective Action Plan National University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control Management agrees with the importance of ensuring t...
Management’s Corrective Action Plan National University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control Management agrees with the importance of ensuring that the return of Title IV funds (R2T4) are performed both timely and accurately. The NCU Processing team has led focused R2T4 training on several subjects, including the importance of return amount inputs to ensure our R2T4 processors receive regular refresher training and coaching to prevent any R2T4 calculation inaccuracies. The Processing team will continue to conduct subject matter training monthly. The Quality Assurance team will continue to conduct weekly R2T4 calculation reviews to demonstrate internal controls and accuracy. The Quality Assurance review process includes reviewing the R2T4 calculation for accuracy and verifying that all system inputs such as EDExpress and COD are completed correctly. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance and Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024
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