Corrective Action Plans

Finding 411732 (2022-009)

Material Weakness 2022

Ohio Institute of Allied Health, Inc.

IL

Subrecipient Monitoring

Finding 2022-09 Heightened Cash Monitoring - see corrective action plan submitted with the audit report.

View Audit 312103

Finding 411335 (2022-002)

None 2022

Humboldt County School District

NV

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.308 § 200.309

AUDIT FINDING REFERENCE: 2022-002FINDING SUMMARY:The District?s expenditures charged to grant award number 21-340-07000 occurred prior to the date of the sub-grantaward provided by the State of Nevada Department of Education.RESPONSIBLE PERSON:Dr. David Jensen, SuperintendentPLANNED CORRECTIVE ACTIO...

AUDIT FINDING REFERENCE: 2022-002FINDING SUMMARY:The District?s expenditures charged to grant award number 21-340-07000 occurred prior to the date of the sub-grantaward provided by the State of Nevada Department of Education.RESPONSIBLE PERSON:Dr. David Jensen, SuperintendentPLANNED CORRECTIVE ACTION:This finding was in relation to a pass-through grant of Supplemental Corona Virus Relief Funding provided to theDistrict in lieu of an error found in the PCFP funding formula for the bi-ennium. While the District?s expenditures forthe program are consistent with the March 1, 2020 through December 31, 2021 Period of Performance for thisfederal funding, the Period of Performance on the sub-grant Award was listed as December 10 through December 31,2021. Prior to acceptance, the District informed the pass-through entity that the funds would be used to reimbursecosts incurred during July through October, 2021, and the pass-through entity personnel verbally assured Districtmanagement that this would be acceptable. However, the pass-through entity did not amend the sub-grant awardperiod of performance, resulting in non-compliance with the sub-grant award.Humboldt County School District agrees with the audit finding that this was an isolated instance resulting from aunique situation that arose and was out of the District?s control, and is not the result of a systematic problem.However, the District will follow the recommendation and make every effort to obtain written documentation of anypromised revisions to sub-grant awards prior to expending funds from the pass-through entity in the future.ANTICIPATED COMPLETION DATE:January 31, 2023

View Audit 312061

Finding 411168 (2022-001)

Significant Deficiency 2022

Northwest Michigan Health Services, Inc.

MI

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Federal Audit ClearinghouseNorthwest Michigan Health Services respectfully submits the following corrective action plan for the year ended March 31, 2022.Name and address of independent public accounting firm:Quast, Janke & Company1010 N Johnson StBay City, MI 48708Audit Period: March 31, 2022Conta...

Federal Audit ClearinghouseNorthwest Michigan Health Services respectfully submits the following corrective action plan for the year ended March 31, 2022.Name and address of independent public accounting firm:Quast, Janke & Company1010 N Johnson StBay City, MI 48708Audit Period: March 31, 2022Contact person responsible for Corrective ActionHeidi Britton, Chief Executive OfficerThe findings from the March 31, 2022 schedule of findings and questions costs are detailed in the schedule above. The findings are numbered consistently with the numbers assigned in the schedule.FINANCIAL STATEMENT AUDIT FINDINGSNone.MAJOR FEDERAL AWARDS FINDINGS2022-001 Federal Program - Federal Program CFDA # 93.224 and 93.527 Health Center ClusterRecommendation ? Auditors recommend additional training for staff on sliding fee policies and procedures and management to monitor and verify that processes are being performed as prescribed.Action Taken ? We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Additional staff training on slide fee discounts is in place and monthly review and testing of compliance with Center sliding fee discount policy will be done.

View Audit 312031

Finding 411153 (2022-001)

Material Weakness 2022

Nemo Workforce Development Board

MO

Subrecipient Monitoring § 200.331

2022-001 Subrecipient MonitoringRecommendation: We recommend the Organization review policies and procedures for subrecipient monitoring. Further, the Organization should ensure that all documentation and support for the monitoring of activities for subawards in regards to authorized purpose, terms ...

