Corrective Action Plans

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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.
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.
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.
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.
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.
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
Finding 367181 (2023-001)
Significant Deficiency 2023
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.
Views of Responsible Officials: We agree with the finding.
Views of Responsible Officials: We agree with the finding.
Federal Award Findigs and Questioned Costs - Finding 2023-002 The School District must verify eligibility of children in a sample of househould applications approved for free and reduced prices meal benefits for that school year. Verification was not performed for one of the School District's sub re...
Federal Award Findigs and Questioned Costs - Finding 2023-002 The School District must verify eligibility of children in a sample of househould applications approved for free and reduced prices meal benefits for that school year. Verification was not performed for one of the School District's sub recipients. Adequate oversight of the verification process was not in place in order to ensure verification process occurred related to one of the School District's sub recipients. Corrective Action: The software that the District uses for the school lunch program randomly chooses applications in which to verify each year. Prior to the 2023-24 shcool year, the District's sub recipient, Holy Family, was not included in the District's school lunch software and was manually tracked. Beginning 9/6/23, Holy Family is now included in the District's Software and will be part of the random selection process that will be competed by 11/5/23 and each year's due date thereafter.
Finding Number: 2023-001 Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the free, reduced and total number of meals. Therefore, if the number of free or reduced meals is typed incorrectly, the difference automatically adds...
Finding Number: 2023-001 Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the free, reduced and total number of meals. Therefore, if the number of free or reduced meals is typed incorrectly, the difference automatically adds or subtracts to the number of fullpaid meals. While there is review and approval of amounts prior to entering meal counts into the MiND system, the district did not consider that once free and reduced meals are entered into the system, the number of full pay meals auto fills to the number required to match/balance the total meals served. This resulted in the District not identifying that two claims requests undercounted reimbursable meals which shorted the District receiving additional funding of $7,639. Planned Corrective Action: After an in-depth review of the circumstances that led to the incorrect (under count) request for meal reimbursement error, an additional review and approval procedure has been implemented. This will ensure the final meal claims data, including the MiND system auto calculated data reflects the district’s internal meal count data reporting. Contact person responsible for corrective action: John Fitzgerald, Assistant Superintendent for Business & Finance Completion Date: July 31, 2023
Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform r...
Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform required tests, such as penetration tests and vulnerability assessments to test the safeguards that are in place. CCSJ has named a qualified individual, Tony Kwintera - Director of IT Operations, to oversee the information security program. We are also reaching out to our 3rd party partners to ensure that their data privacy safeguards align with the requirements of the GLBA. Responsible officers: Tony Kwintera, Director of IT Operations (tkwintera@ccsj.edu); Lynn Miskus, Vice President of Business and Finance Estimated completion date: June 15, 2024
Finding Number 2023-003 • Significant deficiency in internal controls over compliance related to procurement. Federal Agency: U.S. Department of Commerce Program Title: Pacific Fisheries Data Program Assistance Listing Number: 11.437 Award Nu...
Finding Number 2023-003 • Significant deficiency in internal controls over compliance related to procurement. Federal Agency: U.S. Department of Commerce Program Title: Pacific Fisheries Data Program Assistance Listing Number: 11.437 Award Numbers: NOAA-NMFS-AK-2023-2007663 Award Period: October 1, 2022 to September 30, 2027 Criteria • 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Procurement Standards require that awardees use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. Condition/Context for Evaluation • IPHC's internal controls over procurement do not include the controls and procedures required by 2 CFR 200. Questioned Costs • Not applicable. Cause • IPHC has not yet modified its procurement policies with the requirements of the 2 CFR Part 200 Procurement Standards. Effect or Potential Effect • As a result, IPHC cannot be certain that procurements were conducted in accordance with the 2 CFR Part 200 Procurement Standards. Repeat Finding • Not applicable. Recommendation • We recommend that IPHC update its procurement policy to include all procurement requirements of 2 CFR Part 200. - Procurement standards 2 CFR 200 Subpart D or 200.318-200.327 - Requirement for documented policies consistent with standards 200.318(a) Contact Person(s): • Executive Director: David Wilson (david.wilson@iphc.int); • Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: As this was the IPHC’s first full GAAP Audit, Single Audit of federal grant funds, and also our first year transitioned from a Cash-basis of accounting to an Accrual-basis of accounting, there are a number of policies and procedures that are in the process of being amended. It will take the Secretariat several months to bring our written process guides into alignment with “2 U.S. Code of Federal Regulations (CFR) Part 200”, as well as our Financial Regulations (2021) that will be considered for amendment at the upcoming 100th Session of the IPHC Finance and Administration Committee (FAC100) and subsequent 100th Session of the IPHC Annual Meeting (AM100) in late January 2024. During the 2nd quarter of FY2024 (1 January – 31 March 2024) the IPHC will undertake a thorough review of “2 U.S. Code of Federal Regulations (CFR) PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS” and update our procurement policies and processes accordingly. Anticipated completion date: Deadline: 1 April 2024.
