Corrective Action Plans

Finding 525689 (2024-001)

Significant Deficiency 2024

Middle Kentucky Community Action Partnership, Inc.

KY

Subrecipient Monitoring Reporting Significant Deficiency

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date...

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date. From this calendar an alert can and will e sent to the CFO and a designated second person to alert them as to the upcoming required date that this and other reports are to be submitted. The calendar both electronic and in written form is now in use and no further instances of this occurrence should occur within the fiscal department in the future.

View Audit 344835

Finding 525687 (2024-001)

Significant Deficiency 2024

The Primary Care Coalition of Montgomery County, Maryland, Inc.

MD

Subrecipient Monitoring Eligibility Reporting

Views of Responsible Officials: Management agrees with the finding and has already filed the required FFATA report. Completion Date: 11/22/2024

View Audit 344804

Finding 525682 (2024-004)

Material Weakness 2024

Flat Rock - Haw Creek School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports cov...

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Assistant will jointly review all expenditures or fedral grant awards with in the fiscal year that are to be reported to ensure accuracy of reporting. Anticipated Completion Date: July 2025

View Audit 344796

Finding 525630 (2024-001)

None 2024

Midland Univeristy

NE

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cance...

Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cancel any portion of loans to be distributed. Name(s) of Contact Person(s) Responsible for Corrective Action: Doug Watson, Financial Aid Director & Joseph Harnisch, CFO Anticipated Completion Date: The Corrective Action was completed on August 16, 2024.

View Audit 344747

Finding 525618 (2024-001)

None 2024

Town of Dudley, Massachusetts

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

When the reporting portal opens in late March 2025 for Annual Reports due by April 30, 2025 (for the April 1, 2024-March 31, 2025 reporting period), the Town Accountant will enter a project under expenditure category 6.1 (Revenue Replacement) that will include the $3,519,030.12 that was obligated an...

When the reporting portal opens in late March 2025 for Annual Reports due by April 30, 2025 (for the April 1, 2024-March 31, 2025 reporting period), the Town Accountant will enter a project under expenditure category 6.1 (Revenue Replacement) that will include the $3,519,030.12 that was obligated and expended by Dudley for revenue replacement. On the overview section of the 2024 report the town will report the full $3,519,030.12 as obligated and expensed.

View Audit 344723

Finding 525596 (2024-001)

Material Weakness 2024

River Network

CO

Procurement, Suspension & Debarment Subrecipient Monitoring

Management agrees with the recommendation to establish and follow a documented internal control process over the review of procurement. Staff will work with management to ensure that subrecipients and contractors with expenses over federal limits will be tested against the debarment list. Additional...

Management agrees with the recommendation to establish and follow a documented internal control process over the review of procurement. Staff will work with management to ensure that subrecipients and contractors with expenses over federal limits will be tested against the debarment list. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.

View Audit 344697

Finding 525578 (2024-003)

Material Weakness 2024

Gage County

NE

Subrecipient Monitoring

The Sheriff will discuss with the administrative staff to develop policies to ensure timely and accurate remittances to the Treasurer’s office.

View Audit 344683

Finding 525554 (2024-001)

Significant Deficiency 2024

Bethany College

KS

Student Financial Aid Cash Management Subrecipient Monitoring

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: Febru...

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President

View Audit 344637

Finding 525553 (2024-002)

Significant Deficiency 2024

Bethany College

KS

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency

Corrective Action Plan 2024-002: The College concurs with the finding and will formalize its written Information Security Program. Anticipated Completion Date: Spring 2025 Contact Person: Joshua Bieber, Director of Information Technology

View Audit 344637

Finding 525546 (2024-001)

Material Weakness 2024

University of Wisconsin Hospitals & Clinics Authority

WI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor...

