Corrective Action Plans

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The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.
The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.
Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had e...
Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had expensed the entire annual license fee. The period for eligible expenditures did not begin until October 1, 2022. This journal entry expensed the full cost of the invoice, $11,914.50, and the district did not prorate the costs to include only those expenses from October 1, 2022 through June 30, 2023. The District did not adhere to the proper period for expenditures. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop a summary of all federal grants. This summary will detail the fiscal year it is associated with but more importantly, it will provide the proper period of eligible expenditures for each federal funding source. This summary may be used and readily available at the time approvals are granted for expenditures. If an expense does not fall within the eligible time period, the expense can be rejected by the approver. This summary will be shared with all administrators and staff. In addition, the process for reclass journal entries will also include a pause to check that each invoice associated with a federal grant, is falling within the proper period of expenditures. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools
The Cooperative will make required deposits to the General Operating Reserve.
The Cooperative will make required deposits to the General Operating Reserve.
While this finding is isolated to the Wood Clinic which ended its AACO program in November 2022, we have communicated the requirement to maintain supporting award documentation to all Penn Medicine practices continuing with Ryan White programs.
While this finding is isolated to the Wood Clinic which ended its AACO program in November 2022, we have communicated the requirement to maintain supporting award documentation to all Penn Medicine practices continuing with Ryan White programs.
The University uses the Visual Compliance tool to provide dynamic screening of vendors in order to reduce administrative burden, eliminating the need to run screenings periodically, and to provide timely notification of any potential suspension and debarment issues with vendors. As part of the FY22 ...
The University uses the Visual Compliance tool to provide dynamic screening of vendors in order to reduce administrative burden, eliminating the need to run screenings periodically, and to provide timely notification of any potential suspension and debarment issues with vendors. As part of the FY22 audit, we realized that during the transition from manual screening of vendors to the integration of Visual Compliance with our vendor system, the initial screening in Visual Compliance for certain vendors, appeared to have been missed. Therefore, in February 2023, the Procurement Office ran a batch screen on all active vendors missing the screening documentation in VC at that time; and no further action is needed as a result of the current finding. However, due to the timing of that corrective action plan, the 2 vendors, BMG Labtech Inc and Diagnostic Biochips Inc, had invoices paid in FY23 prior to the corrective action such that there was no evidence of their screening in our system at the time of payment.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: In order to remediate cited deficiencies and to bring Southern Wesleyan University into compliance with updated regulation changes to the Gramm-Leach-Bliley Act, the Department of Information Technology will update its written info...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: In order to remediate cited deficiencies and to bring Southern Wesleyan University into compliance with updated regulation changes to the Gramm-Leach-Bliley Act, the Department of Information Technology will update its written information security program. In addition, the department will also sufficiently document its security risk assessment and safeguards. This documentation will include sufficient information on general threats, the implementation of vendor management policies and reviews, and the implementation of an incident response plan. After all the aforementioned documentation has been compiled, the department will provide a report to the Board at the university's fall 2024 Board of Trustee’s meeting, detailing the measures enacted. Person Responsible for Corrective Action Plan: Warren Dennis, Assistant Director of Information Technology Anticipated Date of Completion: 06/01/2024
2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulation...
2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Executive Director will review the completed risk assessment to identify specific shortcomings, so that safeguards can be documented in relation to those specific risks. Additionally, he will review the updated GBLA regulations and ensure the University is in compliance. Name of the contact person responsible for corrective action: Brandon Ray, Executive Director, Information Technology Planned completion date for corrective action plan: January 31, 2023.
U.S. Department of Education 2023-001 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance w...
U.S. Department of Education 2023-001 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the state criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024
2023-002 -#84.425D COVID-19 Elementary and Secondary School Emergency Relief Fund II Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-131309-DPI-ESSERFll-163 Pass-through Entity: Wisconsin Department of Public Instruction Criteria: Wage rate requirements apply t...
2023-002 -#84.425D COVID-19 Elementary and Secondary School Emergency Relief Fund II Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-131309-DPI-ESSERFll-163 Pass-through Entity: Wisconsin Department of Public Instruction Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborer must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor complies with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $34,828. There was not a prevailing wage clause in the contract and certified payrolls were not received. Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $34,828. Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Consider determining if the contractor performing the project in 2022-2023 paid prevailing wage rates for costs reimbursed by the grant. Otherwise, the District should replace the cost with other allowable costs. Response: The District replaced the cost with other allowable costs. Contact Person: Doreen Treuden Anticipated Completion: November 27, 2023
View Audit 5871 Questioned Costs: $1
Views of Responsible Officials and Planned Corrective Actions: The Association will undertake review of its procedures related to FFATA reporting and will implement additional controls to ensure timely submission of FFATA sub-award reports.
Views of Responsible Officials and Planned Corrective Actions: The Association will undertake review of its procedures related to FFATA reporting and will implement additional controls to ensure timely submission of FFATA sub-award reports.