View Audit 289963 Questioned Costs: $1
Training was provided to staff reviewing applications. District has since joined the CEP and is streamlining the internal processes for identifying eligibility as low income.
Training was provided to staff reviewing applications. District has since joined the CEP and is streamlining the internal processes for identifying eligibility as low income.
View Audit 289879 Questioned Costs: $1
2023-004 ESSER - Segregation of Duties – Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants. Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/T...
2023-004 ESSER - Segregation of Duties – Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants. Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/Taken in Response to Finding: Lauren Lucius will prepare the ESSER claim and either Tonya Gebert or Rodney Huther will approve the claim before it is submitted. Name of the Contact Person Responsible for Corrective Action: Lauren Lucius Planned Completion Date for Corrective Action Plan: December 15, 2023
A. Formally Establish and Document Risk Acceptance Process Requirements for risk assessments and risk acceptance processes to comply with GLBA were expanded in June of 2023. The District engaged a third-party consultant to conduct a GLBA-compliant risk assessment and advise on recommended changes t...
A. Formally Establish and Document Risk Acceptance Process Requirements for risk assessments and risk acceptance processes to comply with GLBA were expanded in June of 2023. The District engaged a third-party consultant to conduct a GLBA-compliant risk assessment and advise on recommended changes to the District’s Written Information Security Plan (WISP) to comply with the new requirements. The findings and recommendations were presented to the District in October of 2023 and are currently under review. The District will initiate a project to formalize risk acceptance by December 31st, 2023, and implement the risk acceptance process by June 30, 2024. B. Perform Regular Backup Restoration Tests The District has engaged with a third party to build a testing environment to physically test restoration of the SIS environment. Initiation of the project is pending processing of the Purchase Order. The District anticipates completion of the restoration by December 31st, 2023. With respect to SAP, the District is currently engaged in an effort to migrate the SAP database to HANA. When this project is complete, the same test environment will be capable of performing physical recovery tests for SAP. The HANA migration is estimated to be completed on February 28th, 2024. C. Perform Timely Access Revocation and Regular Access Reviews With respect to the District’s Single Sign-On (ADFS or SSO) environments, the District engaged professional services consultants to address this item by automating the disablement of employee accounts based upon the termination of assignment. The work is currently underway. The target completion of the process is December 15, 2023. With respect to the SAP environment, the District has engaged with a vendor to implement Multifactor Authentication (MFA) in the SAP environment. Work will begin upon processing the Purchase Order. Once both efforts are complete, disabling employee accounts in SSO, SIS and SAP will be performed automatically based upon the termination of assignments according to criteria established by Human Resources. With respect to access reviews of SIS and SAP, the District is currently researching the export of user audit logs to the District’s analysis environment to enable regular reviews. The new target to perform regular access reviews for SAP and SIS is the end of Q1 2024. With respect to physical access reviews, the District Information Security Team will perform an annual review of relevant operational protocols for data center access with the appropriate internal teams and perform an audit of data access at a minimum of once per year. The first annual protocol review will be completed by December 1st, 2023. The first annual audit will commence no later than March 1st, 2024. D. Perform Necessary Due Diligence to Regularly Evaluate All Third-party Safeguards To prevent recurrence, the LACCD Information Security Team will coordinate an annual review of Administrative Protocol 3723A: Information Security Evaluation of Third-Party Providers with District Financial Aid, Procurement and Educational Programming and Institutional Effectiveness (EPIE) leadership teams to help assure future relevant contracts are provided to the Information Security Team prior to renewal to allow for timely security review. E. Maintain and Review Logs of Users’ Activity for both SAP and PS SIS The District is currently researching the export of user audit logs to the District’s analysis environment to enable regular reviews. The new target to perform regular access reviews for SAP and SIS is the end of Q1 2024. F. Implement data encryption for Devices Storing Customer Data The District engaged a third-party consultant to perform a comprehensive