Corrective Action Plans

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Finding 504696 (2024-004)
Significant Deficiency 2024
Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with aud...
Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procedure will be implemented for the review of the report submission including the proper documentation of the review Name of the contact person responsible for corrective action: Angela Schults, Comptroller Planned completion date for corrective action plan: 1 April 2025
Finding 504695 (2024-003)
Significant Deficiency 2024
Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explana...
Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Village has developed a review process which satisfies the requirements for suspension and debarment per the Uniform Guidance. Staff is assigned to monitoring the need for this process and when appropriate, complete necessary procedure to document findings relative to suspension or debarment. Name of the contact person responsible for corrective action: Angela Schultz, Comptroller Planned completion date for corrective action plan: April 30, 2025
MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 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—FE...
MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 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—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-01: 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: The college has reviewed and updated procedures to ensure that graduation and enrollment files are submitted in the necessary sequence to reflect the appropriate enrollment status and effective dates. Name(s) of the contact person(s) responsible for corrective action: Nanci A. Beier, Registrar Planned completion date for corrective action plan: Completed
Finding 504301 (2024-006)
Significant Deficiency 2024
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the re...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the need to enhance our documentation of internal controls to ensure testability and maintain compliance with federal reporting standards. While our existing internal processes ensured data accuracy, timeliness, and submission compliance, we acknowledge that documentation of the review process is beneficial. Moving forward, the Contract Review Officer (CRO) will review FFATA reports submitted by another team member. When the CRO submits the report, her supervisor or an OSP employee will perform the review. Each review instance will be documented with the reviewer’s name and date to reinforce control transparency and testability, aligning our process more closely with compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Sarah Martonick, Director, Office of Sponsored Programs, 208-885-2145. Planned completion date for corrective action plan: October 31, 2024
Finding 504300 (2024-005)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Expla...
Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a weekly report for all communications. We also reviewed the populations selection. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: 12/31/24
Finding 504296 (2024-003)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with aud...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024
Finding 504292 (2024-004)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Aid updated our auto packaging policy. Name(s) of the contact person(s) responsible for corrective action: This was a part of our aid year rollover process and planning. Planned completion date for corrective action plan: April 2024
View Audit 326827 Questioned Costs: $1
Finding 504291 (2024-002)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS 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: We are adjusting our corrective action. Last year we tested several out of cycle enrollment adjustments each term to ensure our processes were working. We didn’t find any issues. This year we will be comparing all the students were not reported to the Clearinghouse with the list reported to the Clearinghouse to ensure all students who need to be reported are properly reported. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: We ran our first comparison on 9/19/2024 and we will be running every month we do the Clearinghouse reporting.
Finding 504290 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation ...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the auditors’ recommendations of corrective action needed to ensure unclaimed Title IV federal funds are resolved within 240 days of disbursement date. The University has reviewed existing processes and identified improvements that will be made to internal procedures to ensure proper compliance is met. Name(s) of the contact person(s) responsible for corrective action: Delora Shoop & Amanda Bauer. Planned completion date for corrective action plan: December 2024
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal re...
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was isolated to less-than-half-time Pell recipients. These recipients will be processed through the auto-packing process and then will undergo a secondary manual review prior to disbursement. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes and John Bender Planned completion date for corrective action plan: Immediate Implementation
Finding 503947 (2024-002)
Significant Deficiency 2024
Action taken in response to finding: We have 26 active awards that would be non-R&D. Grants and Contracts Accounting (GCA) is currently reviewing each to verify if all had check boxes checked as R&D on Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Sub...
Action taken in response to finding: We have 26 active awards that would be non-R&D. Grants and Contracts Accounting (GCA) is currently reviewing each to verify if all had check boxes checked as R&D on Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward. Once we have the impacted population, GCA will issue a modification for those to draw attention to the error. In addition, GCA will ensure internal procedures are updated to review this field and verify proper identification prior to subaward execution. Anticipated Completion Date: September 30, 2024 Person Responsible: Tracy Walters, Director of Grants and Contracts Contact/Responsible Party: Tracy Walters, Director of Grants and Contracts Contact Information: trwalte@clemson.edu
Finding 503946 (2024-001)
Significant Deficiency 2024
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the r...
