Corrective Action Plans

Finding 630 (2023-001)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Plann...

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Planned: Enrollment Services staff have created a shared logbook that will track and compile NSC transactions. This logbook is saved to a shared drive with access given to appropriate staff, VP of Student Development and Dean of Enrollment Services. Additionally, any extended gaps in reports being verified, submitted and/or responses by either College staff or NSC staff will be followed up with by the Assistant Dean of Enrollment Services and logged in the NSC logbook for audit purposes. Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

View Audit 1222

Finding 573 (2023-002)

Significant Deficiency 2023

East China School District

MI

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

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval a...

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval and consideration during the grant planning process.

View Audit 1118

Finding 567 (2023-001)

Significant Deficiency 2023

Covenant College, Inc. and Supporting Foundation

GA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 1) Written Annual report to the Board of Directors on the overall status of ISP and GLBA compliance does not address risk management and control decisions, results of testing, security events or violations and management's respon...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 1) Written Annual report to the Board of Directors on the overall status of ISP and GLBA compliance does not address risk management and control decisions, results of testing, security events or violations and management's response to each, and recommendations for changes in the Program. A report was submitted to the Board of Trustees in September 2023 for their review at the October meeting on campus. The Board will meet on campus again in March 2024 should any additional information or changes be needed. 2) MFA is not enabled for Banner by Ellucian and National Student Clearinghouse - § 314.4(c)(5) of the GLBA. This is in progress. Technical specifications for MFA in Banner have been reviewed. Testing of three possible options should be started in October 2023. Our Registrar has contacted the NSC and requested MFA on our accounts. 3) No annual penetration testing of information systems. This is in progress. As of September 2023 five vendors were being reviewed and evaluated for this engagement. 4) Vendors are only evaluated at contract initiation. This is in progress. Review of templates and approval needed has already started. Person Responsible for Corrective Action Plan: Dr. H. Collin Messer, Vice President for Academic Affairs Anticipated Date of Completion: May 1, 2024

View Audit 1114

Finding 558 (2023-001)

Significant Deficiency 2023

Augustana College

IL

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Department of Education Augustana College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistentl...

Department of Education Augustana College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Augustana’s WISP will be revised to address GLBA required elements. Name of the contact person responsible for corrective action: Chris Vaughan Planned completion date for corrective action plan: January 1, 2024 If the United States Department of Education has questions regarding this schedule, please call Jacob Bobbitt at 309-794-7154.

View Audit 1111

Finding 466 (2023-001)

Significant Deficiency 2023

Global Learning Public Charter School

MA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring

The Global Learning Charter Public School Administration and Board of Trustees acknowledge that the limitations present with the segregation of financial duties are the direct result of the size of the school’s financial operation. Over the next year, GLCPS will be undergoing a change in leadership ...

The Global Learning Charter Public School Administration and Board of Trustees acknowledge that the limitations present with the segregation of financial duties are the direct result of the size of the school’s financial operation. Over the next year, GLCPS will be undergoing a change in leadership that will provide the school with greater opportunity to enhance internal financial oversight, further augmenting existing procedures. GLCPS will continue evaluating these procedures and implementing changes as recommended. The Global Learning Charter Public School Foundation will also be reviewing the composition of its Board of Directors to clearly delineate the roles and responsibilities of its members.

View Audit 1016

Finding 435 (2023-001)

Significant Deficiency 2023

Northeast Ohio Medical University

OH

Subrecipient Monitoring Reporting Significant Deficiency

Finding Number: 2023-001 Anticipated Completion Date: October 16, 2023 Responsible Contact Person: Bianka Hernandez, Director of Grants Accounting Planned Corrective Action: All FFATA reporting will be entered onto the FSRS website immediately after full execution. The report will be saved and sub...

Finding Number: 2023-001 Anticipated Completion Date: October 16, 2023 Responsible Contact Person: Bianka Hernandez, Director of Grants Accounting Planned Corrective Action: All FFATA reporting will be entered onto the FSRS website immediately after full execution. The report will be saved and submitted monthly as new subaward agreements are fully executed. The FFATA report will be monitored and reviewed three business days before the end of the current month, so that the report may be submitted in a timely manner.

