Corrective Action Plans

Finding 524920 (2024-002)

Significant Deficiency 2024

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommenda...

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524916 (2024-005)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation:...

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524790 (2024-002)

Significant Deficiency 2024

University of Dubuque

IA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180 Questioned Costs: $1

Finding 524789 (2024-001)

Significant Deficiency 2024

University of Dubuque

IA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the acad...

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the academic year are being reported on a timely basis Financial Aid Office will manually check and enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates Financial Aid Office and Registrar’s Office have been continually working together to ensure timely and accurate reporting of withdrawal dates. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180

Finding 524713 (2024-001)

Significant Deficiency 2024

Norwich University

VT

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response t...

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The errors noted in the finding resulted from a missing step in the reconciliation process. Until recently the Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reenforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not reoccur, subsequently, the registrars office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. Name(s) of the contact person(s) responsible for corrective action: Sarah Harris, Director, Office of Financial Aid Planned completion date for corrective action plan: December 2024

View Audit 344144

Finding 524663 (2024-002)

Material Weakness 2024

University of Southern Indiana

IN

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, ...

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. Contact Person Responsible for Corrective Action: Jina Platts, Assistant Vice President for Finance and Administration and Assistant Treasurer Contact Phone Number and Email Address: 812-465-7090; jlplatts@usi.edu Views of Responsible Officials: We concur with the finding that the University should have ensured that subrecipient audit reports were received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. The University had other controls in place related to subrecipient monitoring including the review of financial reports and requests for reimbursement for subrecipient expenses. One purpose of collecting and reviewing subrecipient audit reports is to determine the level of monitoring required as high, medium, or low. Although the University treats all subrecipients as high risk, we are unable to issue a formal management decision to subrecipients within six months of acceptance of the audit report by the Federal Audit Clearinghouse without assurance that audit reports are received and reviewed in a timely manner. Description of Corrective Action Plan: The University will update subrecipient monitoring procedures as follows: 1. Upon issuance of a subaward, the Business Office will verify if a subrecipient is subject to single audit according to OMB Uniform Guidance. If so, the subrecipient must provide a complete copy of their most recent independent audit used to meet their OMB Uniform Guidance requirement or a link to their record on the Federal Audit Clearinghouse. 2. The Business Office will review the report to verify that there are no findings that may impact the proposed subaward. In the event there are such findings, the Business Office will notify the Office of Sponsored Projects & Research. Together the two offices will determine an appropriate plan of action and issue a Management Decision Letter as required by Uniform Guidance. 3. The Business Office will identify subrecipients receiving payments quarterly and verify that their most recent audit reports have been received and reviewed. Any audit reports completed after issuance of a subaward will be reviewed as described in #2 above. Anticipated Completion Date: Planned corrective actions to be implemented in January 2025.

View Audit 344100

Finding 524659 (2024-001)

Material Weakness 2024

University of Southern Indiana

IN

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those ver...

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee was responsible for performing and reviewing verifications during the audit period without an independent oversight, review, or approval process involving a second employee. Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial Assistance Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu Views of Responsible Officials: We concur with the finding. While the University of Southern Indiana had internal controls in place to prevent aid from disbursing before verification was marked complete and assigned responsibility for verification processing to a well-trained employee with 20 years of verification processing experience, staff vacancies in the department in addition to training and preparation for vast changes in application, award calculation, and system controls for the 2024-2025 aid year limited the ability to conduct an independent review on a sample of students for which verification had been performed. Given the fact that there were very minimal changes to the verification process from the verification process performed in the last several years, in lieu of an independent review, management determined that for the 2023-2024 aid year, utilizing an after-the-fact review on a sample of completed verifications by the employee performing the verification, to review/double-check the verification procedures, provided reasonable assurance that compliance would be achieved. No instances of non-compliance in verification procedures were detected in the audit. Description of Corrective Action Plan: Staffing levels are returning to normal and new staff have a more complete understanding of overall financial aid including the verification process. Also, the Department of Education has provided additional clarification and guidance for all 2024-2025 processing and reduced the number of students selected for verification, allowing management the ability to resume the performance of an independent review on a sample of students for which verification had been performed. Anticipated Completion Date: The independent review was reinstated effective for verifications performed in Fall 2024 and going forward.Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . .􀀃The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.”

