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Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 stu...
Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 students where the Enrollment and Admissions Departments discovered submission of fraudulent documents to verify residency. City Colleges performed a thorough investigation of student enrollment and verified that no aid was disbursed for these identified fraudulent enrollments Cause City Colleges experienced turnover in the Admissions Department and was training a new employee. The new employee did not have enough training or experience to identify fraudulent documents when the students enrolled with the college and registered for classes. City Colleges was not aware that this issue was required to be reported to the Department of Education. Corrective Action Taken or Planned: The College will review and monitor the Department of Education regulations. The Student Financial Aid will continue to train employees on the regulations and will timely report issues to the Department of Education. Contact Person: Tiffany Morrison, Associate Vice Chancellor – Financial Aid & Scholarship Anticipated Completion Date: In progress
Finding 2023-007 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Annual Reporting Condition City Colleges did not accurately report certain information required in the calendar year 2022 annual report. The following instances of noncompliance were identified: • HEER...
Finding 2023-007 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Annual Reporting Condition City Colleges did not accurately report certain information required in the calendar year 2022 annual report. The following instances of noncompliance were identified: • HEERF Institutional Portion: City Colleges submitted the annual report for Olive Harvey for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $234,118 which was a result of a figure being double counted in the total. • HEERF Institutional Portion: City Colleges submitted the annual report for Malcolm X for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $5,580,216 which was a result of a figure being double counted in the total. Cause City Colleges did not have effective internal controls in place to ensure reports were submitted accurately. Corrective Action Taken or Planned Finance will validate and review the OH and MX 2023 annual report for HEERF prior to submission in 2024. Financial Aid will submit the required HEERF Annual Reporting Correction for OH and MX. In addition, will submit the final required 2023 HEERF annual report. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: December 31, 2023
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic i...
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of December 2023. Corrective Action Taken or Planned CCC will refresh the current data inventory and instate periodic inventory refresh procedures by December 31, 2023. Contact Person: Zarko Njakara, Interim CIO Anticipated Completion Date: December 31, 2023
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campus...
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that review controls were performed over the transfer, carryforward, carryback, and administrative cost calculations in the Fiscal Operations Report and Application to Participate (FISAP) for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. • Reporting: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that secondary review controls were performed over FISAP data for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. Cause City Colleges did not formally document the additional reviews and approvals over the department’s review of the FISAP. Corrective Action Taken or Planned Financial Aid will develop and document a review/approval process that will detail accurate reporting, secondary reviews, and review/approval of FISAP submissions and completions. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through Jan...
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Kennedy King College had excess cash for the Direct Loan Program ranging from $1,349 to $4,318 during the period of November 29, 2022 through December 13, 2022, from $1,508 to $3,948 during the period of January 6, 2023 through January 16, 2023 and from $3,207 to $5,137 during the period of June 15, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns, however, amounts were not returned within a seven-day period. • Truman College had excess cash for the Pell Grant Program ranging from $164,625 to $262,034 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Truman College had excess cash for the Direct Loan Program ranging from $2,731 to$8,669 during the period of January 20, 2023 through February 16, 2023 and from $752 to $10,028 during the period of April 28, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned within a seven-day period. Cause The College drew down funds available in the G5 system as opposed to drawing down expected student disbursement amounts. Corrective Action Taken or Planned District Office Financial Aid will develop and implement better controls and procedures for monitoring the timing of the draw downs and student disbursements as well as controls to monitor the return of excess cash, if any, within the 7-day period. During the middle of a semester, timely reconciliations will be prepared, reviewed and approved prior to the next draw down to ensure the acceptable amount is drawn down and disbursed timely to the students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
View Audit 6574 Questioned Costs: $1
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements we...
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements were reported one day late. Cause The financial aid office inadvertently miscalculated the reporting date. Corrective Action Taken or Planned Financial Aid will add additional monitoring controls of COD files to ensure timely reporting. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The...
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The financial aid office did not follow-up on the gainful employment of students. Corrective Action Taken or Planned The Financial Aid Office will work with campus leadership and staff to ensure an accurate reporting process is in place to track gainful employment and completion. Documentation will be required by campus leadership to show communication efforts for students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause Th...
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Corrective Action Taken or Planned City Colleges sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports CCC enrollment data to NSLDS. City Colleges (Records, Financial Aid, Decision Support and the Office of Information Technology) continues to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: May 1, 2024
Finding Reference 2023-001 Corrective Action Plan: • After the quarter end, the Compliance Manager will request a report containing Teacher Loan Forgiveness applications reviewed by Trellis during the quarter. • The Compliance Manager will select a random sample of five applications to review for ac...
