Corrective Action Plans

Finding 369047 (2023-005)

Significant Deficiency 2023

OK

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of cu...

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Office of Internal Audit is beginning work on another System-wide Information Technology (IT) Penetration Testing and Vulnerability Assessment at all institutions within the OSU/A&M System. They will be coordinating with local IT staff from each institution, as well as the OSU Chief Information Officer, Raj Murthy and the A&M System Chief Information Officer, Heath Hodges, to schedule the work. Name(s) of the contact person(s) responsible for corrective action: Heath Hodges and Kevin Isom, Planned completion date for corrective action plan: March 31, 2024

View Audit 290458

Finding 369043 (2023-004)

Significant Deficiency 2023

Connors State College

OK

Student Financial Aid Internal Control / Segregation of Duties § 200.303

Federal Program Title: Student Financial Aid Cluster (SFA), 240-day limitation on checks ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Recommendation: W...

Federal Program Title: Student Financial Aid Cluster (SFA), 240-day limitation on checks ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Checks will only be re-issued for up to 180 days. A joint effort between the Bursar, Accounting and Financial Aid offices to reach the students via email, phone, and text before the 180-day deadline. After 180 days the check will be voided, and the funds returned. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

Finding 369039 (2023-003)

Significant Deficiency 2023

Connors State College

OK

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

Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dat...

Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Recommendation: We recommend that the student financial aid department works to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Students identified in the weekly reconciliation that have not posted to COD will be highlighted. In the subsequent reconciliation if student still has not been posted in COD the Financial Aid Director will manually post the student to COD as well as fix any errors so that if can be posted. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

Finding 369035 (2023-002)

Significant Deficiency 2023

Connors State College

OK

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

Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 1...

Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from the change Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: At the end of each semester a listing of all graduates will be given to the Financial Aid Office from the Registrar. Financial Aid will then go into NSLDS to manually update graduates status. This process will be done in conjunction with the submittion of graduates to the National Clearinghouse by the Registrar. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

Finding 369002 (2023-003)

Significant Deficiency 2023

Catholic Community Services of the Mid-Willamette Valley, INC

OR

Eligibility Internal Control / Segregation of Duties § 200.303

Recommendation: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statues. Action: The Organization has scheduled regular meetings (twice per month) with the property manageme...

Recommendation: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statues. Action: The Organization has scheduled regular meetings (twice per month) with the property management company to monitor the activities of the provider to ensure we are in compliance with Federal Statues. In addition, twice per year, we will perform an internal audit of each tenant file to ensure compliance.

View Audit 290445

Finding 366925 (2023-002)

Significant Deficiency 2023

Calumet College of St. Joseph

IN

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

The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from N...

The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from Notepad) with the help of the Institutional Research office to ensure that data meets the criteria required by the clearinghouse and is free of errors. The responsibility to ensure that data submitted to the National Clearinghouse and NSLDS remains with the Registrar’s office at CCSJ. The Registrar’s office at CCSJ will review data for accuracy, timeliness, and completeness before uploading to the FTP Clearinghouse site. Furthermore, the Director of Student Financial Services has been added as a secondary administrator to the college’s FTP clearinghouse account in which he and the Registrar will receive alerts generated through the Clearinghouse when reports have been uploaded to the site. The Registrar is the primary party responsible for clearing alerts, but the Director of Student Financial Services will verify that the alerts have been cleared. Responsible officers: Marlena Avalos, Assistant Vice President of Academic Affairs (mavalos@ccsj.edu); Derek Shouba, Vice President of Academic Affairs Estimated completion date: March 31, 2024

View Audit 290098

Finding 366921 (2023-001)

Significant Deficiency 2023

Calumet College of St. Joseph

IN

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

Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform r...

Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform required tests, such as penetration tests and vulnerability assessments to test the safeguards that are in place. CCSJ has named a qualified individual, Tony Kwintera - Director of IT Operations, to oversee the information security program. We are also reaching out to our 3rd party partners to ensure that their data privacy safeguards align with the requirements of the GLBA. Responsible officers: Tony Kwintera, Director of IT Operations (tkwintera@ccsj.edu); Lynn Miskus, Vice President of Business and Finance Estimated completion date: June 15, 2024

View Audit 290098

Finding 366727 (2023-001)

None 2023

Los Angeles Community College District

CA

Questioned Costs Student Financial Aid Eligibility § 200.303

The District believes this error was an isolated incident and the effect is minimal as we performed an extensive review of all nine campuses’ Pell grant award disbursements for the term and found that this was the only similar award. The District will monitor disbursements and will perform reconcili...

The District believes this error was an isolated incident and the effect is minimal as we performed an extensive review of all nine campuses’ Pell grant award disbursements for the term and found that this was the only similar award. The District will monitor disbursements and will perform reconciliation on a monthly basis. Personnel Responsible for Implementation: FA Office and the Central Financial Aid Unit. Position of Responsible Personnel: FA Managers Expected Date of Implementation: Already Implemented

View Audit 289733 Questioned Costs: $1

Finding 366611 (2023-002)

Significant Deficiency 2023

Eastern Oregon University

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are r...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EOU’s third party vendor, National Student Clearinghouse, has notified EOU of an additional reporting tab where a list of students who were on our degree report that was submitted, but for various reasons did not have a “Graduate” status applied to their record can be obtained. The Registrar’s office will access the report and manually update the student’s record. Moving forward, after our degree file is processed each term, we will review the students listed in this tab and manually update their status to match our records, so they will correctly and timely report to the National Student Loan Data System. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt Planned completion date for corrective action plan: February 9, 2024

View Audit 289516

Finding 366610 (2023-001)

Significant Deficiency 2023

Eastern Oregon University

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review the 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. Explan...

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review the 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: Upon discovering that a student’s remaining Pell Grant LEU had not been rolled forward to the next term, it was immediately recalculated and disbursed. The process for calculating Pell is done in batch after each term has ended. Financial aid has added a reminder once per term to verify internally that the process has been run for the previous term, and any students with low LEU get their remaining eligibility rolled forward. If it has not been run, monitoring will continue until it is completed. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: March 22, 2024.

View Audit 289516

Finding 366587 (2023-001)

Significant Deficiency 2023

Womenventure

MN

Reporting Matching / Level of Effort / Earmarking § 200.303

Finding: Reporting: Internal Controls Condition: This finding, a significant deficiency in internal control, stated that for the two quarters tested, the CFO was preparing and signing the Technical Assistance reports but supervisory review of the completed reports was not performed prior to submissi...

Finding: Reporting: Internal Controls Condition: This finding, a significant deficiency in internal control, stated that for the two quarters tested, the CFO was preparing and signing the Technical Assistance reports but supervisory review of the completed reports was not performed prior to submission to the Small Business Administration. Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding. • A new internal control process for the review of Technical Assistance reports will be developed and documented. This process should outline the specific steps and responsibilities for supervisory review. • All personnel involved in the preparation and review of Technical Assistance reports will receive training on the grant report preparation process. • Going forward, Technical Assistance reports shall only be submitted to the SBA after they have undergone the required supervisory review. Responsible Official: Karla Dross, CFO is responsible for ensuring the successful implementation of this corrective action plan. Completion Date: The implementation of the corrective action plan shall commence immediately and should be completed within 90 days from the date of this plan. Ongoing monitoring and reporting procedures will continue indefinitely.

View Audit 289423

Finding 366498 (2023-009)

Significant Deficiency 2023

New Mexico Highlands University

NM

Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.320

Recommendation: The Auditor recommends that the procurement policy be updated to comply with all relevant federal procurement requirements and reviewed for necessary revisions regularly. Action Taken: The HEERF award should have been setup as a restricted fund. Going forward, all grants and contrac...

