Corrective Action Plans

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Institutional Comments on Findings and Recommendations: Compliance Requirements – Applicable After a Student Begins Attendance: The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the stud...
Institutional Comments on Findings and Recommendations: Compliance Requirements – Applicable After a Student Begins Attendance: The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within fourteen (14) days after the student’s last day of attendance. In one (1) of the two (2) cases the Date of Determination was twenty-two (22) days after the Last Day of Attendance and in the second case, the Date of Determination was Three (3) days after the Last Day of Attendance. All funds due to the Department, (for the first case $682.00 of Unsub. Direct Loan funds and in the second case $974.22 of Federal Pell Grant funds), were returned within the forty-five (45) days required timeframe as of the Date of Determination of each case. This process was evidenced to the auditors for their records. Actions Taken or Planned: The institution is fully aware of the Return of Title IV funds (R2T4) reporting requirements and deadlines. The issue related to this finding was identified as a lack in some Faculty notifying student absences within the fourteen (14) day timeframe to process an R2T4 in a timely manner as required. Although this issue was already discussed with them by the Dean of Academic Affairs, an additional follow up meeting would be held to remind them of the importance in monitoring student attendance and notifying student absences to the Registrar office within the required timeframes to fully comply with the R2T4 reporting requirements. Status of Corrective Actions on Prior Findings: The issue as related to this finding occurred in the past audit.
View Audit 305178 Questioned Costs: $1
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administ...
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Fin...
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
View Audit 305169 Questioned Costs: $1
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial ...
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
View Audit 305169 Questioned Costs: $1
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's...
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing
View Audit 305169 Questioned Costs: $1
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Direct...
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing
View Audit 305169 Questioned Costs: $1
Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Regist...
Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guid...
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal gu...
Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal gui...
Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
View Audit 305169 Questioned Costs: $1
During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certific...
During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certification process. This activity will be aligned to the recent updates of the electronic platform.
A user guide will be established describing the steps to assembly the academic year in Banner system. This document will detail all the validation tables, processed at the registrar’s office, that impact the financial aid office procedures. Each associate registrar will have access to this guide. ...
A user guide will be established describing the steps to assembly the academic year in Banner system. This document will detail all the validation tables, processed at the registrar’s office, that impact the financial aid office procedures. Each associate registrar will have access to this guide. The institutional registrar will be in charge of disseminating this guide across all campuses and locations. The Registrar office will notify Financial Aid, once they validate the table assembly is completed in Banner.
To save the current and future FISAP, financial aid will proceed as follows: 1. An Argos report based on Banner data that permits the data to be exported to Excel. This will filter data for various sections of the application. 2. A shared folder in OneDrive to which the associate director of inform...
To save the current and future FISAP, financial aid will proceed as follows: 1. An Argos report based on Banner data that permits the data to be exported to Excel. This will filter data for various sections of the application. 2. A shared folder in OneDrive to which the associate director of information processes and financial aid assistant vice-president have access. 3. Creation of a "FISAP preparation guide” that describes each part of the application, the corresponding data, and its sources. Each source will have its supporting documents. 4. Once the FISAP process begins, the documents that are going to be stored are: a. Original Banner and Excel Data b. Tuition report by category issued by the accounting Office (Accounting Director). c. Pell expenditures per enclosure issued by the accounting office (Associate Director of External Funds). d. Draft of FISAP (before submission) e. Submitted FISAP f. Final FISAP that is exported from COD that contains the information when the CEO filed the signature. g. Notification by venue when COD receives the request. h. Notification of discrepancies or review from the USDE. i. Updates or changes in FISAP application, if applies.
Finding 395218 (2023-041)
Significant Deficiency 2023
Finding 2023-041 – Corrective Action Plan There is no disagreement with the audit finding. The financial aid office has identified the position within the department that is responsible for completing monthly reconciliation or the Direct Lending program. This position has been given the policy an...