Finding Reference 2023-001 Corrective Action Plan: • After the quarter end, the Compliance Manager will request a report containing Teacher Loan Forgiveness applications reviewed by Trellis during the quarter. • The Compliance Manager will select a random sample of five applications to review for accuracy and completeness. • The Compliance Manager will review all documentation submitted and ensure that Trellis systems are updated/documented accordingly. • The results of the review, including any exceptions noted, will be summarized, documented, and reported to the Manager of Customer Support, the Director of Operations, and the VP of Operations. Contact Person: Susan High Anticipated Completion Date: October 6, 2023
Recommendation: Implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will updat...
Recommendation: Implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organizatio...
Recommendation: Implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organizat...
Recommendation: Implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in ...
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to findin...
Recommendation: Implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in ...
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Finding Number 2023-006 — Significant Deficiency in Internal Control — Covid 19-ESSER II 23b-Summer School and ESSER II-98C - Approval Process Condition: During expense testing of ESSER funds, a July 2022 expenditure for $24.95, payable to BMO, and an August 2022 invoice for $10,167, payable to IXL ...
Finding Number 2023-006 — Significant Deficiency in Internal Control — Covid 19-ESSER II 23b-Summer School and ESSER II-98C - Approval Process Condition: During expense testing of ESSER funds, a July 2022 expenditure for $24.95, payable to BMO, and an August 2022 invoice for $10,167, payable to IXL for math software licenses, were not approved by the Director of Business Services. During this time, the Director of Business Services position was vacant. Proper internal control procedures would ensure a proper approval process, for any position that is temporarily vacant. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop an approval process workflow that would temporarily utilize another administrator for approvals in Munis if any key position is vacant. The district has two administrators per building. The administrators will have the other building administrator act as approver for that building in the event an administrative position is vacant. If both principal positions are vacant, an administrator in another building will be integrated into the approval process for the building with no administrator. At Central Office, the next key position for approvals would be Trina Smith, the Accounts Payable/Accounts Receivable Accountant. If this position is vacant, the llRlPayroll Accountant will assume those approval duties. The final step of approval is the Director of Business Services to approve items before the AP/AR position can process any items. These items include invoices, requisitions, purchase orders, payroll related items and journal entries. In the event the Director of Business Services position is vacant, the District Superintendent of Schools will be the final approver. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools
Finding 3732 (2023-001)
Significant Deficiency 2023
Corrective Action Plan (Prepared by the Charter Holder) Finding 2023 – 001 Management has recognized the need for additional personnel to assist in ensuring compliance and accuracy with various reporting and compliance requirements. In September 2023, the Charter Holder posted a grant manager positi...
Corrective Action Plan (Prepared by the Charter Holder) Finding 2023 – 001 Management has recognized the need for additional personnel to assist in ensuring compliance and accuracy with various reporting and compliance requirements. In September 2023, the Charter Holder posted a grant manager position to support the Chief Financial Officer with state and federal reporting, budgeting, and grant compliance. While the position is vacant, the Charter Holder’s business manager is reviewing financial and compliance reports for accuracy. Management has reached out to Texas Education Agency about the reporting error and is waiting for further instructions on how to correct the reporting error. Responsible Party: Marian Hamlett, CFO Implementation Date: Immediately
2023-002 Finding: Assessment System Security Title 1, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))) Summary of Finding: The District is required to establish internal controls to ensure assessment security. Historically one of these internal controls included a Site Visit Sche...
2023-002 Finding: Assessment System Security Title 1, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))) Summary of Finding: The District is required to establish internal controls to ensure assessment security. Historically one of these internal controls included a Site Visit Schedule to provide security assessment reviews. Site visits were performed at a select number of schools but did not include all Title schools in compliance with the requirements of the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently implementing a process to ensure compliance. The Chief of Strategy and Data Acquisition has developed in coordination with the district Director of Metrics and Accountability, Area Superintendents, and the Colorado Department of Education Assessment Division a process processes to implement the needed internal controls that will ensure compliance to this requirement. They are as follows: Area Data Coaches will visit their portfolio of schools in the first 3 days of the state assessment window to ensure compliance with assessment security policies and procedures. Each data coach will receive full training from the CDE and the District Assessment Coordinator to ensure compliance with all security protocols in each building. Education Insights utilizes Area Data Coaches who work in close partnership with each Area Superintendent. Client Responsible Party: Natasha Crouse, Director of Metrics and Accountability. Each site visit will be documented with findings and any pertinent outcomes recorded. These logs will be securely stored on the Education Insights shared drive. Client Responsible Party: Dr. David Khaliqi, Chief of Strategy and Data Acquisition Completion Date: Assessment security training implemented as of March. 1, 2024. Standardized security assessment checklists and rubrics will be established by April 1, 2024. All site visits will be completed by April 10, 2024. Ongoing training throughout the year will be accomplished as needed. Adjustments and revisions to initial processes will be implemented as needed. Time and Effort certifications will be completed semi-annually.
