Corrective Action Plans

Finding 390385 (2023-001)

Significant Deficiency 2023

CA

Subrecipient Monitoring § 200.332

The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon a...

The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon as practical.

View Audit 301199

Finding 390372 (2023-001)

Material Weakness 2023

Collins Career Center

OH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.320 § 200.327

At the beginning of the project the Center did not plan on using federal grant funds. At the conclusion of the project, it was determined that the project could be paid for by federal funds.

View Audit 301193

Finding 390303 (2023-001)

Significant Deficiency 2023

Office of Hawaiian Affairs State of Hawaii

HI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.319 § 200.320 § 200.327

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This ...

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This procedure was implemented on a go forward basis on March 13, 2024.

View Audit 301164

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390269 (2023-004)

Significant Deficiency 2023

Commonspirit Health

IL

Subrecipient Monitoring Questioned Costs § 200.303

REFERENCE: 2023-004 – Subrecipient Monitoring Research and Development Cluster (Assistance Listing Nos. 12.420, 93.394, 93.650, 93.853, 93.866) Federal Grantor: U.S. Department of Defense, U.S. Department of Health and Human Services Facility: St. Joseph’s Hospital and Medical Center Finding: Whil...

REFERENCE: 2023-004 – Subrecipient Monitoring Research and Development Cluster (Assistance Listing Nos. 12.420, 93.394, 93.650, 93.853, 93.866) Federal Grantor: U.S. Department of Defense, U.S. Department of Health and Human Services Facility: St. Joseph’s Hospital and Medical Center Finding: While St. Joseph’s Hospital and Medical Center has controls in place to review and approve invoices prior to payment, the review was not precise enough to ensure duplicate invoices are not paid to subrecipients. St. Joseph's Hospital and Medical Center approved and paid duplicate invoices for 2 out of 35 selections. This error was identified by St. Joseph's and they are actively working on getting a refund from the subrecipient. The duplicate payments charged to the grant were $5,514. Corrective Action Plan: St. Joseph’s Hospital and Medical Center research administration identified the duplicate invoice request from the subrecipient and have been actively working with the subrecipient to receive a refund and adjust the federal reimbursement request. New procedures have been implemented for research administration to notify research finance of any incorrect payments and research finance will accrue for the adjustment. Person Responsible: Tomas Cortez, Grant Accounting Manager – St. Joseph’s Hospital and Medical Center Expected Completion: June 2024

View Audit 301158

Finding 390267 (2023-004)

None 2023

The Houston Food Bank and Subsidiaries

TX

Questioned Costs Subrecipient Monitoring Eligibility

Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule. In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance depar...

Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule. In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance departments, one in Accounting and one in Partner Services, have been fully established to monitor compliance.

View Audit 301154

Finding 390261 (2023-102)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Eligibility Student Financial Aid § 200.303 § 200.513 § 200.521

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and...

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025 P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $5,612 Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Anticipated completion date: June 30, 2024 The District is aware of the importance of maintaining effective internal control over federal awards and ensuring compliance with applicable federal regulations. The District will work with the TRIO project directors at each college to review and revise existing procedures to require an independent and knowledgeable employee review and approve student eligibility determinations prior to awarding program services to them. The District will enhance communication and training efforts to ensure that the TRIO project directors and all staff administering the TRIO programs understand all eligibility requirements and related district-wide policies and procedures. As of March 21, 2024, the questioned costs for the program have been resolved.

View Audit 301142 Questioned Costs: $1

Finding 390260 (2023-103)

Material Weakness 2023

Maricopa County Community College District

AZ

Special Tests & Provisions Questioned Costs Subrecipient Monitoring § 200.303

Assistance Listing number and name: 84.031 Higher Education – Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096 and P031S200081, October 1, 2020 through September 30, 2025 P031C2...

Assistance Listing number and name: 84.031 Higher Education – Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096 and P031S200081, October 1, 2020 through September 30, 2025 P031C210057 and P031C210077, October 1, 2021 through September 30, 2026 P031S220015 and P031S220179, October 1, 2022 through September 30, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Reporting and special tests and provisions Questioned costs: Unknown Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Diana Aguirre-Rosales, Fiscal Director, Maricopa Community Colleges Foundation Anticipated completion date: December 31, 2024 The District is aware of the importance of ensuring that reports submitted are reviewed for accuracy prior to submission and implemented new processes for report review and submission in November 2023. On February 7, 2024, after multiple requests, the U.S. Department of Education (ED) provided the District with access to ED’s reporting system, which will allow the District to timely submit reports. The District will coordinate with the Maricopa Community Colleges Foundation to ensure that the endowment contracts include all necessary federal regulation information and that the investment and disbursement of funds are in accordance with federal regulations.