Recommendation: The Auditor recommends that the procurement policy be updated to comply with all relevant federal procurement requirements and reviewed for necessary revisions regularly. Action Taken: The HEERF award should have been setup as a restricted fund. Going forward, all grants and contracts will be classified as a restricted fund and federal compliance will be followed if it is applicable. Due Date of Completion: Done Responsible Official: Stephanie Gonzales – VPFA/Comptroller and Office of Research and Sponsored Projects

View Audit 16132 Questioned Costs: $1

Finding 11924 (2023-004)

Material Weakness 2023

Perham Hospital District

MN

Material Weakness Reporting Internal Control / Segregation of Duties § 200.303

Finding 2023-004 Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Organization utilized net revenues and gross revenues in the lost reven...

Finding 2023-004 Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Organization utilized net revenues and gross revenues in the lost revenue calculation causing errors in the lost revenue calculation which resulted in key line items being reported incorrectly in the Period 4 HHS Report. Corrective Action Plan: Management will correct the lost revenue calculation using budgeted net revenues to actual net revenues. The HHS report will be corrected on the next required report to HHS, if applicable. Management will enhance internal control procedures around the secondary review of the HHS Report to ensure all key line items are properly supported. Responsible Individuals: Justine Anderson, CFO Anticipated Completion Date: October 31, 2023

View Audit 15889

Finding 11923 (2023-003)

Material Weakness 2023

Perham Hospital District

MN

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

Finding 2023-003 Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Organization selected option iii to calculate lost revenue using budget...

Finding 2023-003 Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Organization selected option iii to calculate lost revenue using budgeted net revenues to actual net revenues. The Organization utilized net revenues for part of the calculation and then utilized gross revenues in later quarters. This inconsistency of net and gross revenues caused a miscalculation of the Organization’s total lost revenue. Corrective Action Plan: Management will correct the lost revenue calculation using budgeted net revenues to actual net revenues. Management will enhance internal control procedures around the secondary review of the lost revenue calculation. Responsible Individuals: Justine Anderson, CFO Anticipated Completion Date: October 31, 2023

View Audit 15889

Finding 11916 (2023-001)

Significant Deficiency 2023

Murphy Elementary School District No. 21

AZ

Special Tests & Provisions Cash Management Reporting § 200.303

Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Linda Cordova, Business Manager Anticipated Completion Date: December 1, 2023 Planned Corrective Action: The food service liaison is responsible for submitting meal claims...

Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Linda Cordova, Business Manager Anticipated Completion Date: December 1, 2023 Planned Corrective Action: The food service liaison is responsible for submitting meal claims and verifying meal that counts agree with the supporting documentation. Supporting documentation will be retained in the Business Services Department.

View Audit 15863

Finding 11883 (2023-001)

Significant Deficiency 2023

Goodwill of the Olympics & Rainier Region

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303

Contact Person(s): Program Staff: Eu-wanda Eagans Candice Dickason JoLynn Dunavant Gayle Mitchell Kwaji Miller Brinda Wood Fiscal Staff: Anne Porter Ken Gibbon Stephanie Staylen Nanette Smith Corrective Action Planned for finding that 2 of 13 participants tested did not have annual recertifications ...

Contact Person(s): Program Staff: Eu-wanda Eagans Candice Dickason JoLynn Dunavant Gayle Mitchell Kwaji Miller Brinda Wood Fiscal Staff: Anne Porter Ken Gibbon Stephanie Staylen Nanette Smith Corrective Action Planned for finding that 2 of 13 participants tested did not have annual recertifications of household income performed during the period under audit. • Assistant Program Manager to complete missing recertification paperwork and documents for the recertification of the participant still active in the SCSEP program by 2/29/24. The second participant has since exited the SCSEP program. To complete the missing recertification requires self-disclosure from the participant of the household income. To contact this person in order to update the recertification paperwork, by 3/15/24 we will: • Reach out via phone and email. • Reach out via letter to the last address of record. • Update the recertification based on information received or document actions taken to recertify if contact attempts have failed. • All SCSEP staff to review all remaining SCSEP participant files for required documents and ensure that we are in compliance of SCSEP rules and regulations. Update files if needed. Half of the files will be reviewed by 3/15/24. The other half will be complete by 4/30/24. • Quarterly internal review by Assistant Program Manager of 5 random files of SCSEP participants for file compliance with SCSEP rules and regulations. Conduct through 12/31/24 to ensure program compliance. • Finance Department to schedule Clark Nuber CPAs to conduct a technical training on grant documentation compliance requirements for both Finance and Workforce Development staff. Plan for training to take place prior to 4/30/24.