#2023-003 Significant Deficiency in internal controls and noncompliance related to reporting: The District did not have adequate internal controls over meal claiming process and as a result, errors were made and not detected. Recommendation: Personnel need to be assigned to provide a second rev...
#2023-003 Significant Deficiency in internal controls and noncompliance related to reporting: The District did not have adequate internal controls over meal claiming process and as a result, errors were made and not detected. Recommendation: Personnel need to be assigned to provide a second review of the meal counts. Ideally, software would be used to avoid human error in tallying. Action Taken: Since May of 2023, the Bandon School District has used Mealtime to avoid human error in tallying. The Food Services Director reviews these numbers monthly to ensure accuracy.
The College did not report total expenditures on the quarterly reports for the ALN 84.425M (SIP). The College will revise procedures to ensure amounts reported on the reports are accurate.
The College did not report total expenditures on the quarterly reports for the ALN 84.425M (SIP). The College will revise procedures to ensure amounts reported on the reports are accurate.
Finding 2023-001 Recommendation: We recommend that management adheres consistently to its policies around the verification of student information to ensure compliance with verification requirements. We further recommend that management perform a monitoring review for the list of students selected fo...
Finding 2023-001 Recommendation: We recommend that management adheres consistently to its policies around the verification of student information to ensure compliance with verification requirements. We further recommend that management perform a monitoring review for the list of students selected for verification at a level of precision that would identify any errors or instances of noncompliance with federal requirements and that this review be documented View of Responsible Officials and Planned Corrective Actions: For the 2022-23 aid year, the federal verification process was waived except for those selected for federal verification and assigned to the V-4 and V-5 verification groups. A financial aid counselor missed the assignment of a student to the V-5 verification group and inadvertently waived the verification requirements and set the student to “selected not verified”, as if the student was assigned to the V-1 verification group. Following the discovery of this error, a review was conducted with all the financial aid staff to remind them to check within the University’s financial aid system to verify students’ verification group assignments. Since the full verification process was reinstated for the 2023-24 year, a recurrence of this finding is not likely since all students selected will need to be verified moving forward. The University will implement the recommendation to ensure future compliance with verification requirements. Individual Responsible for Corrective Action: Elizabeth Rihl Lewinsky, Assistant Vice President for Financial Aid, 610-660-1346, lewinsky@sju.edu Anticipated Completion Date for Corrective Action: The planned Corrective Actions will be immediately implemented
Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2023, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical ...
Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2023, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical default on the Flexible Subsidy Loan. Management should continue communicating with HUD in order to obtain approval for the deferment request for the Section 201 Flexible Subsidy Loan. Action(s) taken or planned on the finding Management agrees with the recommendation. Management has submitted a request for deferment of the Flexible Subsidy Loan. Management is awaiting HUD approval of the deferment request.
Finding 3414 (2023-002)
Significant Deficiency 2023
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are ...
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act (GLBA) regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College engaged a consulting firm as our Virtual Chief Information Security Officer (vCISO) in 2022-23 to assist in compliance with the GLBA. The College’s work with our vCISO includes a comprehensive risk assessment of the College’s information security posture, a determination of identified risks, access to expert security resources to build an effective and measurable security program, and an evaluation of the controls protecting the external network. These action items began in the 2022-23 fiscal year and are ongoing in the 2023-24 fiscal year. The vCISO program includes virtual multi-year ongoing support. Name(s) of the contact person(s) responsible for corrective action: Harlan Jorgensen, Director of Computing Services Planned completion date for corrective action plan: June 30, 2024
fter discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
fter discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that housing quality unit inspections are performed on an annual basis.
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implement...
After discussion with the auditor, senior management understands the importance of having a properly functioning monitoring system in place to ensure that controls that are properly designed are in fact placed in operation and functioning as intended. The compliance manager responsible for implementing the controls over compliance has been terminated, and senior management will institute monitoring procedures to ensure that controls over compliance are both properly designed and functioning as intended.
Management agrees with the findings presented by the auditors. Management has taken the following actions already to meet this standard. The Organization has taken corrective actions to meet this standard for FY24. These actions include the drafting of a procurement policy that aligns with the requi...
Management agrees with the findings presented by the auditors. Management has taken the following actions already to meet this standard. The Organization has taken corrective actions to meet this standard for FY24. These actions include the drafting of a procurement policy that aligns with the requirements outlined in 2 CFR 200.320 and communicating the policy to its staff for use when planning to allocate procurement costs to federal grants. Management plans to leverage the existing system in place to track and document compliance with the standard procurement procedures as outlined in the policy. Management is committed to conducting periodic internal reviews as part of our compliance checks. We are dedicated to maintaining strong internal controls over compliance, and these measures will help us meet the standards for procurement used in the acquisition of property or services required under Federal awards.
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.
Corrective Action: The Executive Director of Finance and Coordinator of Testing and Accountability & State/Federal Programs will do additional training on Title I plans and how to claim money.  We will monitor the claims quarterly to track spending for each quarter to make sure we are meeting the pe...