review of PeopleSoft security controls, including the implementation of encryption of financial aid data within PeopleSoft. The results are pending. Based upon those recommendations, the District will work with encryption providers to develop and implement field-level encryption of financial aid data in SIS as appropriate. With respect to end-user devices storing sensitive data, the District recently adopted workstation hardening requirements that include whole-disk encryption for desktop and laptop computers used by personnel who routinely access sensitive information, including financial aid data. The District will implement the standards on workstations used by employees in financial aid and institutional research by June 30, 2024. Once this is complete, additional workstations will be encrypted in order of potential risk. G. Strictly Implement Processes and Control for Direct Changes in the SAP Production Environment The requests for direct changes in SAP production will be tracked and included in our help desk requests so that an auditable trail can be created leading to the purpose and completion of the production changes. Additionally, direct production change requests will be reviewed and approved following the LACCD Change Control process. Minor updates that do not fall within the change control guidelines will require managerial approval within the help desk system. Personnel Responsible for Implementation: Carmen V. Lidz Position of Responsible Personnel: Vice Chancellor & Chief Information Officer
A. Incorrect Calculation of Return to Title IV Funds East Los Angeles College The corrective action plan that will be put in place is to develop a chart with a predetermined number of days based on the enrollment period. This will avoid the manual counting of the number of days for each student. We...
A. Incorrect Calculation of Return to Title IV Funds East Los Angeles College The corrective action plan that will be put in place is to develop a chart with a predetermined number of days based on the enrollment period. This will avoid the manual counting of the number of days for each student. We also trained an additional staff member to help with the workload. This will ensure that errors will be caught before the completion of the review process. Implementation will begin in Spring 2024. Staff is currently being trained. Personnel Responsible for Implementation: Gavino Herrera Position of Responsible Personnel: Financial Aid Supervisor Expected Date of Implementation: Spring 2024 Los Angeles Southwest College The corrective action that we are implementing to remediate this finding is to move the campus return to Title IV processing to the “R2T4 Unit” at the District Office. Personnel Responsible for Implementation: Muniece R. Bruton Position of Responsible Personnel: Financial Aid Manager Expected Date of Implementation: December 1, 2023 B. Untimely Notification of Grant Overpayment to Students and Secretary East Los Angeles College The Corrective Action plan is being implemented by providing an additional staff member to assist with the return to Title IV process along with helping with the validation to ensure calculation, notification, and reporting to NSLDS will be completed on a timely basis. A reminder is set in the Financial Aid Technician Outlook calendar to help remind them to help meet the deadline of the reporting requirement. Personnel Responsible for Implementation: Gavino Herrera Position of Responsible Personnel: Financial Aid Supervisor Expected Date of Implementation: Fall 2023 C. Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date In the fall 2022 term, the District implemented training for all Distance Education (DE) faculty members to reduce the risk of data entry errors. DE faculty receive follow-up notifications at the beginning of every term). In addition, the District attempted to conduct random sampling to ensure the accuracy of the data entry. However, the District did not have the authorization or resources to perform sampling during the audit period. As a result, the corrective action plan (CAP) was only partially implemented during fiscal year 2023. In fall 2023, the District secured the human resources and required authorizations to conduct random sampling of the faculty data entry. The District’s Internal Audit Department (IAD) is performing random sampling of all campuses. As of fall 2023, all corrective actions have been fully implemented. Personnel Responsible for Implementation: Steve Giorgi, Betsy Regalado, Keyna Crenshaw Position of Responsible Personnel: Financial Aid Manager, Associate Vice Chancellor of Educational Programs and Institutional Effectiveness, LACCD Supervising Auditor) Expected Date of Implementation: Fall 2023
View Audit 289733 Questioned Costs: $1
Significant Deficiency in Internal Control over Compliance and Other Matters 2023-003 (Previously 2022-002) Subrecipient Monitoring U.S. Department of Health and Human Services Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.870 Recommendation: We recommend the p...
