Corrective Action Plans

Finding 369551 (2023-001)

None 2023

MO

Subrecipient Monitoring

Condition: Federal Award Programs Audits - The Organization was notified it did not pass its physical REAC inspection. Recommendation: The Organization should adopt a policy which requires periodic (more than annual) review of its operating and maintenance policies and procedures, as well as review ...

Condition: Federal Award Programs Audits - The Organization was notified it did not pass its physical REAC inspection. Recommendation: The Organization should adopt a policy which requires periodic (more than annual) review of its operating and maintenance policies and procedures, as well as review by the individuals monitoring the operating and maintenance of the property, to ensure that physical maintenance of the property is within good standing. View of Responsible Officials and Corrective Actions: Financial Reporting - Shawmet Homes, Inc. will take the corrective action to meet all of the requirements as indicated and agreed to by HUD. Anticipated Completion Date: Completion date to reflect full compliance in reporting will be resolved within the HUD requirements.

View Audit 290839

Finding 369541 (2023-002)

Significant Deficiency 2023

Child and Family Agency of Southeastern Connecticut, Inc.

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Audit Finding Reference: 2023-002 Recommendation: The Agency should establish a system of controls to ensure that expenditures of the grant are allowable under the grant conditions.Plan of Action:  CFA agrees with the auditors finding. Management will develop a written procedure to ensure that p...

Audit Finding Reference: 2023-002 Recommendation: The Agency should establish a system of controls to ensure that expenditures of the grant are allowable under the grant conditions.Plan of Action:  CFA agrees with the auditors finding. Management will develop a written procedure to ensure that proper action is taken at the time the invoice is submitted for approval. This will include reviewing the cost principles in Subpart E of the Uniform Guidance with the appropriate staff to ensure they are charging allowable costs to the grant. A system of internal controls will be developed and reviewed to ensure that all grant expenditures are allowable under the regulations of the grant. We anticipate having this written procedure ready by February 29, 2024. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please contact Lisa Baxter. BaxterL@ChildandFamilyAgency.org Sincerely yours, Lisa Baxter Chief Financial and Administrative Officer

View Audit 290825

Finding 369535 (2023-001)

Significant Deficiency 2023

Child and Family Agency of Southeastern Connecticut, Inc.

CT

Procurement, Suspension & Debarment Subrecipient Monitoring

Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Name of Contact Person: Lisa Baxter, Chief Financial and Administrative Officer Audit Fi...

Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Name of Contact Person: Lisa Baxter, Chief Financial and Administrative Officer Audit Finding Reference: 2023-001 Recommendation: We recommend the system of controls for procurement, suspension and debarment are updated to properly address the necessary requirements. Plan of Action: CFA agrees with the auditors finding. Management will develop a written procedure to ensure that proper action is taken at the time the invoice is submitted for approval. We anticipate having this written procedure ready by February 29, 2024. As of today the vetting process is being applied by our HR staff with current subcontractors and staff working in the federally funded programs.

View Audit 290825

Finding 369513 (2023-003)

Material Weakness 2023

Rapid City Club for Boys, Inc.

SD

Internal Control / Segregation of Duties Subrecipient Monitoring

Finding No 2023-003: Heartland Heights Apartments Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has met with Lloyd Property Management and has been receiving regular financial statements. The Organization will implement a plan to evaluate internal cont...

Finding No 2023-003: Heartland Heights Apartments Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has met with Lloyd Property Management and has been receiving regular financial statements. The Organization will implement a plan to evaluate internal controls to ensure adequacy and effectiveness. Anticipated Completion Date: Ongoing

View Audit 290783

Finding 369499 (2023-001)

Significant Deficiency 2023

Wells College

NY

Student Financial Aid Subrecipient Monitoring

Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The fin...

Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT Finding 2023-001 - Student Financial Assistance Cluster Compliance Requirement N. Gramm-Leach-Bliley Act-Student Information Security Recommendation: Our auditors recommend that we conduct a formal risk assessment and update our written information security program (WISP) to ensure the seven required elements are addressed. As part of this process, Information Technology (IT) policies should be updated to align with our current IT environment and be formally approved and implemented throughout the College. Action Taken: Wells College is partnering with Grey Castle Security to do a Risk Assessment and Penetration test. This will be completed in February. Additionally, Grey Castle has helped to redraft our Incident Response Plan. This has been completed, and training on this plan is scheduled for later in January, with Tabletop simulations occurring with the Wells College Emergency Planning Team and IT in February. Over the next couple of months, IT will be refreshing its policies in collaboration with the Wells College Technology Advisory Group (TAG), a committee representing all areas of the college. Once TAG has approved policies, they will go to the Cabinet for approval. Multiple policies will be merged to create the WISP as a self-contained document, rather than the multiple policies in place. The Chief Financial Officer, Robert Cree, is responsible for implementing this plan by June 30, 2024, and can be reached at (315) 364-3408 or rcree@wells.edu .

View Audit 290774

Finding 369473 (2023-003)

Significant Deficiency 2023

Western Seminary

OR

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhan...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhancing the documentation and reporting of our internal security audits. Person Responsible for Corrective Action Plan: Sean Gordon, Director of Information Technology Operations and Software Development Anticipated Date of Completion: June 30, 2024

View Audit 290692

Finding 369423 (2023-003)

Material Weakness 2023

Newberry College

SC

Student Financial Aid Subrecipient Monitoring Material Weakness

Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion...

Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024

View Audit 290607

Finding 369355 (2023-001)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the Col...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024

View Audit 290586

Finding 369351 (2023-001)

Significant Deficiency 2023

New Mexico Aging and Long-Term Services Department

NM

Cash Management Subrecipient Monitoring Significant Deficiency

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division...

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division (ASD) has processed the OPR for return of the $10,958 to the Department of Health. ALTSD will implement training for agency directors and other leaders who oversee and implement grant projects. This training will include the process for development of the initial budget allocations to appropriate categories grant procedures for requesting changes to the budget categories from the funder. The training will also include a process for streamlined communication between the director or manager and the ASD grant staff responsible for the financial controls. Timeline of Corrective Actions: Perform first training to any programmatic grant manager or involved staff by January 1, 2024. This will be ongoing any time a new grant award is received by the agency. Responsible Party(ies): Chief Financial Officer

View Audit 290577

Finding 369348 (2023-002)

Material Weakness 2023

Valparaiso Community Schools

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon...

Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon wage rate requirement language has been added to all bid packets and quote solicitations. The Educational Support Coordinator and Deputy Treasurer will work with VCS Department Directors to monitor all federally-funded construction projects for compliance with said language. Anticipated Completion Date: February 1, 2024

View Audit 290574

Finding 369341 (2023-001)

Material Weakness 2023

Columbia Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness

Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in ag...

Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the agreement with West Roofing to install and renovate the HVAC system at Columbia High School, which was January 7, 2021, ESSER funds were not awarded to the District. The District planned on using its Permanent Improvement funds (a non -federal program sourced fund) to pay West Roofing. The District initially paid West Roofing from the Permanent Improvement fund for the installation/renovation of the HYAC at Columbia High School as per the initial contract. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through ESSER funds. The prevailing wage was not met under the existing contract. The District has implemented the following Action Plan for Correction: 1. The Treasurer will ensure that all agreements intended to be sourced through Federal Funds will contain prevailing wage rate provisions prior to signing such agreements. 2. The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Funds, 3. The Treasurer will educate all responsible parties in the District regarding prevailing wage documentation to ensure appropriate documentation is obtained prior to payment to the contractors and prior to requesting Federal Funds.

View Audit 290568

Finding 369320 (2023-005)

Significant Deficiency 2023

Great Plains Food Bank

ND

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individu...

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate

View Audit 290553 Questioned Costs: $1

Finding 369311 (2023-003)

Material Weakness 2023

Cleary University

MI

Subrecipient Monitoring Material Weakness

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Cleary understands that GLBA requires universities and other institutions to create controls concerning the handling of data in conformance with best practices in cybersecurity. We realize that it is vital for us to be fully comp...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Cleary understands that GLBA requires universities and other institutions to create controls concerning the handling of data in conformance with best practices in cybersecurity. We realize that it is vital for us to be fully compliant to safeguard our institution's and our students' sensitive information, and we have put in place a robust set of activities and services. The GLBA requires us to implement administrative, technical, and physical safeguards to protect the security and confidentiality of non-public personal information (NPI). Some of these requirements have been addressed in the past fiscal year, and the rest are currently being implemented in this fiscal year. Person Responsible for Corrective Action Plan: Eric Riddering, Director of Information Technology Anticipated Date of Completion: October 2024

View Audit 290552

Finding 369307 (2023-002)

Significant Deficiency 2023

Union Parish School Board

LA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding 2023-002 Internal Controls Over Reporting Conditions Identified: Testing the annual ESSER performance report with data on expenditures, subrecipients, uses of funds including mandatory reservation, expenditures, number of key positions, and criteria used to allocate the funds to the schools ...