View Audit 15778

Finding 11879 (2023-003)

Significant Deficiency 2023

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Reporting § 200.303

Higher Education Emergency Relief Funds - Institutional Portion – Assistance Listing No. 84.425E and 84.425F Recommendation: Recommendation for the College to review its review process for these reports and implements a reconciling process between the report and the supporting documentation to make ...

Higher Education Emergency Relief Funds - Institutional Portion – Assistance Listing No. 84.425E and 84.425F Recommendation: Recommendation for the College to review its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Person compiling report will have two staff review report prior to submission and posting. Name(s) of the contact person(s) responsible for corrective action: Leigh FitzHenry Planned completion date for corrective action plan: 11/30/2023

View Audit 15771

Finding 11831 (2023-001)

Significant Deficiency 2023

George C. Wallace Community College - Dothan

AL

§ 200.303

Single Audit Findings Item 2023‐001 – Allowable Costs/Activities Contact person: Marc Nicholas, Dean of Business Affairs Management’s Response – The College will strictly adhere to its policy of obtaining current executed contracts or agreements for all employees under the program, prior to payme...

Single Audit Findings Item 2023‐001 – Allowable Costs/Activities Contact person: Marc Nicholas, Dean of Business Affairs Management’s Response – The College will strictly adhere to its policy of obtaining current executed contracts or agreements for all employees under the program, prior to payment of the employee. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before 1/31/24.

View Audit 15659

Finding 11513 (2023-001)

Significant Deficiency 2023

Rural Health Redesign Center Organization

PA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.303

Contact person responsible for corrective action: Gerry Egan, Fiscal Finance Manager Contact phone number: (610) 944-2119 Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with under co...

Contact person responsible for corrective action: Gerry Egan, Fiscal Finance Manager Contact phone number: (610) 944-2119 Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Description of Corrective Action Plan: Currently, the Organization requires all new vendors to complete the attached “Vendor Registration Form”. On page 5 the vendor acknowledges they have not or are currently not suspended and debarred. A new step that Procurement implemented as of November 21, 2023 was verification of vendor’s status on sam.gov and attaching the screenshot to the supporting documentation. The Organization will also create a specified procurement policy that outlines these steps to ensure that vendors are suspended or debarred. Completion Date: November 21, 2023

View Audit 15344

Finding 11332 (2023-002)

Significant Deficiency 2023

Unified School District Number 494

KS

Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding 2023-002 Recommendations: The District should have an employee compare the third party’s equipment inventory records with the financial records for completeness. An employee should also be present during the physical equipment inventory each year and maintain records of proof for its occurre...

Finding 2023-002 Recommendations: The District should have an employee compare the third party’s equipment inventory records with the financial records for completeness. An employee should also be present during the physical equipment inventory each year and maintain records of proof for its occurrence. Lastly, the current inventory records should also be altered in order to be maintained with information required by 2 CFR section 200.313(d)(2) that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data of disposal and sales price of the property. Action Taken: We agree with the recommendation. Our targeted implementation date is June 2024.

View Audit 15163

Finding 11331 (2023-001)

Significant Deficiency 2023

Unified School District Number 494

KS

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

Finding 2023-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the r...

Finding 2023-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2024.

View Audit 15163

Finding 11294 (2023-001)

Significant Deficiency 2023

Horizons for Homeless Children

MA

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

2023-001 - Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program: 93.596 and 93.575 Child Care Development Fund (CCDF) Cluster Responsible Official Sharon Fuller, CFO Plan Detail The Organization will implement a quarterly audit process whereby a person in a superv...