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: Management became aware of the need to perform additional procedures to comply with Uniform Guidance part way through the year ended June 30, 2024 and completed the evaluation once it became known. However, by that time, the vendor was already charged to the grant prior to the completion of the vendor evaluation. UW Health has developed processes and procedures to ensure compliance with the Uniform Guidance and that evaluations are taking place prior to any vendors being charged to the grant. UW Health is also in the process of updating policy to comply with Uniform Guidance. Anticipated completion Date: June 2025 UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services and Jamie Soyk, Program Director – Financial Reporting

View Audit 344625

Finding 525540 (2024-002)

None 2024

Benedict College

SC

Subrecipient Monitoring

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: An internal assessment of security needs caused the College to engage a professional security company and appoint a virtual Chief Information Security Officer (vCISO) to bolster information security posture and align with regulat...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: An internal assessment of security needs caused the College to engage a professional security company and appoint a virtual Chief Information Security Officer (vCISO) to bolster information security posture and align with regulatory requirements. The security team focused on the following: • Implementing 24/7 security monitoring to safeguard our digital infrastructure. • Setting up a Security Information and Event Management (SIEM) system to proactively detect and respond to threats. • Formalizing security reporting processes to enhance transparency and accountability. • Conducting vulnerability assessments to identify and address potential security weaknesses. The formal written assessment plan will be appropriately documented and reviewed by April 2025. A status report on compliance with GLBA will be made to the Board annually at its May or June meeting. Person Responsible for Corrective Action Plan: Anthony Caldwell, CIO Sharron T. Burnett, VP Finance & Operations/CFO Anticipated Date of Completion: June 30, 2025

View Audit 344611

Finding 525515 (2024-002)

Significant Deficiency 2024

State of Hawaii Department of Transportation- Harbors Division

HI

Subrecipient Monitoring

Management will coordinate with its contractor to expand the staffing assigned to conduct oversight of the federal grant program to ensure compliance. Management will develop and follow a checklist to assess the compliance risks of the subrecipient. Assessments will be conducted at selected mileston...

Management will coordinate with its contractor to expand the staffing assigned to conduct oversight of the federal grant program to ensure compliance. Management will develop and follow a checklist to assess the compliance risks of the subrecipient. Assessments will be conducted at selected milestones beginning at development of the grant application and throughout the life of the grant, and will consider the following factors: Subrecipient’s prior experience with grants, either as a direct recipient or subrecipient; Results of the previous compliance audit of the same or similar program that has been audited as a major program; Changes in key personnel; System changes or updates; and In-person, on-site monitoring of the activities of any subrecipient shall take place annually to ensure that the subaward is used for authorized purposes, in accordance with federal statute and regulations.

View Audit 344581

Finding 525514 (2024-001)

Significant Deficiency 2024

State of Hawaii Department of Transportation- Harbors Division

HI

Subrecipient Monitoring Reporting

Require the contractor to develop a checklist and schedule of compliance requirements related to subawards and Harbors Division’s role as the pass-through entity. Checklists will be used during the grant application and awards process to ensure timely submittal of the required Federal Funding Accoun...

Require the contractor to develop a checklist and schedule of compliance requirements related to subawards and Harbors Division’s role as the pass-through entity. Checklists will be used during the grant application and awards process to ensure timely submittal of the required Federal Funding Accountability and Transparency Act report. As provided in the Work Order, Harbors Division will work with the contractor to develop processes and establish milestones and schedules to complete the work necessary to meet required report submittal deadlines in accordance with the terms of the grant. For example, the checklist and schedule of compliance requirements shall include dates for subrecipient submittals to Harbors Division and granting agency filing deadlines. Harbors Division will institute a compliance review committee comprised of management for oversight of the federal grant program and to expand the support to ensure compliance.

View Audit 344581

Finding 525307 (2024-001)

Material Weakness 2024

University of Rio Grande

OH

Student Financial Aid Subrecipient Monitoring Material Weakness

Finding Number: 2024-001 Condition: The University did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: To address the root cause of the enrollment reporting error, which stemmed from turnover in the registrar’s office during ...