Material Weakness: Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the feder...
Material Weakness: Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Hospital claimed reimbursement for health-related lost revenue during the COVID-19 pandemic. Condition: The Hospital claimed reimbursement for health-related lost revenue based on a comparison of actual monthly revenue for the months of March, April, and May 2020 to the same corresponding months of 2019. Within the calculation, the Hospital excluded certain other operating revenue from the 2020 monthly totals which were included in the 2019 monthly totals. As a result, the compilation of revenue used between the periods was not consistently applied resulting in a higher lost revenue calculation than prescribed by the applicable guidance. Views of Responsible Officials: Management agrees with the finding. Planned Completion Date: April 30, 2024. Person Responsible: Cyrstal Wyatt, CFO.
View Audit 5310 Questioned Costs: $1
Corrective Action Plan: AlaHA will accomplish the following: 1) Send guidance to hospital systems with multiple facilities reported on their 941s that they should retain general ledger detail reconciliations to support the funds received. 2) Request the hospital involved in the exception cited fo...
Corrective Action Plan: AlaHA will accomplish the following: 1) Send guidance to hospital systems with multiple facilities reported on their 941s that they should retain general ledger detail reconciliations to support the funds received. 2) Request the hospital involved in the exception cited for not having submitted general ledger evidence submit additional support for the reconciliation they submitted. 3) Should a similar tranche of funds become available in the future, AlaHA will ensure disbursements are not made before receipt of general ledger evidence to support the amount reported by the hospital. Target Date: For items 1 & 2 in the corrective action plan, November 6, 2023.
2023-002 - Expenditure Controls - Significant Deficiency The District agrees that while significant progress has been made in this area, there is still work to do regarding the pre-authorization of purchases. The Business Manager has held meetings with each building and department individually to co...
2023-002 - Expenditure Controls - Significant Deficiency The District agrees that while significant progress has been made in this area, there is still work to do regarding the pre-authorization of purchases. The Business Manager has held meetings with each building and department individually to communicate proper procedures. She has also issued All Staff emails outlining these procedures and referencing board policy supporting these practices. Proper procurement procedure instructions are also available via video through a link on the Business Office Department page of the District website for reference. We recognize that proper training is imperative to compliance in all departments and the Business Office will continue to provide training throughout the year, with an emphasis in departments with new staff.
Management agrees with the finding. The Medical Center’s secondary review control will ensure allowable expenses are being claimed.
Management agrees with the finding. The Medical Center’s secondary review control will ensure allowable expenses are being claimed.
Management agrees with the finding. Controls will be put into place to ensure the lost revenue calculation reported properly includes and excludes all relevant information.
Management agrees with the finding. Controls will be put into place to ensure the lost revenue calculation reported properly includes and excludes all relevant information.
Finding 2023-003 Finding Title: Student Financial Assistance Cluster Name of Contact Person: Traci Boeve, Director of Financial Aid Corrective Action: Hastings College will add additional staff as a control to the current process. The Assistant Registrar and the Office of Financial Aid will be inclu...
Finding 2023-003 Finding Title: Student Financial Assistance Cluster Name of Contact Person: Traci Boeve, Director of Financial Aid Corrective Action: Hastings College will add additional staff as a control to the current process. The Assistant Registrar and the Office of Financial Aid will be included in the receipt of the graduation file. The Assistant Registrar will confirm in NSC (National Student Clearinghouse) the file was uploaded with no errors. The Office of Financial Aid will also request a report from NSLDS, which can be compared to the file that was directly uploaded to NSC. Anticipated Date of Completion: In place for 2023-2024 school year.
Finding 2747 (2023-001)
Significant Deficiency 2023
Correction Action to be Taken: Management will implement controls which ensure parties subject to this requirement are verified as not being present on the suspension and debarment list prior to initiating contracts or payments.
Correction Action to be Taken: Management will implement controls which ensure parties subject to this requirement are verified as not being present on the suspension and debarment list prior to initiating contracts or payments.
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