Finding 2023-041 – Corrective Action Plan There is no disagreement with the audit finding. The financial aid office has identified the position within the department that is responsible for completing monthly reconciliation or the Direct Lending program. This position has been given the policy and procedures related to reconciliation and has immediately begun following these procedures. This position will also seek out additional resources and trainings to ensure compliance moving forward. The director will support the process by allowing the time for these processes to be done on a monthly basis as well as provide support for future trainings. Anticipated Completion Date: January 2024 Contact Person: Jennifer Burke, Interim Director of Financial Aid, Rhode Island College jburke1@ric.edu
Finding 395210 (2023-042)
Significant Deficiency 2023
Finding 2023-042 – Corrective Action Plan There is no disagreement with the audit finding. The University has enacted an Information Security Policy, “URI Information Technology Standard”, which was issued on December 6, 2023. This standard defines the minimum information security requirements fo...
Finding 2023-042 – Corrective Action Plan There is no disagreement with the audit finding. The University has enacted an Information Security Policy, “URI Information Technology Standard”, which was issued on December 6, 2023. This standard defines the minimum information security requirements for the University of Rhode Island. The full standard can be found at the following URL: https://uri0.sharepoint.com/sites/URIInformationTechnologyServicesCommunication/SitePages/ITS-Security.aspx?ga=1. Anticipated Completion Date: December 6, 2023 Contact Persons: Gabrile Fariello, Interim Chief Information Officer, University of Rhode Island gfariello@uri.edu Michael Khalfayan, Chief Information Systems Officer, University of Rhode Island mkhalfayan@uri.edu
Finding 395209 (2023-040)
Significant Deficiency 2023
Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security O...
Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security Officer (vCISO) to support compliance as well as provide training and consulting services. The Assistance Vice President, Chief Information Officer is tasked with ensuring that the Written Information Security Program is updated annually and that compliance is maintained. Anticipated Completion Date: June 2024 Contact Person: Pamela Christman, Assistance Vice President, Chief Information Officer, Rhode Island College pchristman@ric.edu
Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) and Controller (Michelle Lane) Corrective Action: The University concurs with the finding. The University will make disbursements as soon as they are available, but no later than the three (3) business days fo...
Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) and Controller (Michelle Lane) Corrective Action: The University concurs with the finding. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner. Anticipated Completion Date: June 30, 2024
Name of Responsible Individual: University Registrar (Charee Ellison), Vice President of Academic Affairs (Dr. Renata Dusenbury) Corrective Action: The University concurs with this finding. This action is completed through a third party service (National Student Clearinghouse) which updates the NSL...
Name of Responsible Individual: University Registrar (Charee Ellison), Vice President of Academic Affairs (Dr. Renata Dusenbury) Corrective Action: The University concurs with this finding. This action is completed through a third party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner. Anticipated Completion Date: June 30, 2024
Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired ...
Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward. Anticipated Completion Date: June 30, 2024
Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days...
Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days after payment or the University becomes aware of the need to make an adjustment. Internal controls will be maintained by reporting on a daily basis as disbursements are posted. Anticipated Completion Date: June 30, 2024
2023-003 Allowable Cost- Payroll Recommendation We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Explanation of disagreement with audit finding: There...
2023-003 Allowable Cost- Payroll Recommendation We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Requirements to support documentation of payroll expenditures will be reviewed with school staff annually as part of grant support visits, resource materials provided and other technical assistance sessions. 2. As part of Spring 2024 site visits to be completed prior to June 30, 2024, Title I specialists will review with school staff requirements for documentation to support payroll expenditures using Title I funds. Documentation of stipend and temporary staff payroll will be collected and saved in the school’s grant monitoring folder. This activity will also occur in September 2024 for summer stipend/temp staff payments. 3. Charter schools utilizing Title II and/or Title IV funds will continue to participate in twice annual monitoring by the Office of Data Monitoring and Compliance to review support documentation for any stipend/temporary staff payments. 4. Schools leveraging ESSER funds in SY23/24 for stipend/temporary staff payments will be requested to upload support documentation to a district established SharePoint site prior to June 30, 2024. 5. By April 30, 2024 requirements for payroll expenditure documentation will be reviewed with district offices implementing grant funded district initiatives. These meetings include Title I, Title II, Title III, Title IV, Perkins and COVID relief grant funds. All district offices will be required to save support documentation for stipend and temporary staff payments for district level and/or district coordinated activities to a SharePoint folder to ensure accessibility for future monitoring activities. The district staff person from the Office of Data Monitoring and Compliance assigned to support the federal grant will review uploaded materials to ensure the documentation supports payroll expenditures. Name(s) of the contact person(s) responsible for corrective action: Kimberly Hoffmann Planned completion date for corrective action plan: June 2024.