View Audit 344100

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524562 (2024-001)

Significant Deficiency 2024

Pacific Oaks Education Corporation

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Finding 524536 (2024-001)

Significant Deficiency 2024

Phoenix Union High School District No. 210

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency § 200.303

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was iss...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was issued without proper authorization. Action planned in response to finding: The District concurs with the finding, recognizing that the expenditure was allowable, and that the approval process was not in place for this expenditure. The District has removed access to the quick approval option for the end‐user to ensure bypassing does not occur. The District will continue to provide training ensuring end users follow proper procedures. Internal controls will be evaluated to ensure proper approval systems are in place to prevent this from recurring.

View Audit 343938

Finding 524499 (2024-002)

Significant Deficiency 2024

Franklin Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.

View Audit 343871

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524468 (2024-001)

Significant Deficiency 2024

The Colleges of Law

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343821

Finding 524460 (2024-004)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Procurement, Suspension & Debarment § 200.303

Beginning March 2025, prior to entering into a covered transaction, the City will verify that its vendors are not suspended or debarred or otherwise excluded from participating in the transaction, when utilizing federal grant dollars. The City will accomplish this by by checking the System for Awar...

Beginning March 2025, prior to entering into a covered transaction, the City will verify that its vendors are not suspended or debarred or otherwise excluded from participating in the transaction, when utilizing federal grant dollars. The City will accomplish this by by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov. The City will provide training to appropriate staff of this requirement.

View Audit 343795

Finding 524447 (2024-001)

Significant Deficiency 2024

National 4-H Council

DC

Questioned Costs Subrecipient Monitoring § 200.1 § 200.211 § 200.303 § 200.332

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial managemen...

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

View Audit 343772 Questioned Costs: $1

Finding 524391 (2024-003)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

Procurement, Suspension & Debarment § 200.303

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-003 Finding: Lack of Control Documentation over Review of Suspended/Debarred Vendors Applicable Regulation: Uniform Grant Guidance (2 CFR 180.300) states that when entering into a covered transaction with another ...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-003 Finding: Lack of Control Documentation over Review of Suspended/Debarred Vendors Applicable Regulation: Uniform Grant Guidance (2 CFR 180.300) states that when entering into a covered transaction with another person at the next lower tier, the nonfederal entity must verify the person with whom the nonfederal entity intends to do business is not excluded or disqualified by: (a) checking Sam.gov Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Finding: KHSU was not able to provide support showing that a check had been performed on vendors with whom KHSU entered into covered transactions to verify the vendor was not suspended or debarred. Corrective Action Taken or Planned: Effective immediately, the Chief Financial Officer (CFO) is responsible for reviewing and approving all new vendors. Additionally, the CFO has reviewed and verified that none of the vendors for FY24 were listed as suspended or debarred in the federal System for Award Management (SAM). Additionally, these measures will be put in place: 1. Implementation of Formal Documentation Process • Additional question added to required new vendor paperwork. Vendors must denote if they are currently suspended or debarred. • University procurement policy has been updated to include new process for vendor approvals. 2. Centralized Recordkeeping • All completed new vendor applications will continue to be maintained in a centralized and secure repository for auditing purposes (Workday). • CFO will maintain documentation on review of vendors, including date they were reviewed and if they are suspended or debarred. 3. Training and Communication • Updated internal processes have been communicated with staff involved in vendor management to ensure awareness. • Clear guidelines on the review, documentation, and recordkeeping processes has been distributed to relevant team members. 4. Periodic Monitoring and Quality Control • An internal review of vendor approvals will be conducted quarterly to ensure compliance with the updated policy. • The internal audit team will include the review of suspended/debarred vendor documentation as part of their regular audit procedures. Contact Person: Matt Ankenbrandt, Chief Financial Officer mankenbrandt@kansashsc.org Anticipated Completion Date: 2/1/25