Finding Number: 2024-001 Condition: The University did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: To address the root cause of the enrollment reporting error, which stemmed from turnover in the registrar’s office during Spring 2024 and resulted in an oversight of unofficial withdrawals reported to the Clearinghouse/NSLDS until identified during the audit, a comprehensive corrective action plan has been developed. Our institution is implementing a new ERP system, we will automate enrollment reporting to ensure timely and accurate data submission. Additional staff will be recruited and trained, with cross-training programs to mitigate turnover impact. Regular internal audits will ensure compliance. Improved communication and coordination will enable continuous monitoring to improve overall efficiency and accuracy. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: 09/01/2024

View Audit 344535

Finding 525272 (2024-001)

Material Weakness 2024

Cheney Care Community

WA

HUD Housing Programs Reporting Subrecipient Monitoring

Finding 2024-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2025 Recommendation: It was recommended management of Cheney Care Community review...

Finding 2024-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2025 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the financial reporting and close processes to determine whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Action Taken: Cheney Care Community will review their internal controls over the financial reporting and close processes to determine whether additional controls need to be implemented going forward.

View Audit 344495

Finding 525251 (2024-003)

Significant Deficiency 2024

American Baptist Theological Seminary

TN

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

American Baptist College does not dispute this finding. It is the College’s policy to submit all records/documentation by published due dates. To do so, however, the College must have qualified employees to carry out stated requirements. Since July 2024 the College has published a job opening for th...

American Baptist College does not dispute this finding. It is the College’s policy to submit all records/documentation by published due dates. To do so, however, the College must have qualified employees to carry out stated requirements. Since July 2024 the College has published a job opening for the Director of Financial Aid but has been unable to fill the position due to limited resources. The College is currently working with a consulting firm to provide financial aid services to the student body and will publish the job position until it is filled.

View Audit 344463

Finding 525236 (2024-001)

Material Weakness 2024

YWCA Metropolitan Chicago

IL

Subrecipient Monitoring Internal Control / Segregation of Duties Eligibility § 200.303

Condition: There was a lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with federal program requirements, specifically over the following: a)Tier (day care home eligibility) determinations b)Subrecipient monitoring Noncompliance was ident...

Condition: There was a lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with federal program requirements, specifically over the following: a)Tier (day care home eligibility) determinations b)Subrecipient monitoring Noncompliance was identified for subrecipient monitoring as noted in the context below. Planned Corrective Action: (a)Management is working with the Software company staff to develop software-based evidence of second review. If this is not possible, a tracking mechanism external to the software will be developed by March 2025. (b)Under management’s supervision, monitoring visits are being brought current on the contract currently in place and will be completed as required by end of contract. A tracking mechanism has been put in place to ensure compliance with the required number of monitoring visits and timeliness. Contact person responsible for corrective action: Loukisha Pennex, Chief of Youth and Family Potential and Anjanette Brown, CFO. Anticipated Completion Date: June 2025

View Audit 344452

Finding 525195 (2024-001)

Material Weakness 2024

Eastbrook Community School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Context: For testing of activities allowed and unallowed, a sample of 21 vendor vouchers were selected for testing. Two vouchers totaling $61,841 were related to disbursements for floor replacement costs incurred and charged to the ESSER III grant award. The School Corporation received approval fr...

Context: For testing of activities allowed and unallowed, a sample of 21 vendor vouchers were selected for testing. Two vouchers totaling $61,841 were related to disbursements for floor replacement costs incurred and charged to the ESSER III grant award. The School Corporation received approval from the Indiana Department of Education (IDOE) through the grant application to utilize a portion of the ESSER II grant award for floor replacement throughout the School Corporation. During the audit period, the School Corporation had $88,600 that was disbursed and reported on the SEFA for ESSER II and $142,400 that was disbursed and reported on the SEFA for ESSER III for floor replacement. The School Corporation did not receive approval from the Indiana Department of Education (IDOE) to use ESSER III funding for the flooring project as required for construction or remodeling related projects. The total amount of the flooring project funded by the ESSER III grant, including amounts paid prior to the audit, was $219,992. The portion of the flooring project paid by the ESSER II grant was $163,000 which was properly approved by IDOE. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will put a system in place to ensure that each grant application is printed in its entirety, including the narratives, and file them in the appropriate grant files maintained by the business manager. The business manager will verify that the agreed upon expenditures are included in the grant application before any orders are placed or purchases are approved. Additionally, accounting descriptions set up in the financial software will better reflect IDOE-approved expenditures. Anticipated Completion Date: February 25, 2025

View Audit 344409 Questioned Costs: $1

Finding 525191 (2024-002)

Material Weakness 2024

Eastbrook Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the fede...