2023-001 - Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program: 93.596 and 93.575 Child Care Development Fund (CCDF) Cluster Responsible Official Sharon Fuller, CFO Plan Detail The Organization will implement a quarterly audit process whereby a person in a supervisory capacity will verify completion and signatures of the Child Care Subsidy Application and Fee Agreements. Anticipated Completion Date June 30, 2024

View Audit 15151

Finding 11248 (2023-004)

Significant Deficiency 2023

College of Lake County

IL

Questioned Costs Student Financial Aid Equipment & Real Property Management § 200.303

Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bl...

Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bliley Act (GLBA) known as the “Safeguards Rule” by June 9, 2023. Corrective Action Taken or Planned: The College will create a readily accessible written information security program document outlining all standards to meet and maintain compliance with the GLBA. While the College has not yet formally adopted an information security program, they have demonstrated substantial compliance with the required elements under the Gramm-Leach Bliley Act, including: • Development and implementation of risk assessment frameworks that include penetration testing (16 C.F.R. 314.4(b)); • Adoption of a cybersecurity roadmap and various College policies based on internationally recognized NIST standards (16 C.F.R. 314.4(c)); • Regular testing and monitoring of the effectiveness of the safeguards currently implemented (16 C.F.R. 314.4(d)); • Implementation of policies and procedures to ensure personnel can enact safeguards that should be formally included in the information security program (16 C.F.R. 314.4(e)); • Adoption of procedures and policies for the evaluating and adjusting the safeguards that have been implemented, including monthly vulnerability scans accompanied by a remediation plan for any vulnerabilities identified (16 C.F.R. 314.4(g)); • Creation of a Cybersecurity Incident Response Plan (16 C.F.R. 314.4(h)); and • Annual training and reporting for the College’s Board of Trustees on cybersecurity safeguards (16 C.F.R. 314.4(i)). The Director of Cybersecurity and the Chief Information Officer are designated as the responsible parties for oversight and implementation of the program. Anticipated Completion Date: June 30, 2024 Responsible Person: Allison Porterfield-Woods, Chief Information Officer

View Audit 15031 Questioned Costs: $1

Finding 11245 (2023-003)

Significant Deficiency 2023

College of Lake County

IL

Questioned Costs Subrecipient Monitoring Cash Management § 200.303

Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence...

Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence, grants transactions will be reviewed by the Principal Investigator/Program Director, the Strategic Advancement unit, and the Finance Office for allowability and alignment with the grant’s performance period. Anticipated Completion Date: This process has already been implemented by the College. Responsible Persons: Nick Branson, Assistant Vice President for Strategic Advancement Jean Stephan, Controller

View Audit 15031 Questioned Costs: $1

Finding 11244 (2023-002)

Significant Deficiency 2023

College of Lake County

IL

Reporting Subrecipient Monitoring § 200.303

Identifying Number: 2023-002 Finding: The College did not publicly post a certain required report timely. The following instance of noncompliance was identified: • HEERF Institutional Portion and MSI: The College posted a report to their website on October 23, 2023, for the period of April 1, 2...

Identifying Number: 2023-002 Finding: The College did not publicly post a certain required report timely. The following instance of noncompliance was identified: • HEERF Institutional Portion and MSI: The College posted a report to their website on October 23, 2023, for the period of April 1, 2023 – June 30, 2023, which was 110 days after the required deadline of July 10, 2023. Corrective Action Taken or Planned: The FY2023 Q2 report was completed by the College and posted on the website. Due to transition in personnel overseeing the quarterly reporting deadline, the initial due date for this report passed before the College completed its report. The College completed its reporting and public posting before the HEERF closeout deadline as specified in the Department of Education’s Closeout Liquidation Letter. Anticipated Completion Date: This process has already been implemented by the College Responsible Person: Nick Branson, Assistant Vice President Strategic Advancement Jean Stephan, Controller

View Audit 15031

Corrective Action Plans

Filters