Finding 2023-002 Internal Controls Over Reporting Conditions Identified: Testing the annual ESSER performance report with data on expenditures, subrecipients, uses of funds including mandatory reservation, expenditures, number of key positions, and criteria used to allocate the funds to the schools was not complete and did not agree with information submitted to the LDOE. Corrective Action Plan: The staff member who is responsible for preparing and completing the necessary ESSER reports has received a copy of this finding and will make the necessary changes when future information is submitted to the LDOE.

View Audit 290539

Finding 369242 (2023-001)

None 2023

Town of Lincoln

MA

Subrecipient Monitoring Reporting § 200.1

RE: Single Audit Finding 2023-001 I provide the following information regarding the Town of Lincoln’s Corrective Action Plan: Finding 2023-001 Condition: Obligations were overstated by $1,435,098 on March 31, 2023 Project and Expenditure report. Corrective Action Planned: The Town now has a cle...

RE: Single Audit Finding 2023-001 I provide the following information regarding the Town of Lincoln’s Corrective Action Plan: Finding 2023-001 Condition: Obligations were overstated by $1,435,098 on March 31, 2023 Project and Expenditure report. Corrective Action Planned: The Town now has a clear understanding of the reporting requirements for obligations, and will report the correct amounts in the next report. Anticipated Completion Date: March 31, 2024 Contact: Colleen Wilkins, Finance Director/Town Accountant, wilkinsc@lincolntown.org 781-259-2673 Please let me know if you have any questions or if you need additional information. Sincerely, Colleen Wilkins Finance Director/Town Accountant Town of Lincoln 16 Lincoln Rd. Lincoln, MA 01773

View Audit 290526

Finding 369128 (2023-003)

Significant Deficiency 2023

Oklahoma State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024

View Audit 290482

Finding 369061 (2023-003)

Material Weakness 2023

White Oak Independent School District

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at t...

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at that time, left in May of 2023 and was replaced with a Business Manager in June of 2023. The Business Manager began assessing specific deficiencies within the department. New procedural manuals were adopted in August of 2023. The business manager left in December of 2023 due to personal reasons and a new CFO was hired. A new payroll coordinator was also onboarded during December 2023. Between the new staff members and the new Superintendent all systems have been turned over and are trying to get back to an effective and efficient level of function. The new plan of action is to allow the CFO to set goals and make necessary changes regarding business operations and procedures. The audit findings will be our guide for making corrective actions. The CFO and Superintendent will continue to update processes, written procedures, and establish appropriate internal controls to ensure appropriate oversight and compliance with laws, rules, and regulations. Business Office staff will continue working to adequately segregate duties and establish additional monthly and annual reconciliation processes with oversight by the CFO, program directors, andSuperintendent as appropriate. Responsible Party: Carrie Howard, CFO Estimated Completion Date: August 31, 2024

View Audit 290464

Finding 369060 (2023-002)

Material Weakness 2023

White Oak Independent School District

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at t...

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at that time, left in May of 2023 and was replaced with a Business Manager in June of 2023. The Business Manager began assessing specific deficiencies within the department. New procedural manuals were adopted in August of 2023. The business manager left in December of 2023 due to personal reasons and a new CFO was hired. A new payroll coordinator was also onboarded during December 2023. Between the new staff members and the new Superintendent all systems have been turned over and are trying to get back to an effective and efficient level of function. The new plan of action is to allow the CFO to set goals and make necessary changes regarding business operations and procedures. The audit findings will be our guide for making corrective actions. The CFO and Superintendent will continue to update processes, written procedures, and establish appropriate internal controls to ensure appropriate oversight and compliance with laws, rules, and regulations. Business Office staff will continue working to adequately segregate duties and establish additional monthly and annual reconciliation processes with oversight by the CFO, program directors, and Superintendent as appropriate. Responsible Party: Carrie Howard, CFO Estimated Completion Date: August 31, 2024

View Audit 290464

Finding 369047 (2023-005)

Significant Deficiency 2023

Connors State College

OK

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of cu...