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the requestor if they had also added the missing hours via a CU Special Pay. Additionally, as of 06/21/2024, the Late Timesheet option was turned off on CU Special Pay to strengthen controls. Individuals now contact payroll@clemson.edu for assistance. Once contacted the payroll/timekeeping team will update the timecard and ensure the missed pay is added to the next payroll cycle, assuming an emergency/off-cycle check is not needed. The College of Engineering and Applied Sciences (CECAS) will take action to strengthen internal controls to ensure accuracy and compliance. We will establish clear procedures to verify employee payroll data via paylines, as well as cross checking with CU Payroll to ensure changes are properly documented and authorized. We will provide ongoing training for departmental payroll staff on best practices and compliance requirements. Anticipated Completion Date: September 17, 2024 Person Responsible: Central Payroll – Ami Hood, Payroll Director; CECAS – Keri Cortese, Director of Procurement and Payroll Operations Contact/Responsible Party: Ami Hood, Payroll Director Contact Information: hooda@clemson.edu
View Audit 326225 Questioned Costs: $1
Finding 2024 -002 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number: 93.526 Program Name: Grants for Capital Development in Health Centers Finding Summary: There was no evidence retained that the Community Health Center reviewed vendors to determine their st...
Finding 2024 -002 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number: 93.526 Program Name: Grants for Capital Development in Health Centers Finding Summary: There was no evidence retained that the Community Health Center reviewed vendors to determine their status in regards to the suspension and debarment requirement. Furthermore, the Community Health Center did not have written suspension and debarment policies. Responsible Individuals: Shelly Davis, CFO Corrective Action Plan: Management has reviewed and updated their procurement, suspension and debarment policy to include specific documentation regarding the documentation of suspension and debarment practices. Anticipated Completion Date: Procurement Policy 432 was updated and approved by the Board of Directors on June 27, 2024. Additionally, a procurement procedure was developed and implemented at the same time. This corrective action will be ongoing.
Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures...
Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance. Action Taken: Hubbs-SeaWorld Research Institute plans to modify its procurement procedures for federal grants to comply with 2CFR section 200.319 by continuing to require at least three bids (or a sole source statement, if applicable) for any purchases over the micro-purchase threshold, currently $10,000. In addition, we will monitor cumulative vendor purchases on a monthly basis to ensure that price or rate quotations are obtained from an adequate number of qualified sources, that is, at least three bids (or a sole source statement, if applicable.)
Finding 503360 (2024-002)
Significant Deficiency 2024
Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Compl...
Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Completion Date: September 30, 2024 Responsible Party: Michaela Arndt, County Clerk
Finding 2024-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans andGrants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Gerry Le...
Finding 2024-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans andGrants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program's reserve fund is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and will sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account. Anticipated Completion Date: Ongoing
Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment s...
Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment status. The university immediately (August 2024) implemented training for the newly appointed Interim Registrar on the importance of timely and accurate reporting of enrollment status changes and graduation status. This training was conducted in coordination with the Vice President of Student Services, the Director of Financial Aid, the Controller, and the Director of Information Technology. In addition to hands-on training provided by university personnel, online resources were utilized from NSLDS, Clearinghouse, and the United States Department of Education. The policies and procedures for enrollment reporting has been strengthened, and includes the following reporting schedule: a student roster schedule will be submitted every 30 days. The exceptions report will be reviewed immediately and will be corrected within 10 days. Within 15 days of the end of each semester, a list of graduated students will be submitted to NSLDS. Exceptions will be corrected immediately to ensure all records in NSLDS match the student’s record. The university is confident that the finding related to enrollment reporting has been resolved. Enrollment files are being submitted every 30 days. Summer 2024 completers graduated on August 9, 2024. These students were reported through Clearinghouse, exceptions were addressed, and enrollment statuses of “Graduated” show on NSLDS as certified on September 13, 2024. The schedule of enrollment and reporting and graduation reporting will ensure that the statuses will be accurate in NSLDS. Responsible Person Rose Mulkey, Interim Registrar Anticipated completion date Completed as of July 26, 2024.
Finding 501986 (2024-002)
Significant Deficiency 2024
Program: AL 21.027 - COVID-19- Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended o...