View Audit 301142 Questioned Costs: $1

Finding 390234 (2023-001)

Material Weakness 2023

National University

CA

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we c...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we continue to refine our R2T4 processes, we’ve had two key challenges we are addressing: Timeliness of R2T4 calculations: In FY22, NU identified an issue with how it was identifying unofficial withdrawals at the institution. To assist in rectifying the issue, we implemented a 35-day attendance policy that resulted in a significant amount of students being attritted from the University. We were working with a third-party firm to help us complete all the R2T4 calculations, which proved challenging; between our internal staffing and external support, we did not have the ability to do all of the calculations timely. As we’ve analyzed the needed manpower, we’ve expanded our Processing and Quality Assurance teams. The establishment of two additional teams within the Processing team in 2024 underscores our commitment to ensuring the timely completion of necessary calculations. Simultaneously, the increased Quality Assurance team is poised to support the enhanced internal controls, conducting weekly reviews of R2T4 calculations to verify their accuracy and timeliness. Missing students for R2T4 calculations who were withdrawn: We have established precise and accurate criteria for the development and execution of report queries. This initiative aims to ensure the comprehensive identification of students who discontinue attendance before the end of a payment period, thereby mitigating the risk of oversight. To bolster the reliability of these refined processes, NU is committed to implementing regular testing of the attendance queries. By conducting these tests at established intervals, the institution seeks to verify that the queries consistently identify the correct cohort of students. This approach serves as a crucial mechanism to maintain the accuracy of our withdrawal determination processes and underscores our dedication to continuous improvement. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390202 (2023-003)

None 2023

St. Lukes Health Network, Inc. and Controlled Entities

PA

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal ...

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The Network agrees with the finding, and will make the following enhancement to the process: A review of the R2T4 calculation will be evidenced to ensure the calculation is prepared completely and accurately to determine whether a refund is required as well as to verify any post-withdrawal disbursements. The Network is implementing this process beginning in Q4 of FY2024. For inquiries regarding this finding, please contact Lisa Storck, Senior Associate Dean, and Joe Zelasko, Senior Financial Aid Coordinator, who are responsible for the corrective action.

View Audit 301103

Finding 390170 (2023-001)

Significant Deficiency 2023

Prince William Sound Science and Technology Institute

AK

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting....

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting. A second procedure outlines how to complete the required reporting. All existing subcontracts over $30,000 were reported as required. Proposed completion date: December 15, 2023.

View Audit 301086

Finding 390168 (2023-002)

Material Weakness 2023

Altus Independent School District #18

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390167 (2023-001)

Material Weakness 2023

Altus Independent School District #18

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390155 (2023-001)

Significant Deficiency 2023

City of Daly City

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federa...

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2686 68-0281986 Name of Pass-Through Entity: California State Water Resources Control Board • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Cheresa Wang, Financial Services Manager • Corrective Action Plan: City staff will better comply with this rule going forward by either checking the exclusions list for suspensions or debarments for proposed contractors and subrecipients or by including suspension and debarment language in contracts. Finance staff communicated this new procedure to the appropriate project managers in April 2023. In addition, Finance staff developed a new Suspension and Debarment Policy, dated 12/4/23, to provide guidance to project managers on how to comply with this rule. • Anticipated Completion Date: 06/30/24

View Audit 301060

Finding 390146 (2023-002)

Material Weakness 2023

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subreci...

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subrecipient disbursements. Moving forward, management will ensure that it properly allocate expenses in accordance with Uniform Guidance Regulations. In addition, management plans to work closely with the federal passthrough entity to ensure that overbilled amounts are returned during the fiscal year ending June 30, 2024

View Audit 301052 Questioned Costs: $1

Finding 390145 (2023-001)

Significant Deficiency 2023

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 301052

Finding 390136 (2023-001)

Significant Deficiency 2023

Northeast Colorado Board of Cooperative Educational Services

CO

Cash Management Subrecipient Monitoring Material Weakness § 200.305

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the gran...

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the grant manager determines the amount to be requested and this will be subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. A review of the internal control procedures with all grant management and finance staff will assure that this is not a reoccurring issue.

View Audit 301027

Finding 390135 (2023-101)

Material Weakness 2023

Gila County

AZ

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Assistance Listings number and program name: 21.027 COVID-19 Corona Virus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2024 Corrective Action Plan: The County will develop, implement, and maintain procedures requiring both the performance & doc...

Assistance Listings number and program name: 21.027 COVID-19 Corona Virus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2024 Corrective Action Plan: The County will develop, implement, and maintain procedures requiring both the performance & documentation of independent review and approval of all federal program reports prior to submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. Program expenditures will be reconciled to the County’s accounting records. The County’s previous corrective action plan stated “Errors identified will be reported to the federal agency in adjusted or resubmitted reports” however the Federal Reporting interface lacks capacity for resubmitted reports. The adjusted reports resulted in the understatement and overstatement amounts noted in Federal Award Finding 2023-101. Departmental training will be provided for staff responsible for preparing and reviewing reports for both data management, compliance with Uniform Guidance, 2 Code of Federal Regulations (CFR) §200.510, and adherence to County’s policies and procedures.