Corrective Action: The Executive Director of Finance and Coordinator of Testing and Accountability & State/Federal Programs will do additional training on Title I plans and how to claim money.  We will monitor the claims quarterly to track spending for each quarter to make sure we are meeting the percentages that are required by the state department. The Coordinator of Testing and Accountability & State/Federals will meet monthly with the Grants Accountant to monitor Title I.
As a result of the deficiency noted, the Business Services and Procurement Departments have revoked all purchasing privileges from the Magnet Program Office for a period of 90 days. All purchases, including school level purchases, must be approved by Business Services or Procurement directly. During...
As a result of the deficiency noted, the Business Services and Procurement Departments have revoked all purchasing privileges from the Magnet Program Office for a period of 90 days. All purchases, including school level purchases, must be approved by Business Services or Procurement directly. During this time, the MSAP program office personnel will undergo specific training related to federal compliance including procurement, suspension and debarment. Following this 90-Day period, the District will implement additional monitoring procedures to ensure transactions that do not qualify as “small-purchases” be performed by the District Procurement Department.
The District will implement additional internal control procedures to require the MSAP Director complete a request for reimbursement based off general ledger expenditures similar to other federal programs at the District. In addition, the District will implement additional monitoring procedures to e...
The District will implement additional internal control procedures to require the MSAP Director complete a request for reimbursement based off general ledger expenditures similar to other federal programs at the District. In addition, the District will implement additional monitoring procedures to ensure requests for reimbursement are received and reflect general ledger transactions prior to performing any drawdown of federal funds.
ALN 14.850 – Public & Indian Housing – Operating Subsidy and Utilities Expense Level Calculation Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Implement procedures to monitor compliance with HUD regulator...
ALN 14.850 – Public & Indian Housing – Operating Subsidy and Utilities Expense Level Calculation Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Implement procedures to monitor compliance with HUD regulatory requirements related to the Authority’s calculation of operating subsidy and utilities expense level. Management will implement some form of supervisory review process to ensure that operating subsidy and utilities expense level calculations are complete and accurate. Person Responsible for Correction of Finding: Mr. Kevin Jones, Executive Director Projected Completion Date: March 31, 2024
Lincoln Land Community College (LLCC) acknowledges and takes seriously the audit findings presented, highlighting areas where compliance requirements were not met. These findings are crucial in ensuring the ongoing enhancement of our Information Security Program. To address these concerns LLCC has ...
Lincoln Land Community College (LLCC) acknowledges and takes seriously the audit findings presented, highlighting areas where compliance requirements were not met. These findings are crucial in ensuring the ongoing enhancement of our Information Security Program. To address these concerns LLCC has proactively taken several measures. In June 2022, the College appointed an IT Security and Assurance Manager, tasked with overseeing the Information Security Program and ensuring compliance with the Gramm-Leach-Bliley Act (GLBA). The Manager has played a pivotal role in developing a comprehensive roadmap to guide the continued evolution of our Information Security Program. This roadmap specifically outlines the steps required to address the identified deficiencies, as detailed in the schedule of findings document received from the CLA. LLCC affirms its agreement with the details provided in the document and has prioritized these findings as top-level concerns in the roadmap. In the upcoming Fiscal Year 2024 (FY24), LLCC commits to diligently implementing the roadmap, with a focused emphasis on the following key areas: 1. Implementation and Periodic Review of Access Controls: The IT Security and Assurance Manager will lead efforts to establish robust access controls and ensure regular reviews to align with compliance requirements. 2. Encryption of Customer Information: Although informal procedures are in place, a comprehensive strategy for encrypting customer information both within the College’s system and during transit will be implemented to safeguard sensitive data. 3. Security Assessment of Applications: Rigorous evaluations, assessments, and testing procedures for applications transmitting sensitive information will be instituted to bolster the overall security posture. 4. Anticipation and Evaluation of System Changes: Proactive measures will be taken to anticipate and evaluate changes to the information system or network, ensuring a proactive stance against potential vulnerabilities, including the development of a formalized change management process. 5. Regular Testing and Monitoring: LLCC is committed to instituting regular testing, monitoring, and assessing protocols for established safeguards to ensure their ongoing effectiveness. 6. Implementation of Policies and Procedures: Policies and procedures will be refined and enforced to guarantee that personnel can effectively enact the information security program. 7. Monitoring Information System Service Providers: Development of a comprehensive approach to monitoring the College’s information system service providers has been initiated and will be established to ensure compliance with security standards. Lincoln Land Community College views this as an opportunity for continuous improvement and remains dedicated to upholding the highest standards of information security. The commitment to addressing these findings is integral to our ongoing efforts to safeguard sensitive information and maintain compliance with regulatory requirements.
This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Ma...
This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Manager. The plan for monitoring adherence is the business manager will double check reports before submitting them to the State of Michigan.
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