2022-001 Subrecipient MonitoringRecommendation: We recommend the Organization review policies and procedures for subrecipient monitoring. Further, the Organization should ensure that all documentation and support for the monitoring of activities for subawards in regards to authorized purpose, terms and conditions, and performance goals are properly maintained.Corrective Action Taken: As of July 1, 2022, North Central Missouri College was selected as the Grant Recipient/Fiscal Agent for the Northeast Workforce Development Board?s grant funds. Procedures to manage, track, and account for all subrecipient grant awards are in place and will be followed.Anticipated Completion Date: July 1, 2022.

View Audit 312030

Finding 410371 (2022-003)

Significant Deficiency 2022

Alamo Area Resource Center, Inc.

TX

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Finding 2022-003EligibilityManagement Response: Management agrees with auditor recommendations and a plan is in place to increase the effectiveness of reviews to ensure the completeness of client certification requirements.Action Plan: 1) Identify the departments that had eligibility errors. 2) Prov...

Finding 2022-003EligibilityManagement Response: Management agrees with auditor recommendations and a plan is in place to increase the effectiveness of reviews to ensure the completeness of client certification requirements.Action Plan: 1) Identify the departments that had eligibility errors. 2) Provide comprehensive training to ensure a clear understanding of Ryan White eligibility requirements among departments.Enacted: June 2023Responsible Person: Director of Case ManagementFinalized: July 2023Action Plan: 3) The programs use a new platform, e2SanAntonio, that has a built-in feature that flags clients that are out of compliance. Will perform monthly audits of Ryan White eligibility using the new eligibility platform reporting.Enacted: April 2023Responsible Person: Director of Case ManagementFinalized: June 2023

View Audit 311961

Finding 409887 (2022-003)

Significant Deficiency 2022

University of Delaware

DE

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective Action PlanYear Ended June 30, 2022Finding 2022-003: Procurement: Suspended and DebarredCondition Found:In the auditor?s testing over suspension and debarment, they identified nine covered transactions in a sample of 40 procurement transactions for which the University was unable to prov...

Corrective Action PlanYear Ended June 30, 2022Finding 2022-003: Procurement: Suspended and DebarredCondition Found:In the auditor?s testing over suspension and debarment, they identified nine covered transactions in a sample of 40 procurement transactions for which the University was unable to provide supporting documentation that we verified the vendor was not suspended or debarred prior to entering into the procurement transaction with the vendor. It was determined that the related vendors were not suspended or debarred.Recommendation:The auditors recommend the University enhance its internal control over compliance with the federal regulations related to suspension and debarment to ensure covered transactions are not entered into with parties that have been suspended or debarred.University of Delaware Corrective Action Plan:The University agrees with the finding. The University will ensure suspension and debarment language is included within the contracts of all new covered transactions effective July 1, 2023 and thereafter.Additionally, the University will investigate utilizing third-party verification software to screen existing and potential vendors against the System for Award Management (SAM.gov) Exclusions list daily with expected execution by July 1, 2024.Anticipated Completion Date:Suspension and Debarment: Contract Clause ? July 1, 2023Suspension and Debarment: SAM.gov Verification ? July 1, 2024Contact Persons:Jeff Friedland, Associate Vice President for ResearchDavid Fenkel, Associate Vice President & Chief Procurement Officer

View Audit 311956

Finding 409836 (2022-001)

Significant Deficiency 2022

Lawton Community Schools

MI

Cash Management School Nutrition Programs Subrecipient Monitoring

Lawton Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022.Auditor: Seber Tans, PLC555 W. Crosstown Pkwy, STE 304Kalamazoo, MI 49008Audit Period: Year ended June 30, 2022District Contact Person: Dianne Webster, Business Office ManagerThe findi...