View Audit 953

Finding 434 (2023-001)

Significant Deficiency 2023

South Pointe Housing, Inc.

LA

Subrecipient Monitoring HUD Housing Programs Reporting

At the end of July, 2023, security deposits held on behalf of tenants were $9,206 and funds held in reserve at the bank were $9,442.80. August security deposits held on behalf of tenants were again $9,206 and funds held in reserve at the bank were $9,442.80. We will continue to monitor this on a mo...

At the end of July, 2023, security deposits held on behalf of tenants were $9,206 and funds held in reserve at the bank were $9,442.80. August security deposits held on behalf of tenants were again $9,206 and funds held in reserve at the bank were $9,442.80. We will continue to monitor this on a monthly basis.

View Audit 947

Finding 399 (2023-001)

Significant Deficiency 2023

Okemos Public Schools

MI

Subrecipient Monitoring School Nutrition Programs Significant Deficiency

OKEMOS PUBLIC SCHOOLS FOR THE YEAR ENDED JUNE 30, 2023 Okemos Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2023 District Con...

OKEMOS PUBLIC SCHOOLS FOR THE YEAR ENDED JUNE 30, 2023 Okemos Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2023 District Contact Person: Liz Lentz, Executive Director of Finance Finding 2023-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: Management agrees with the finding and had already changed procedures during the school year to better track and claim meals.

View Audit 830

Finding 372 (2023-001)

Material Weakness 2023

Kearney Housing Agency

NE

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

I have reached out to the Nebraskaland Bank regarding alternate collateralization. If this bank cannot provide appropriate collateral, a new banking institution will be found.

View Audit 782

Finding 367 (2023-001)

None 2023

Jessie Trice Community Health System, Inc.

FL

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.317 § 200.318 § 200.327

Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implem...

Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implementation Date of Corrective Action Plan: Management has started revising its policy and expects to have a revised procurement policy during fiscal year ending January 31, 2024.

View Audit 770

Finding 343 (2023-001)

None 2023

Southern Virginia University

VA

Student Financial Aid Subrecipient Monitoring Cash Management

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid proce...

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays. Anticipated Completion Date: Completed

View Audit 719

Finding 338 (2023-002)

Significant Deficiency 2023

South Arkansas Regional Health Center, Inc.

AR

Cash Management Subrecipient Monitoring

The Center will be creating new general ledger accounts that reference the budget categories for the CCBHC grant. Each month there will be a reconciliation performed between the trial balance and amounts submitted to be drawn down for the grant. The expenses included in the general ledger will be re...

The Center will be creating new general ledger accounts that reference the budget categories for the CCBHC grant. Each month there will be a reconciliation performed between the trial balance and amounts submitted to be drawn down for the grant. The expenses included in the general ledger will be reviewed thoroughly to ensure they are allowable expenses. Additionally, all expenses will be coded to the account associated with the category they are budgeted in to allow for easier expense tracking when drawing down funds for the grant.

View Audit 683

Finding 323 (2023-001)

Significant Deficiency 2023

Mary Lee Flagship

TX

Subrecipient Monitoring

Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 202 training regarding the initial and recertif...

Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 202 training regarding the initial and recertification process. Additionally, management is staffing the property with a dedicated property manager that will be responsible for reviewing tenant files for compliance with HUD procedures including uses of EIV reports and ensure supporting documentation is maintained in each tenant’s file prior to signing new or amended leases.

View Audit 626

Finding 236 (2023-003)

Significant Deficiency 2023

Sunrise Community Health

CO

Internal Control / Segregation of Duties Subrecipient Monitoring

Recommendation: Our auditors recommended the Organization review internal controls in regards to the determination, recording and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilitzed for each sliding fee encounter. Explanation of disagreement wi...

Recommendation: Our auditors recommended the Organization review internal controls in regards to the determination, recording and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilitzed for each sliding fee encounter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization's enrollment and billing department will work together to identify when any errors occur based on the documentation the patient provides. The enrollment team will verify the rate, and the billing and coding team will begin checking to ensure the rate that the patient was screened for is the rate the patient is being charged for and that the correct discoutn applies.

View Audit 487

Finding 221 (2023-002)

Material Weakness 2023

Mary Lee Charles Place

TX

HUD Housing Programs Subrecipient Monitoring

Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the initial and recertif...

Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the initial and recertification process. Additionally, management is staffing the property with a dedicated property manager that will be responsible for reviewing tenant files for compliance with HUD procedures including uses of EIV reports and ensure supporting documentation is maintained in each tenant’s file prior to signing new or amended leases. Estimated completion date is November 30, 2023.

View Audit 460

Finding 216 (2023-001)

None 2023

Chowan University

NC

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

Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and docum...

Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and documentation process will be created to track, manage and reconcile the disbursement requests sent to COD. This process will aidin recognizing approved disbursements, rejected requests, and posting of disbursements. • The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit. Anticipated Completion Date: The disbursement procedures will be monitored on an ongoing basis.

View Audit 409

Finding 209 (2023-001)

Significant Deficiency 2023

University of Health Sciences and Pharmacy in St Louis

MO

Student Financial Aid Subrecipient Monitoring Reporting

The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the N...

The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the National Student Clearinghouse's (NSC's) system automatically overrides the graduation data in the University's Jenzabar report without notifying the University, a two-step corrective action plan has been initiated. The modified reporting process to improve internal controls consists of the following steps: 1. Upload the initial Jenzabar enrollment reporting into the NSC system which will show full-time enrollment for both the bachelor's degree and the PharmD program; 2. File a second report reflecting the date of completion of the bachelor's degree for all students in the integrated program to remedy the NSC system override of graduation data in the initial Jenzabar report; and 3. Conduct a manual verification of graduation data in the National Student Loan Data System to ensure complete, accurate and timely reporting of graduation information from NSC. The modified reporting process is expected to be fully implemented at the conclusion of the 2023-2024 academic year in conjunction with completion of commencement, which is scheduled to occur in May 2024.

View Audit 398

Finding 87 (2023-001)

Significant Deficiency 2023

The Friendly House of Davenport, Iowa

IA

Subrecipient Monitoring

The Organization has implemented a facility monitoring program that incorporates all of the facility visit requirements as described in the grant agreement.

View Audit 105

Finding 1216731 (2022-001)

Material Weakness 2022

STEPS to Recovery Homes

AZ

Subrecipient Monitoring Allowable Costs / Cost Principles

Management of the Organization will restructure all classes in the functional classing system, as well as utilize the project function, and consistently apply expenditures such that system reports accurately reflect income and expenditures by program / grant.

View Audit 403176

Finding 1216173 (2022-010)

Material Weakness 2022

Virgin Islands Port Authority

VI

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

The Authority will retain emails between preparers and reviewers for forms that cannot be signed.

View Audit 402648

Finding 1216172 (2022-009)

Material Weakness 2022

Virgin Islands Port Authority

VI

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

The Authority will continue to make progress in meeting required review processes and submission timelines. For the reports where the submission requirement is unclear, the Authority will consult with its federal partner to obtain a determination.

View Audit 402648

Finding 1216171 (2022-008)

Material Weakness 2022

Virgin Islands Port Authority

VI

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

The Director of Engineering will sign reports submitted to the FAA to confirm that the items have been reviewed. The Senior Compliance Officer serves as the recordkeeper for documents filed between the Authority, the FAA, and other institutions, ensuring that the Authority submits the required filin...

The Director of Engineering will sign reports submitted to the FAA to confirm that the items have been reviewed. The Senior Compliance Officer serves as the recordkeeper for documents filed between the Authority, the FAA, and other institutions, ensuring that the Authority submits the required filings and maintains a working spreadsheet of items sent. In addition, Accounting has implemented a tickler system to remind staff to submit financial reports to Engineering or the grantor.

View Audit 402648

Finding 1216167 (2022-006)

Material Weakness 2022

Virgin Islands Port Authority

VI

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

The Authority will ensure that when a federal report is prepared by Director, it will be reviewed by another Director or member of the management team.

View Audit 402648

Finding 1214376 (2022-012)

Material Weakness 2022

St. Croix Chippewa Housing Authority

CA

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.327

2022-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as de...

2022-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 401032

Finding 1214375 (2022-011)

Material Weakness 2022

St. Croix Chippewa Housing Authority

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management § 200.305

2022-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this fi...

2022-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 401032

Corrective Action Plans

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