Program: AL 21.027 - COVID-19- Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: August 16,2024 Responsible Party: Dixon County Board of Supervisors: Don Andersen, Deric Anderson, Roger Peterson, Neil Blolun, Lisa Lunz, Terry Nicholson, and Steve Hassler.
Finding 2024-003 Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the...
Finding 2024-003 Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Responsible Individual: Mandy Robinson, Administrator Corrective Action Plan: We will implement additional control processes to ensure a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balance is completed by staff separate from the preparer. Anticipated Completion Date: 12/31/2024
Management's Response: KC CARE Agrees Views of Responsible Officials and Corrective Action: This appears to be an isolated incident where the vendor was not entered at the correct time in our contract management database. But, in response to this incident, management created a clearer policy and ou...
Management's Response: KC CARE Agrees Views of Responsible Officials and Corrective Action: This appears to be an isolated incident where the vendor was not entered at the correct time in our contract management database. But, in response to this incident, management created a clearer policy and outlined the timing of entering new vendors into the database and then making sure to do initial exclusion check during procurement process. Responsible Official: Dennis Dunmeyer, COO Anticipated Completion Date: Already implemented.
Condition: Due to a lack of effectively designed and implemented controls to ensure compliance with allowable cost principles, management requested reimbursement based upon employment contract agreements rather than actual payroll costs incurred for the individuals working under the grant. Planned C...
Condition: Due to a lack of effectively designed and implemented controls to ensure compliance with allowable cost principles, management requested reimbursement based upon employment contract agreements rather than actual payroll costs incurred for the individuals working under the grant. Planned Corrective Action: The organization will implement internal controls to ensure expenditure is allowed in accordance with 2 CFR 200 Subpart E. Costs must be necessary, reasonable, and allocable. Contact person responsible for corrective action: Charles Berry (CFO) Anticipated Completion Date: 06/30/2026
Condition: A lack of effectively designed and implemented internal controls over the accounting records resulted in material entries identified and recorded during the 2023 financial statement audit of the Organization. Additionally, as the result of a lack of effectively designed and implemented co...
Condition: A lack of effectively designed and implemented internal controls over the accounting records resulted in material entries identified and recorded during the 2023 financial statement audit of the Organization. Additionally, as the result of a lack of effectively designed and implemented controls over financial and performance reporting for the Health Center Program cluster grants, inaccurate performance data and the Federal share of expenditures were submitted to HRSA. Planned Corrective Action: The organization will implement internal controls to prepare and review accurate reconciliations with supporting information over all accounting cycles in a timely manner. Contact person responsible for corrective action: Charles Berry (CFO) Anticipated Completion Date: 9/30/2026
Condition: The Organization maintains and tracks Federal expenditures incurred for the year in totality; however, it does not maintain adequate records to track the costs applied to each individual drawdown made throughout the year. Without this linkage, the timeliness between drawdown and either wh...
Condition: The Organization maintains and tracks Federal expenditures incurred for the year in totality; however, it does not maintain adequate records to track the costs applied to each individual drawdown made throughout the year. Without this linkage, the timeliness between drawdown and either when the expenditures for goods and services were incurred or when the disbursement occurred in relation to the drawdown cannot be validated. Planned Corrective Action: The organization will implement controls to ensure cash management and allowability compliance areas are addressed by linking cash drawdowns to Federal expenditures. Contact person responsible for corrective action: Charles Berry (CFO) Anticipated Completion Date: 9/30/2026
Condition: The Organization lacked sufficient internal controls to ensure sliding fee discount applications were on file and included all of the necessary information regarding family size and income to support discount determinations made. Further, controls were not sufficient to ensure the correct...
Condition: The Organization lacked sufficient internal controls to ensure sliding fee discount applications were on file and included all of the necessary information regarding family size and income to support discount determinations made. Further, controls were not sufficient to ensure the correct sliding fee discount was applied. Planned Corrective Action: The organization will implement controls to ensure sliding fee applications are maintained and sliding fee adjustments are based on correct family income and resident size. Contact person responsible for corrective action: Charles Berry (CFO) Anticipated Completion Date: 6/30/2026
Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporti...
Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporting documentation and justification for the requested amount are reviewed and approved before funds are drawn down.
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