Lawton Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022.Auditor: Seber Tans, PLC555 W. Crosstown Pkwy, STE 304Kalamazoo, MI 49008Audit Period: Year ended June 30, 2022District Contact Person: Dianne Webster, Business Office ManagerThe findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule.Finding ? Federal Award Findings and Questioned CostsFinding 2022-01 ? Significant DeficiencyRecommendation: The District should implement a budget, as well as the required corrective action plan for the 2022-2023 school year that will adequately reduce the food service fund balance.Action to be Taken: Management concurs with the facts of this finding and we are in the process of developing and implementing a plan to spend down the food service fund balance.

View Audit 311946

Finding 409733 (2022-001)

Significant Deficiency 2022

The Healthcare Connection INC

OH

Subrecipient Monitoring HUD Housing Programs

The Healthcare Connection, Inc CORRECTIVE ACTION PLANFor the Year Ended December 31, 2022Finding 2022-001Federal program and specific federal awardU.S. Department of Health and Human Services (HHS)93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Car...

The Healthcare Connection, Inc CORRECTIVE ACTION PLANFor the Year Ended December 31, 2022Finding 2022-001Federal program and specific federal awardU.S. Department of Health and Human Services (HHS)93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program)Specific requirementHealth centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay.ConditionDuring a sample of 25 patient visit encounters, we noted that 1 patient visit from March 2022 did not have the applicable sliding fee application on file and the patient charge was adjusted down to zero.CauseThis was due to an error made by manual entry to adjust the sliding fee without sufficient support on file of the patient?s sliding fee application.Effect or potential effectA patient received a sliding fee to write off the entire charge of $210 that was not supported by a sliding fee application. Subsequent to the discovery of the error during the audit, in April 2023, the Organization was able to obtain an application from the patient to support a sliding fee to a charge of $70.Questioned costsNoneRepeat findingNoRecommendationWe recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is obtained before applying a sliding fee discount to a patient account. In addition, we suggest that management establish a policy to perform regular monitoring of a sample of patient file sliding fee applications, to ensure the sliding fee is applied correctly.Corrective ActionWe agreed with the above comment and will implement a system of monitoring sliding fee applications and continue to educate the front desk and intake staff to ensure all documentation is obtained.

View Audit 311938

Finding 406049 (2022-001)

Significant Deficiency 2022

Eastwest Food Rescue

WA

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

EastWest Food Rescue has since implemented a formal expense approval process that requires electronic signatures from authorized individuals before payments will be processed.

View Audit 311592

Finding 404506 (2022-005)

Material Weakness 2022

The Salvation Army Northwest Division

WA

Subrecipient Monitoring Eligibility Material Weakness

The Division will contact each unit distributing TEFAP assistance and communicate the requirement to retain documentation regarding the determination of client eligibility. Anticipated Completion Date: June 2024. Responsible Contact Person: Julie Luft, Northwest Division Social Services Director

View Audit 311047

Finding 403960 (2022-005)

Significant Deficiency 2022

City of Danbury

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding 2022-005 – Significant Deficiency, Procurement and Suspension, and Debarment - Internal Control over Verification Against the System for Award Management (“SAM”) Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for te...

Finding 2022-005 – Significant Deficiency, Procurement and Suspension, and Debarment - Internal Control over Verification Against the System for Award Management (“SAM”) Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City enters into contracts with for federally funded projects, it does not maintain formal documentation that this procedure occurred. Response: We agree with the finding. We are adding this step to our checklist and have assigned the task to our Grants Compliance Coordinator.

View Audit 310810

Finding 403959 (2022-004)

Significant Deficiency 2022

City of Danbury

CT

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2022-004: Significant Deficiency and Noncompliance Finding, Reporting- Special Reporting Assistance Listing Program Title and Number: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Pass-through Entity: N/A Award year: 2022 Criteria or specific requir...