View Audit 305063 Questioned Costs: $1
Identifying Number: Finding No. 2023-002: Special Tests – Enrollment Reporting and Gramm-Leach-Bliley Act Compliance/Material Weakness Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Bleach-Bliley Act, which are both part...
Identifying Number: Finding No. 2023-002: Special Tests – Enrollment Reporting and Gramm-Leach-Bliley Act Compliance/Material Weakness Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Bleach-Bliley Act, which are both part of special tests identified in the 2023 Compliance Supplement. ¬ Corrective Actions Taken or Planned: Responsible Official: Iman Riddick, Registrar, Dean Lane, Chief Information Officer (CIO) Anticipated Completion Date: 06/30/2024 View of Responsible Individuals: Management agrees with the assessment and finding. Dean Lane, CIO, will review the annual updates to the Student Financial Assistance Cluster within the OMB Compliance Supplement to ensure the Institute has policies, procedures, and controls in place for all required compliance requirements. For the noncompliance identified around the Gramm-Leach Bliley Act, the Institute will ensure compliance by establishing a formal written policy that will be created by Dean Lane, CIO, that addresses all required elements for a written information security program listed in the OMB Compliance Supplement. The CFO will review the policy once completed to ensure all required elements within the Compliance Supplement are included. For the noncompliance identified around the Enrollment Reporting special test, the Institute plans to have the Registrar attend comprehensive trainings around enrollment reporting offered by the National Student Clearinghouse (NSC) to further educate and enhance their understanding around the enrollment reporting compliance requirement. In addition, the Institute will have each month’s enrollment data submission by the Registrar to the National Student Clearinghouse reviewed by the Director of Financial Aid to verify completeness, accuracy, and timeliness of reporting. This will allow the Institute to correct any inaccurate reporting and verify timely submissions.
2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Management View and Corrective Action Plan February 9, 2024 Inaccurate Graduated Student Enrollment Reporting Management View and Opinion NYU Registrar reports a student's ...
2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Management View and Corrective Action Plan February 9, 2024 Inaccurate Graduated Student Enrollment Reporting Management View and Opinion NYU Registrar reports a student's enrollment, withdrawal and graduation status to the National Student Clearinghouse (NSC) weekly, per term, which includes a few weeks before and after the term has ended. NSC transfers this data to the National Student Loan Data System (NSLDS). During the degree/graduation reporting period to NSC, the graduation records for some students are not processed prior to NSC's calculated withdrawal which occurs at the start of the subsequent enrollment reporting period. As such, some students are reflected as withdrawn from a term, when in fact they graduated. This impacts the accuracy of student data reported to the National Student Loan Data System. Corrective Action Plan Currently, students self-identify when their loan servicer reflects an incorrect enrollment or loan repayment status. In these cases, the Office of Financial Aid or Registrar manually adjust the NSLDS/NSC file. NSC procedural timelines impact and limit NYU staff’s access to make manual adjustments. Going forward, the Office of Financial Aid and Registrar will collaborate to upload an NYU Graduated Student file directly to NSLDS to update the records of all students to ensure their graduation status are reported accurately and in a timely manner. This upload will be done through the Enrollment Spreadsheet Submittal function on the NSLDS website. The file will include graduated status information for each conferred student in our most recent conferral period. Timeline for Action Plan The corrective action plan will be implemented as follows: Starting in March 2024, the Office of Financial Aid will provide the NSLDS Graduated Student file template to the Registrar. At the close of each conferral period, the Registrar will populate the template spreadsheet with required data points for all graduating students. After the Office of Financial Aid securely receives the completed spreadsheet from the Registrar, it will be uploaded, within the required 60 days, to NSLDS for processing of the students’ graduation records. Responsible Individual: Jason Crowe Email: Jason.Crowe@nyu.edu
Finding 394755 (2023-002)
Significant Deficiency 2023
Finding Number: 2023-002 Condition: The College did not follow all the Tier Two arrangement requirements and disclosures. Planned Corrective Action: The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements...
Finding Number: 2023-002 Condition: The College did not follow all the Tier Two arrangement requirements and disclosures. Planned Corrective Action: The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements. Contact person responsible for corrective action: Ms. Taranne Roberts and Dr. Sharron T. Burnett Anticipated Completion Date: 06/30/2024
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