View Audit 301026

Finding 390126 (2023-003)

Material Weakness 2023

San Francisco Community College District

CA

Allowable Costs / Cost Principles Student Financial Aid Subrecipient Monitoring § 200.430

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and c...

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and charged to the appropriate programs and services. This should be completed by June 30, 2024.

View Audit 301013

Finding 390112 (2023-001)

Significant Deficiency 2023

Omaha - Council Bluffs Metropolitan Area Planning Agency

NE

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Federal Agency Name: U.S. Department of Transportation, Federal Highway Administration Pass‐Through Entity: Nebraska Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Finding Summary MAPA is the pass-through entity for several subrecipient...

Federal Agency Name: U.S. Department of Transportation, Federal Highway Administration Pass‐Through Entity: Nebraska Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Finding Summary MAPA is the pass-through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Corrective Action Plan MAPA will establish written internal procedures and complete a compliance risk determination for every federal subaward to evaluate subrecipient risk of noncompliance in accordance with the guidance provided in 2 CFR 200.332: Requirements for pass-through entities. In particular with regard to this finding, MAPA will verify whether every subrecipient is audited as required by the conditions cited in 2 CFR 200.332(f), and MAPA will evaluate such audits for compliance risk as part of its internal procedures. Responsible Individual Matthew Eash, Director of Finance Anticipated Completion Date June 30, 2024

View Audit 301004

Finding 390109 (2023-001)

Significant Deficiency 2023

City of San Diego

CA

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

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All not...

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All notification receipts and various forms of verification will be saved in house, on the City of San Diego’s network. This corrective action was set in place as of March 28, 2023, based on findings from the water arrearages program audit. The sewer arrearages program was also completed prior to the original corrective action plan date of March 28, 2023. This was the same finding for both the water and sewer arrearage program audits. Moving forward with this action on a continual basis, once email notifications are sent to customers using an external service provider, notification confirmations will be immediately archived at the City of San Diego. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. This affords the City full control and oversight of the verification process for all future noticing. All available notification verifications from the third-party vendor will be downloaded and saved to the City network for future inquiries. Furthermore, internal controls will be enhanced to ensure notification verification compliance. Upon notification to customers, the Billing and Financial Analytics Program Coordinator will oversee the immediate archiving of all confirmations of emails sent to customers using an external service provider. Once complete, the Billing and Financial Analytics Program Coordinator will notify the Program Manager, who will in turn, perform a secondary review of all notifications against the verification documentation to ensure accuracy. At this point, a third level of approval will be added, as the Public Utilities Customer Support Deputy Director will provide a final level review. Once complete, these documents will be saved for a minimum of five years, per the City of San Diego’s retention policy. Implementation Date: 03/28/2023 Contact: Tracy Morales Interim Deputy Director

View Audit 300999

Finding 390105 (2023-001)

Significant Deficiency 2023

Invisible Children, Inc.

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials and Planned Corrective Actions: The Organization made every effort to register subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. However, due to the change from DUNS to UEI by the federal government a...

Views of Responsible Officials and Planned Corrective Actions: The Organization made every effort to register subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. However, due to the change from DUNS to UEI by the federal government and the requirement to use an organization’s UEI to find sub-awardees in FSRS.gov, the Organization was not able to register the subawards meeting the requirements. The Organization is still working with our sub-awardees to establish and collect UEI’s for each so this reporting can be completed this year.

View Audit 300993

Finding 390100 (2023-001)

Significant Deficiency 2023

Saint Michael's College

VT

Subrecipient Monitoring

The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going...

The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going forward the Information Technology department will periodically review the inventory of customer data and update as necessary.

View Audit 300992

Finding 390084 (2023-004)

Significant Deficiency 2023

Aims College District

CO

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Condition: We identified one instance where a student’s program enrollment effective date did not match the institution’s records. Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party se...

Condition: We identified one instance where a student’s program enrollment effective date did not match the institution’s records. Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The College will review enrollment reporting procedures to determine where additional review of data and monitoring of third-party servicer data can be implemented to ensure accurate reporting. Name(s) of the contract person(s) responsible for corrective action: Chris Peterson – Director of Student Financial Aid, Stacy Sharp – Director of Registration and Records, and Laura Beyers – Director of Registration and Records Planned completion date for corrective action plan: June 30, 2024

View Audit 300954

Finding 390055 (2023-001)

None 2023

City of Willows

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Program Income

We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Co...

We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Corrective Action Plan: Given the strain on resource available among City staff, the City is working to hire an outside consulting firm to assure a consisten loan monitoring program is in place. Anticipated Completion Date: June 2024

View Audit 300908

Corrective Action Plans

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