Corrective Action Plans

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The County does check Sam.gov for suspension and debarment transactions. Documentation was retained but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
The County does check Sam.gov for suspension and debarment transactions. Documentation was retained but was lost due to a network intrusion. We will remain diligent in documenting our reviews.
Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent ...
Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent upon packaging which includes type of loan offered, amount, and semester. The loan offer also includes instructions on how to accept the loan and links to resources such as loan interest rates, promissory notes, entrance counseling and how to access loan history via NSLDS. If students choose to accept the loan(s), a loan acceptance notification is sent. This notification includes type of loan, amount, and semester. It also includes right to cancel information, cancellation procedures and instructions on accessing loan history. Loan acceptance notifications are sent nightly upon acceptance. The timing of the loan offer and acceptance notifications is based on when the student completes their financial aid file and is packaged, and when they accept their loan(s) but does not correspond with the actual loan disbursement. UNM has been relying on the loan offer and acceptance notifications and COD disbursement notifications to convey the loan disbursement notification information as required per 34 CFR 668.165. Effective immediately, UNM will establish an internal process to send loan disbursement notifications within 30 days of the actual loan disbursement. The internal process will duplicate our current offer and acceptance notifications. UNM will continue to opt in to COD disbursement notifications as a secondary method of communication. Contact Person: Elizabeth Jacquez-Amador Anticipated Completion Date: October 31, 2023
Finding 10633 (2023-001)
Significant Deficiency 2023
Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College rev...
Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Dr. Deokhyo Kim, Registrar Planned Corrective Action: We communicated with our software vendor, Aptron, to determine what caused the enrollment reporting issues. We identified two issues and worked with Aptron to put measures in place so that these issues do not happen in the future. 1. Missing withdrawn students who were not pulled up by system when they withdrew before or on the 1st enrollment report date. APTRON fixed the programming and the system now pulls those who are withdrawn before or on the 1st enrollment report date for each semester. 2. Missing graduates with their 2nd degree. APTRON fixed the programming, so that our Degree Verify file will now report a student who has earned a second degree with us. A Degree Verify File of graduates was submitted to the NSCH for any student who had earned a second degree not previously reported. Anticipated Completion Date: Fixes with our software vendor have been completed.
2023-006: Unallowable Costs Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review. Action taken in response to finding: Incorrectly charged amounts will be journalled to the correct account in 2023-24. All future grant related p...
2023-006: Unallowable Costs Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review. Action taken in response to finding: Incorrectly charged amounts will be journalled to the correct account in 2023-24. All future grant related payroll expenses will be reviewed by the finance/fiscal team and management. Name of the contact person responsible for corrective action: Susan Wheat, Vice President of Finance and Administration Planned completion date for corrective action plan: January 2024
2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Dir...
2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Director of Information Security and Special Projects position with an Interim placement effective February 1, 2024, to provide leadership in developing, implementing, and maintaining the District’s Information Security Policy including the seven elements required by the Gramm-Leach-Bliley Act. Names of the contact person responsible for corrective action: James “Kimo” Calilan, Director – Information Systems Planned completion date for corrective action plan: April 30, 2024
2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures use...
2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.
2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting proc...
2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: Spring 2024
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of...
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of it in July 2023. Refresher training occurred during August 2023 and we have added members to the R2T4 calculation team in December 2023 in hopes of spreading workload and allowing more time to complete calculations and returns before the relevant deadlines. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: January 2024
2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather th...
2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather than the cumulative number that includes transfer units, when awarding a student in our small BS Biotechnology program. Student had completed 43.5 credits at Solano by the beginning of the aid year. As a result, the student was awarded a second-year subsidized amount when they were eligible for the third year and beyond amount. This resulted in the student receiving $1,000 less subsidized loans than they were eligible for. In July 2023, we trained the team to watch for this issue and evaluated the procedure log that we use for processing Direct Loans. This log now includes two checks that are relevant to ensuring subsidized loan amounts are correct: 1. Confirm the level of the student. If the student is in our BS Biotechnology program, they may have additional eligibility than the standard first-year and second-year loans that we normally process as a community college. 2. If the loan is a single-term loan, is the full subsidized eligibility exhausted before awarding any unsubsidized loan amounts? The student’s file was corrected on COD on 8/3/2023 to reflect a $5,500 subsidized award. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: August 2023
View Audit 14106 Questioned Costs: $1
Finding 10419 (2023-002)
Significant Deficiency 2023
The County has put adopted new procedures within the Accounts Payable County Procedures Manual to actively verify vendors for eligibility utilizing the SAM exclusion database system. Procedure will include a printed copy of the search that will be signed and dated by the employee conducting the sea...