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Office of Internal Audit is beginning work on another System-wide Information Technology (IT) Penetration Testing and Vulnerability Assessment at all institutions within the OSU/A&M System. They will be coordinating with local IT staff from each institution, as well as the OSU Chief Information Officer, Raj Murthy and the A&M System Chief Information Officer, Heath Hodges, to schedule the work. Name(s) of the contact person(s) responsible for corrective action: Heath Hodges and Kevin Isom, Planned completion date for corrective action plan: March 31, 2024

View Audit 290458

Finding 369029 (2023-001)

Significant Deficiency 2023

City of Murfreesboro, Tennessee

TN

Subrecipient Monitoring HUD Housing Programs Reporting

Planned Corrective Actions: The City continues to work with a consultant to assist staff with administration of the Community Development Block Grants program. Community Development has also hired a new Assistant Director and Grant Coordinator during FY 24 who have worked with the consultant to revi...

Planned Corrective Actions: The City continues to work with a consultant to assist staff with administration of the Community Development Block Grants program. Community Development has also hired a new Assistant Director and Grant Coordinator during FY 24 who have worked with the consultant to review processes and implement changes as necessary. Process reviews include reviewing methods for tracking and reporting time and activity spent on the programs.

View Audit 290453

Finding 367260 (2023-001)

Significant Deficiency 2023

Board of Education of Allegany County

MD

Subrecipient Monitoring Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Action: The Board acknowledges the value of an audit/monitoring function. However, as a result of budget constraints, the Board does not plan to implement an internal audit/monitoring function.

View Audit 290343

Finding 367210 (2023-002)

Significant Deficiency 2023

Southern California Institute of Architecture

CA

Student Financial Aid Subrecipient Monitoring Cash Management

Finding number 2023-002 – Eligibility-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action will be implemented in January 2024. The...

Finding number 2023-002 – Eligibility-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action will be implemented in January 2024. The school's management agrees with the finding and has implemented procedure whereby the Financial Aid department will include the Student Identification and Expected Family Contribution (EFC) on the Work Study log to monitor awards against the student’s EFC.

View Audit 290324

Finding 367209 (2023-001)

Significant Deficiency 2023

Southern California Institute of Architecture

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action wa...

Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action was implemented in December 2023. The school's management agrees with the finding and has implemented procedure whereby changes in enrollment status reported to the National Student Clearinghouse will be sample reviewed by the Registrar within NSLDS five business days following the reporting date to ensure the accuracy of the information. As an additional layer, the Financial Aid Manager will also calendar a review reminder. Permanent address changes will be reported on a six-week cycle after the add/drop period each term. Address changes will also be sample reviewed to ensure accuracy within NSLDS.

View Audit 290324

Finding 367192 (2023-001)

Significant Deficiency 2023

University of Saint Katherine

CA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: USK's 001 Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 1. Write a comprehensive Information Security Program, specifically addressing GLBA compliance, and the below areas of concern: a. Design and impleme...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: USK's 001 Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 1. Write a comprehensive Information Security Program, specifically addressing GLBA compliance, and the below areas of concern: a. Design and implement safeguards to protect customer information. b. Address risk assessment, identifying how risks are evaluated and categorized and how existing controls mitigate these risks. Include a plan to implement additional mitigations or formal risk acceptance for any risks outside of management’s risk. c. Detail and establish continuous monitoring processes for information systems or periodic vulnerability assessments and penetration testing. d. Implement policies and procedures that support employee and information security staff training, awareness, and skills. e. Create procedures to periodically assess service providers. f. Review the plan annually, or as needed, as policies, vendors, and staffing change g. Present the written annual status report on the effectiveness of the program to USK’s cabinet Persons Responsible for Corrective Action Plan: Laurel Maguire Controller, Director of HR / Marina Trigonis COO / Wayne Mealhouse - LinkServ Anticipated Date of Completion: May 1st, 2024

View Audit 290312

Finding 367181 (2023-001)

Significant Deficiency 2023

City of Clarksville

TN

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 3...

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 30, 2023.

View Audit 290301

Corrective Action Plans

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