View Audit 343627

Finding 524390 (2024-002)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-002 Finding: Improper Controls Over Personnel Expenses Applicable Regulation: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that a...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-002 Finding: Improper Controls Over Personnel Expenses Applicable Regulation: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Finding: A KHSU supervisor did not properly document approval for one employee’s personnel activity reports. Corrective Action Taken or Planned: Upon being notified by the auditors of this specific issue, the organization took immediate steps to address the finding. The missing documentation for the personnel activity report was located and the supervisor provided retroactive written approval. The updated Personnel Activity Report was submitted to KDADS. This corrective action resolved the specific instance during the audit. In addition, the following will be implemented: 1. Development and Implementation of a Standard Operating Plan • A SOP for reviewing and documenting approvals of personnel activity reports (PARs) will be developed. • The procedure will include detailed steps for supervisors to review, approve, and retain documentation of PARs. 2. Training for Supervisors • All supervisors responsible for approving PARs will have one-on-one training on the new SOP by the Chief Financial Officer, emphasizing the importance of proper documentation to comply with internal controls and audit standards. • Training sessions will be scheduled. 3. Implementation of Monitoring Controls • A secondary review process will be introduced to ensure compliance with the new procedures, including review by the Principal Investigator. • The Grants Management Office or an equivalent oversight body will conduct periodic audits of PAR documentation to verify proper approvals. Contact Person: Matt Ankenbrandt, Chief Financial Officer mankenbrandt@kansashsc.org Anticipated Completion Date: 2/15/25

View Audit 343627

Finding 524389 (2024-001)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, oth...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343627

Finding 524368 (2024-004)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating memb...

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

View Audit 343584

Finding 524366 (2024-003)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were ...

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

View Audit 343584

Finding 524362 (2024-002)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

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

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was respo...

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was responsible for the preparation and submission of the Form 9. There were no documented internal controls in place such as an oversight, review, or approval process to ensure expenditures were correctly reported. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding 􀁹􀈱EVERY􀈱CHILD􀈱􀁹􀈱EVERY􀈱CHANCE􀈱􀁹􀈱EVERY􀈱DAY􀈱􀁹 JAC􀈬CEN􀈬DEL􀈱COMMUNITY􀈱SCHOOLS CENTRAL OFFICE HIGH SCHOOL / ATHLETICS ELEMENTARY SCHOOL 723 N Buckeye Street 4586 N US 421 4544 N US 421 Osgood, Indiana 47037 Osgood, Indiana 47037 Osgood, Indiana 47037 Telephone: (812) 689-4114 Telephone: (812) 689-4643 Telephone: (812) 689-4144 www.jaccendel.k12.in.us Fax: (812) 689-7423 Fax: (812) 689-5632 Fax: (812) 689-5909 INDIANA STATE BOARD OF ACCOUNTS 26 Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for. I actually printed the Form 9 transmittal report that has the accounts and amounts on it and had the Superintendent review it and sign off on it for the December 2024 Form 9. This will be our process moving forward. Anticipated Completion Date: With the completion of the most recent form 9 December 31, 2024.

View Audit 343584

Finding 524336 (2024-001)

None 2024

South Cook County Intermediate Service Center #4

IL

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant...

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant requirements, we noted the following: For Public Safety Partnership and Community Policing Grants - • One of 2 (50%) quarterly federal financial reports were submitted 36 days late. • One of 1 (100%) semi-annual performance report was submitted 47 days late. For McKinney-Vento Education for Homeless Children and Youth - • Four of 4 (100%) quarterly expenditure reports and the Grant Accountability and Transparency Act (GATA) reports were submitted but the South Cook Intermediate Service Center #4 was unable to provide proof of submission; therefore, we were unable to determine if the required reports were submitted timely or at all. • South Cook Intermediate Service Center #4 did not formally establish a Community Advisory Group. PLAN: Management will develop more formal and comprehensive grant monitoring procedures that will include a checklist for all the necessary reporting and compliance requirements. Specifically for the Mc-Kinney Vento grant, formal documentation for the established Community Advisory Group will be obtained in consultation with the grantor. ANTICIPATED DATE OF COMPLETION: June 30, 2025 CONTACT PERSON: Dr. Anthony Marinello, Executive Director

View Audit 343535

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