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have a contract with the company that included the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $231,000. Audit adjustments were proposed, accepted by the School Corporation, and made to the SEFA to correct the issues noted above. We also noted there was no documented, secondary review of the information in the SEFA by someone other than the preparer. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager/Treasurer Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon requirements is a repeat finding due to the timing of the prior audit and a lag for new controls to take effect. When the School Corporation is awarded federal funds that will be used for construction, alteration, or repair projects in excess of $2,000, the superintendent and/or business manager will notify the contractors that the project is being funded by federal funds and the requirements as outlined by the Davis-Bacon Act. In addition, the superintendent and/or the business manager will ensure that the contractors provide weekly payroll report certifications and will review the documents to ensure compliance with the wage rate requirements. The SEFA, which is included with the Annual Financial Report, is reviewed by the deputy treasurer upon its completion. Going forward, any corrections or adjustments made to the SEFA will be reviewed by the deputy treasurer or other district office employee. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 344409

Finding 525080 (2024-001)

Significant Deficiency 2024

Bothwell Regional Health Center

MO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

February 27, 2025 Finding 2024-001 U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: T9952110 Management's Response: Bothwell Regional Health Center will begin performing suspens...

February 27, 2025 Finding 2024-001 U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: T9952110 Management's Response: Bothwell Regional Health Center will begin performing suspension and debarment checks on all vendors/contracts funded with grants in 2025. This process will be implemented in 2025 pending policy review processes. Bothwell Regional Health Center will start documenting reviews of suspension and debarment checks of vendors receiving Federal funds while onboarding new vendors and monitoring periodically throughout the year. Views of Responsible Officials and Corrective Action: Management agrees with the finding and management will implement a control process to ensure that suspension and debarment checks are performed on vendors/contracts funded with grants in 2025. Responsible Official: Steven Davis Chief Financial Officer Bothwell Regional Health

View Audit 344357

Finding 525033 (2024-001)

None 2024

Wartburg College

IA

Subrecipient Monitoring

The CIO has already drafted a new suite of 10 IT Policies that address the relevant regulations, including GLBA. Two (2) of the 10 have already been approved by the Senior Leadership Team (SLT) and posted on the College portal, My.Wartburg. The next 4 are currently under review by SLT.

View Audit 344346

Finding 525031 (2024-001)

None 2024

Pahokee Housing Authority

FL

HUD Housing Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Management has implemented and executed specific corrective actions to address each of HUD’s Findings. The Authority’s Assistant Director, Satyam Polineni has assumed the responsibility of implementing and executing the specific corrective actions and has completed implementation as of February 14,...

Management has implemented and executed specific corrective actions to address each of HUD’s Findings. The Authority’s Assistant Director, Satyam Polineni has assumed the responsibility of implementing and executing the specific corrective actions and has completed implementation as of February 14, 2025.

View Audit 344345

Finding 525012 (2024-002)

None 2024

Our Lady of the Lake University of San Antonio

TX

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Ins...

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The failure to report certain enrollment status changes to the NSLDS on a timely basis during the fiscal year ending May 31, 2024, was an isolated instance due to turnover in the Registrar’s Office. The University has updated the process for reporting enrollment status changes to the NSLDS and has ensured there is adequate cross-training in the Registrar’s Office to prevent future instances of non-compliance with reporting deadlines. Status: Completed Person Responsible for Implementing: Melissa Delgado, Registrar Implementation Date: 01/01/2025

View Audit 344329

Finding 524963 (2024-001)

Material Weakness 2024

National University

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and impo...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

View Audit 344308 Questioned Costs: $1

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Corrective Action Plans

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