Significant Deficiency in Internal Control over Compliance and Other Matters 2023-003 (Previously 2022-002) Subrecipient Monitoring U.S. Department of Health and Human Services Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.870 Recommendation: We recommend the program create an agreement template that contains the required elements of a subaward to distribute to its subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ECECD takes this matter seriously. ECECD has taken immediate steps to resolve the omission of any required elements in our subrecipient agreements. ECECD wants to emphasize that other aspects of sub-recipient monitoring have been effectively corrected and performed. Additionally, the agreement template will be improved to include all required elements to ensure that they are contained within every subrecipient agreement going forward. To ensure a comprehensive resolution, the Chief Procurement Officer and the Chief Financial Officer (CFO) will develop and implement a subrecipient monitoring training for program staff to address and rectify this issue. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Marlene Acosta, Chief Procurement Officer. Planned completion date for corrective action plan: June 30, 2024
Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) 2023-002 (Previously component of 2022-002) FFATA Reporting U.S. Department of Health and Human Services Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.870 Recommendation: While t...
Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) 2023-002 (Previously component of 2022-002) FFATA Reporting U.S. Department of Health and Human Services Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.870 Recommendation: While the program did perform the annual SF425 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the data collected from the subrecipients into the FSRF portal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ECECD takes this matter seriously and has been committed to addressing and correcting it in FY23. ECECD implemented guidelines in FY23 that are accessible on our intranet that mandates all sub-recipients to complete and submit a FFATA report. Current existing FFATA reports have been submitted to the ASD Grants Management Division for further transmission to the appropriate Federal Reporting Agencies. ECECD is fully committed to ensuring compliance with FFATA reporting requirements for all our contracts. Additionally, to prevent any future lapses in FFATA reporting, the Chief Financial Officer (CFO) will develop a system where any contracts with subrecipients involving thirty thousand ($30,000.00) or more will be flagged for mandatory FFATA reporting. These proactive measures will help us maintain transparency and accuracy in our reporting, and ECECD is dedicated to its successful implementation. ECECD is fully committed to strengthening our processes to ensure full compliance with FFATA reporting requirements moving forward. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Inez Gonzales, Grants Manager; ECECD Program Managers. Planned completion date for corrective action plan: June 30, 2024
Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be reviewed, approved, and maintained by administrative personnel. Anticipated Comple...
Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be reviewed, approved, and maintained by administrative personnel. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year. Contact Person Responsible: Cory Hoffman, Business Manager/Board Secretary
View Audit 289540 Questioned Costs: $1
Corrective Action Planned: The District did review and enforce existing Board Policies and procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods and that they are based upon properly reconciled factual info...
Corrective Action Planned: The District did review and enforce existing Board Policies and procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods and that they are based upon properly reconciled factual information.. Final Expenditure Reports have now been submitted or are pending review or revision (2). All current fiscal year quarterly cash on hand reports have been submitted. Current business manager compiles a quarter-end summary of data to be shared with the federal programs administrator. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year. Contact Person Responsible: Cory Hoffman, Business Manager/Board Secretary
Finding 366617 (2023-002)
Significant Deficiency 2023
Audit Finding 2023-002 Criteria or Specific Requirement: Internal controls that assure all construction contracts entered into with federal awards have prevailing wage requirements. Condition: We selected a construction contract to test for prevailing wage requirements noting that this project ha...
Audit Finding 2023-002 Criteria or Specific Requirement: Internal controls that assure all construction contracts entered into with federal awards have prevailing wage requirements. Condition: We selected a construction contract to test for prevailing wage requirements noting that this project had not met these requirements as prevailing wage verbiage was not included in the contract. Context: Construction contracts not following prevailing wage requirements could have been accepted. Effect or Potential Effect: Prevailing wage requirements could have not been met and would impact the amount of federal funding the District receives or the use of it on projects. Cause: The District did not oversee that prevailing wage requirements were included in contracts. Recommendation: Ensure the prevailing wage requirement are included in all construction contracts paid for with federal funds. Responsible Official's Response: CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding Change orders have been issued for the construction project, and contractors will be paid prevailing wages for the entire project. Internal control measures have been adjusted to identify construction projects funded by federal resources and to guarantee that project specifications include the necessary components for prevailing wages. 3. Official Responsible for Ensuring CAP Bradley Bergstrom is the official responsible for ensuring the corrective action of the deficiency. 4. Planned Completion Date for CAP Completed. 5. Plan to Monitor Completion of CAP The Director of Business Services will be monitoring the CAP.