Finding 2022-004: Significant Deficiency and Noncompliance Finding, Reporting- Special Reporting Assistance Listing Program Title and Number: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Pass-through Entity: N/A Award year: 2022 Criteria or specific requirement: Cities were required to submit a one-time interim report with expenditures by Expenditure Category covering the period from March 3 to July 31, 2021, by August 31, 2021. The initial quarterly Project and Expenditure Report covered three calendar quarters from March 3, 2021 to December 31, 2021, and was required to be submitted to Treasury by January 31, 2022. The subsequent quarterly reports will cover one calendar quarter and must be submitted to Treasury by the last day of the month following the end of the period covered. Condition: The interim report and 2 Project and Expenditure Reports were not submitted as required. Cause: Grant management and reporting is not fully centralized within the City and there was turnover in the grant administrator position. The City did not have sufficient internal controls in place to ensure the reports were filed. Effect: The progress reports should be submitted by the deadline. This results in non-compliance with the Reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Prevalence: There was 1 interim report and 3 project and expenditure reports required to be submitted during the audit period. Only one project and expenditure reports was submitted. Questioned Cost: None Repeating Finding: No. Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding.

View Audit 310810

Finding 403907 (2022-007)

Material Weakness 2022

Aerospace MacHinists Joint Training Committee

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.302

Corrective Action Plan: After monthly reconciliations, financial statements will be delivered to AJAC Directors monthly. AJAC Accounting Department will hold monthly close calls to collaborate with AJAC Directors to ensure accuracy of financials. Anticipated Completion Date: Completed

View Audit 310790

Finding 403902 (2022-002)

Material Weakness 2022

Aerospace MacHinists Joint Training Committee

WA

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

Corrective Action Plan: The deficiencies related to internal control policies and procedures were initially identified in a Federal Desk Monitoring Review conducted in November 2022. Internal control policies and procedures were updated in response to these findings and approved by DOL on October 26...

Corrective Action Plan: The deficiencies related to internal control policies and procedures were initially identified in a Federal Desk Monitoring Review conducted in November 2022. Internal control policies and procedures were updated in response to these findings and approved by DOL on October 26, 2023. All financial reporting policies and procedures will be reviewed and updated on an annual basis by AJAC Directors and Supervisors. Anticipated Completion Date: Completed

View Audit 310790

Finding 403891 (2022-003)

Material Weakness 2022

Lauderdale County, Mississippi

MS

Subrecipient Monitoring § 200.332

This payment was a one-time payment for a single project completed by the City of Meridian. Moving forward, Lauderdale County will document the completion of the project.

View Audit 310764

Finding 403889 (2022-003)

Significant Deficiency 2022

West Alabama Aids Outreach, Inc.

AL

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Since completion of the fiscal year ended 9/30/2022, the Organization has added a Director of Grants Management, two grant billers and a purchasing manager to help ensure policies and procedures are being followed. In response to this finding, the CFO and Director of Grants Management have institute...

Since completion of the fiscal year ended 9/30/2022, the Organization has added a Director of Grants Management, two grant billers and a purchasing manager to help ensure policies and procedures are being followed. In response to this finding, the CFO and Director of Grants Management have instituted multiple internal processes to confirm administrative fees do not exceed 10% of grant award. The grant biller will prepare a monthly reimbursement schedule in Excel which shows the budgeted amount for each category. The Director of Grants Management reviews and approves this schedule to ensure it meets the grant requirements. Each individual monthly reimbursement form is approved and signed by the Director of Grants Management to confirm accuracy. Then the reimbursement form submitted is entered in a master spreadsheet "Projects by Line Item" which shows original budget, monthly amounts billed for each budget line item, and remaining balance for each item. This is reviewed each month to ensure no amounts, including the administrative costs exceed approved amounts. Anticipated Completion Date: 9/30/2023 Responsible Contact Person: Chris White, CFO

View Audit 310763 Questioned Costs: $1

Finding 403888 (2022-002)

Significant Deficiency 2022

West Alabama Aids Outreach, Inc.