The County has put adopted new procedures within the Accounts Payable County Procedures Manual to actively verify vendors for eligibility utilizing the SAM exclusion database system. Procedure will include a printed copy of the search that will be signed and dated by the employee conducting the search. Document will be attached to the vendor file and the transaction that initiated the search.
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: Th...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There i...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disag...
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is now appropriately staffed and extra time will be taken to ensure NSLDS is being reviewed prior to loan origination. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleysne & Layla Solar Planned completion date for corrective action plan: Completed
Student Financial Aid Cluster – Assistance Listing No. 84.268 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: The...
Student Financial Aid Cluster – Assistance Listing No. 84.268 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: The financial aid office and student accounts office will work together to clearly communicate the timing of aid being applied to student accounts and being reported to COD to ensure both actions are happening on the same day. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed
Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement wi...
Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All ESF funds were expended as of June 30, 2023, so there is no continuing reporting requirement. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed
A procedure has been established and in place for future awards involving sub-recipients. The College closely monitors grant activity to ensure compliance with underlying grant provisions and notes that there is no financial exposure to the College or the granting agency.
A procedure has been established and in place for future awards involving sub-recipients. The College closely monitors grant activity to ensure compliance with underlying grant provisions and notes that there is no financial exposure to the College or the granting agency.
The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in pl...
The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.
Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN#421030129 Federal Financial Assistance Listing #93.498 Compliance Requirement: Acti...
Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN#421030129 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Finding Summary: The Hospital did not retain evidence of the review and approval of the expenditure listing and lost revenue calculation by a separate individual outside of the preparer. In addition, the Hospital's special report submitted to the Department of Health and Human Services for Period 4 TIN #421030129 did not have evidence that it was reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Michael Coyle, CEO Corrective Action Plan: Management agrees with the finding. Controls will be put into place to ensure review and approval by a separate individual outside of the preparer is retained. Anticipated Completion Date: November 30, 2023
Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN#421030129 Federal Financial Assistance Listing #93.498 Compliance Requirement: Repo...
Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN#421030129 Federal Financial Assistance Listing #93.498 Compliance Requirement: Reporting Finding Summary: The Hospital selected option II to calculate lost revenue, which consists of a comparison of actual results during the period of availability to the approved budget. The Hospital did not have a budget for the entire reporting period that was approved prior to March 27, 2020. For the periods that the client did not have an approved budget, $0 was entered for net patient revenues even though there were patient revenues for this period. Responsible Individuals: Michael Coyle, CEO Corrective Action Plan: Management agrees with the finding and notes that there was no impact to the calculation or end results. Should this type of calculation be required in the future, controls will be put into place to ensure the reporting is complete. Anticipated Completion Date: November 30, 2023
Finding Number: 2023-005 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grant...
Finding Number: 2023-005 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
Finding Number: 2023-004 and 2022-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/r...
Finding Number: 2023-004 and 2022-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
U.S. Department of Education 2023-001: Special Tests and Provisions - National Student Loan Data System (NSLDS) Reporting Condition: Student’s change in enrollment status was not properly reported to National Student Loan Data System (NSLDS). Recommendation: We recommend the College review its repor...
U.S. Department of Education 2023-001: Special Tests and Provisions - National Student Loan Data System (NSLDS) Reporting Condition: Student’s change in enrollment status was not properly reported to National Student Loan Data System (NSLDS). Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses and enrollment information are correctly and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College worked with the National Student Clearinghouse (NSC) to correct and update the students’ statuses to graduation. Per the recommendation of the NSC Audit Resource Division, the College will now add an additional graduate only file to the enrollment verify file and submit the degree verify file after the enrollment graduate file had been submitted. After these reports are run any students who are still being put on the graduate not applied list will be manually updated by the Registrar Office. Name of the contact person responsible for corrective action: Courtney Mitchell, Registrar Planned completion date for corrective action plan: November 30, 2023
Finding Number: 2023-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the ...
Finding Number: 2023-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
Finding Number: 2023-004 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grant...
Finding Number: 2023-004 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
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