Finding 366598 (2023-001)
Significant Deficiency 2023
Criteria: The University is required to comply with the Gramm-Leach-Bliley Act (GLBA) section 16 CFR 314.4(b). Condition: A GLBA compliance risk assessment was not performed within the last fiscal year. Various vulnerability assessments have been conducted since 2020, however updated GLBA compliance...
Criteria: The University is required to comply with the Gramm-Leach-Bliley Act (GLBA) section 16 CFR 314.4(b). Condition: A GLBA compliance risk assessment was not performed within the last fiscal year. Various vulnerability assessments have been conducted since 2020, however updated GLBA compliance guidance has more specific requirements for what must be performed as part of an IT risk assessment in order to identify reasonable, foreseeable internal and external risks to the security, confidentiality, and integrity of student information that addresses the following areas: a. Information systems, including network and software design, as well as information processing, storage, transmission and disposal. b. Detecting, preventing and responding to attacks, intrusions, or other systems failures. c. Documented safeguards for each identified risk. d. Appropriate mitigated risk levels for each identified risk. Updated GLBA guidance requires that a Qualified Individual who oversees the Information Security Program makes a written report to the Board of Trustees on the status of the Information Security Program at least annually. The University's Information Security Program and IT policies has four attributes that were not appropriately documented for GLBA compliance: a. Conduct a periodic inventory of data, noting where its collected, stored, or transmitted. b. Encrypt customer information on the University's system and when it's in transit. c. Assess apps developed by the University. d. Implement multi-factor authentication for anyone accessing customer information on the University's system. Cause: The University did not have controls in place to ensure all GLBA requirements were met. Effect: The University is not in compliance with GLBA requirements. Corrective Actions Taken or Planned: Items that have been resolved: a. Customer data, and backups of customer data, is now encrypted at rest and in transit. b. All users with access to customer data are required to use multi-factor authentication.c. The University password policy has been updated to strengthen passwords and increase minimum length to 12 characters with complexity. The University has also implemented a tool to block the reuse of compromised passwords from the HIBP database. Items to be resolved: a. An update on the University’s information security program draft has been shared with the Board of Trustees and a final report will be issued by February 1, 2024. b. The University has begun an inventory of customer data and systems storing customer data. The University does not have any University developed apps that handle or store customer data (this will be documented in the customer data inventory). This inventory will be completed by April 15, 2024. c. The University is evaluating proposals for an assessment to include a risk assessment and internal and external vulnerability scans. The IT risk assessment is planned to be completed by June 1, 2024. d. Updated GLBA policies, including a disaster recovery policy, will be completed by June 1, 2024 Person Responsible for Implementing Correction Action: Ezra Krumhansl, Chief Financial Officer Implementation Date: Through June 1, 2024
Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF funds for minor remodeling, ren...
Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF funds for minor remodeling, renovation, or construction contracts that are over $2,000 and use laborers and mechanics, must meet Davis-Bacon prevailing wage requirements. Noted the School District expended approximately $168,000 in ESSER funds that related to repairs and renovations out of a total of approximately $11,800,000 in ESSER construction funds that did not include the prevailing wage requirement within the contract’s language. This was one contract during changeover of construction administration that missed the bid language, however, was paid at prevailing wages. Planned Corrective Action: As it pertains to the use of federal funds for construction projects in the School District, when said funds will be used to compensate for labor for any construction project: We will stipulate Davis-Bacon requirements for prevailing wages within contracts as it relates to the use of laborers and mechanics, for all projects over $2,000. Contact person responsible for corrective action: Thomas Wall, Executive Director of Business Services and Operations Anticipated Completion Date: July 1, 2023
Subject: Corrective Action Plan for Title IV Federal Financial Aid Audit Finding Responsible Party: Jill Jonhson, Registrar, johnsoj@smcsc.edu 864-587-4232 We appreciate the opportunity to address the finding related to the untimely reporting of withdrawn and graduated students to the National Stude...