AL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

The CFO has instituted multiple approvals for each reimbursement or purchase request. Since completion of the fiscal year ended 9/30/2022, the Organization has added a Director of Grants Management, two grant billers, and a purchasing manager to help ensure policies and procedures are being followe...

The CFO has instituted multiple approvals for each reimbursement or purchase request. Since completion of the fiscal year ended 9/30/2022, the Organization has added a Director of Grants Management, two grant billers, and a purchasing manager to help ensure policies and procedures are being followed. For reimbursements, employees will complete an Employee Reimbursement Form which is signed by the employee and employee's direct supervisor. For purchase requests, employees will complete a Purchase Order form which is signed by the employee and the employee's supervisor. The signed form is sent to the finance department where it is entered in Bill.com for payment by accounts payable personnel. The Director of Finance approves the reimbursement or purchase on Bill.com, then the CFO approves and releases for payment. The approved Reimbursement Form or Purchase Order is sent to the Director of Grants Management, and if eligible, attached to the monthly billing to grantor for reimbursement. Anticipated Completion Date: 9/30/2023 Responsible Contact Person: Chris White, CFO

View Audit 310763

Finding 403122 (2022-001)

Significant Deficiency 2022

Sacramento Lgbt Community Center

CA

Reporting Subrecipient Monitoring Significant Deficiency

Finding Reference Number: 2022-001 Description of Finding: The Organization submitted its Audited Financial Statements and Single Audit Report to the federal clearinghouse in May 2024, eight months after it was due. Statement of Concurrence or Nonconcurrence: The Organization concurs with this findi...

Finding Reference Number: 2022-001 Description of Finding: The Organization submitted its Audited Financial Statements and Single Audit Report to the federal clearinghouse in May 2024, eight months after it was due. Statement of Concurrence or Nonconcurrence: The Organization concurs with this finding. The delinquency was caused by staff turnover in key positions responsible for the preparation of the Audited Statements and Schedule of Expenditures of Federal Awards. Corrective Action: The Organization has since hired a Chief Operating Officer (COO) who has direct responsibility for the audit process. In addition, the Center created the position of Senior Accountant who will support the COO to ensure the timeliness of the accounting close and submission of the audit. Name of Contact Person: David Heitstuman, Executive Director. Phone 916 442-0185. Email: david.heitstuman@saccenter.org Projected Completion Date: August 2024

View Audit 310239

Finding 403120 (2022-011)

Material Weakness 2022

State of California

CA

Subrecipient Monitoring § 200.303 § 200.332 § 200.501 § 200.513 § 200.521

Public Health’s Center for Preparedness and Response (CPR) agrees that it did not establish a formal risk assessment process over its subrecipients of ELC COVID-19 awards. CPR will establish and document formal procedures for conducting risk assessments of ELC subrecipients. Public Health will also...

Public Health’s Center for Preparedness and Response (CPR) agrees that it did not establish a formal risk assessment process over its subrecipients of ELC COVID-19 awards. CPR will establish and document formal procedures for conducting risk assessments of ELC subrecipients. Public Health will also develop and implement specific subrecipient monitoring procedures. CPR also agrees that it did not obtain single audit reports from ELC subrecipients. CPR will develop and implement procedures outlining the process for obtaining single audit reports from subrecipients, which will include a monitoring mechanism to track compliance with the single audit mandate. Estimated Implementation Date: December 2024 Contact: Melissa Relles, Assistant Deputy Director Division of Operations Center for Preparedness and Response California Department of Public Health

View Audit 310237

Finding 403116 (2022-008)

Material Weakness 2022

State of California

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

The Local Governmental Financing Division, in collaboration with the Audits and Investigations Division, agrees that policies and procedures will be developed to take additional action for significantly late-cost reports and non-compliant counties. As of July 1, 2023, the California Department of He...