Subject: Corrective Action Plan for Title IV Federal Financial Aid Audit Finding Responsible Party: Jill Jonhson, Registrar, johnsoj@smcsc.edu 864-587-4232 We appreciate the opportunity to address the finding related to the untimely reporting of withdrawn and graduated students to the National Student Loan Data System (NSLDS) during the recent Title IV Federal Financial Aid audit. We acknowledge the importance of accurate and timely reporting and have taken immediate corrective actions to rectify the identified issue. 1. Root Cause Analysis: Upon investigation, we identified that the finding was a result of a recent change in the software system used for reporting data to the National Student Clearinghouse (Clearinghouse) which in turn is reported to NSLDS. This change led to a disruption in the timely reporting of students who withdrew or graduated from our institution. 2. Immediate Correction: As soon as the error was identified, our IT team worked promptly to update the system configuration. This correction ensured that all relevant data for withdrawn and graduated students was accurately pulled and submitted to Clearinghouse and NSLDS. 3. Verification and Submission: We have thoroughly reviewed the data to ensure that all students who withdrew or graduated during the audit period have been correctly reported to Clearinghouse. Subsequently, accurate information has been submitted to the NSLDS to fulfill reporting requirements. 4. System Enhancement: To prevent similar issues in the future, we have enhanced our system configuration. This includes implementing additional checks and validations to ensure that the reporting of withdrawn and graduated students is consistently accurate and timely. Our IT team, the Registrar's Office, and Financial Aid Director have conducted rigorous testing to verify the effectiveness of these enhancements. 5. Monitoring and Oversight: Going forward, we will establish a robust monitoring and oversight mechanism to regularly review the data reporting process. This proactive approach will help identify and address any potential issues before they impact compliance with NSLDS reporting requirements. We are confident that the corrective actions implemented will prevent a recurrence of this issue and enhance the accuracy and timeliness of our NSLDS reporting. We remain committed to maintaining the highest standards of compliance with federal regulations and appreciate your understanding in this matter.
Views of Responsible Officials: In the past, WRC performed the risk assessments on the subrecipients by looking at information available on their website, reviewing the audited financial reports as well as performing elaborate Anti-Terrorism checks on the subrecipient, its management and financial i...
Views of Responsible Officials: In the past, WRC performed the risk assessments on the subrecipients by looking at information available on their website, reviewing the audited financial reports as well as performing elaborate Anti-Terrorism checks on the subrecipient, its management and financial institutions. The process was documented in WRC's Fiscal Policies and Procedures. However, the findings of these assessments were not formally documented. During the year, WRC updated it policies and procedures to establish a better way of performing and documenting the risk assessment of the subrecipients. In addition, we are currently in process of registering our subawards in FSRS. We expect the current subawards to be registered within two weeks. We will then look at the possibility of registering expired subawards in FSRS.
Corrective Action Plan - Title I rank and serve budgets are based on the original/final budgets. The total budget per school should never change and should match the rank and serve allocation. Because of staff turnover in Federal Programs, Business Operations, and Finance, the District was unable ...
Corrective Action Plan - Title I rank and serve budgets are based on the original/final budgets. The total budget per school should never change and should match the rank and serve allocation. Because of staff turnover in Federal Programs, Business Operations, and Finance, the District was unable to ensure the schools remained in rank and serve order for 2022-2023. An error was made during the year-end budget cleanup, which changed the schools' original budget. Budget revisions were done, to the Title I budget, to clean up negatives and bring major function object positive at year-end. The entry should have been done within the individual school budgets so the total budget would match the original/final budget. If this entry had not been done, the rank and serve allocations would match to the original buget. Previously, the District has monitored the program correctly and has maintained the District’s rank and serve order. The District will provide training and guidance to the new staff overseeing the grant and the budget allocations to ensure and enforce rank and serve order is maintained going forward. The District has reached out to DOE for guidance on correcting the finding and will follow up with Sean Freeman in the audit resolution and monitoring department once the audit report is published.
View Audit 15892 Questioned Costs: $1
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