The Local Governmental Financing Division, in collaboration with the Audits and Investigations Division, agrees that policies and procedures will be developed to take additional action for significantly late-cost reports and non-compliant counties. As of July 1, 2023, the California Department of Health Care Services transitioned counties away from cost reconciliation financing, and for any state fiscal year after July 1, 2023, counties will no longer be required to submit cost reports. Estimated Implementation Date: July 2023 Contact: Wendy Griffe, Chief Internal Audits California Department of Health Care Services

View Audit 310237

Finding 403094 (2022-003)

None 2022

The Pre-School Inc.

AR

Subrecipient Monitoring Internal Control / Segregation of Duties

If the Organization is subject to a Single Audit in the future, additional procedures will be implemented to track and monitor disbursements and allowable costs. Management does not anticipate having a Single Audit in the future.

View Audit 310234

Finding 402404 (2022-002)

Significant Deficiency 2022

City of Bremerton

WA

Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2022-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements. Name, address, and telephone of City contact person: Mike Riley, Director of Financial Services 345 6th Street, Suite 100 Bremer...

Finding ref number: 2022-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements. Name, address, and telephone of City contact person: Mike Riley, Director of Financial Services 345 6th Street, Suite 100 Bremerton, WA 98337 (360) 473-5303 Corrective action the auditee plans to take in response to the finding: The City will ensure every subaward agreement clearly identifies that it is a federal award and includes the applicable federal requirements for programs funded with Coronavirus State and Local Fiscal Recovery Funds and other federal funding. Anticipated date to complete the corrective action: Immediately

View Audit 309938

Finding 401927 (2022-004)

Significant Deficiency 2022

The Wayside House, Inc. and Subsidiary

MN

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

The Organization will implement control procedures that maintain proper segregation of duties. Federal program reporting shall be prepared by the Staff Accountant or program manager and will require the formal approval from an individual in leadership (COO, Controller) prior to being recorded. The p...

The Organization will implement control procedures that maintain proper segregation of duties. Federal program reporting shall be prepared by the Staff Accountant or program manager and will require the formal approval from an individual in leadership (COO, Controller) prior to being recorded. The prepared file and documentation of the review and approval will be retained in a share drive for future access. Name(s) of Contact Person(s) Responsible for Corrective Action: Nhia Xiong, Staff Accountant, Andrea Vasquez, Chief Operating Officer, Alex Sukalski, New Controller, start date June 3, 2024. Anticipated Completion Date: May 2023

View Audit 309846

Finding 401926 (2022-003)

Significant Deficiency 2022

The Wayside House, Inc. and Subsidiary

MN

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Organization will implement control procedures that maintain proper segregation of duties. Expenditure amounts that are to be applied to federal awards shall be prepared the Staff Accountant and will require the formal approval from an individual in leadership (COO, Controller) prior to being re...

The Organization will implement control procedures that maintain proper segregation of duties. Expenditure amounts that are to be applied to federal awards shall be prepared the Staff Accountant and will require the formal approval from an individual in leadership (COO, Controller) prior to being recorded. The prepared file and documentation of the review and approval will be retained in a share drive for future access.

View Audit 309846

Finding 401563 (2022-009)

Material Weakness 2022

Martin University

IN

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

2022-009 Special Tests and Provisions – The Gramm-Leach-Bliley Act (GLBA) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leac...

2022-009 Special Tests and Provisions – The Gramm-Leach-Bliley Act (GLBA) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University began engagement with AIS, an IT Managed Service Provider in May 2022 and hired a Director of IT in November 2023. The University is working with AIS and Cowbell to develop and implement a Cybersecurity policy, as well as to provide training for all employees, the Board of Governors, and students. The University has also deployed Cloud Storage backup solutions for all data. Name(s) of the contact person(s) responsible for corrective action: Scharvin Wilson, Director of IT, AIS, IT Managed Services Provider, E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Planned completion date for corrective action plan: June 30, 2024

View Audit 309593

Corrective Action Plans

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