Corrective Action Plans

Finding 43070 (2022-003)

Significant Deficiency 2022

KY

Allowable Costs / Cost Principles Reporting § 200.302 § 200.303 § 200.328 § 200.329 § 200.502

County Judge/Executive?s Response: The fiscal court would like to point out that ARPA funds were properly distributed. During this time there was little guidance on how to manage the reporting. All reporting has been corrected.

View Audit 44179

Finding 43013 (2022-001)

Significant Deficiency 2022

Council of Western State Foresters

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Management Response and Planned Corrective Action We concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures. Views of Responsible Officials and Corrective Actions The managem...

Management Response and Planned Corrective Action We concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures. Views of Responsible Officials and Corrective Actions The management team of the Council of Western State Foresters believe in the values of transparency, justification, and documentation for the transactions made while conducting organizational duties, whether funded by federal sources or otherwise. As a small organization with limited staff, suggested reasonable improvements to processes are always welcome. It is in this spirit that the below corrective actions to address the findings and questioned costs noted on the 2022 Single Audit. Corrective Action Plan: 1. The organization?s credit card and the credit card held in the name of the Executive Director are currently one and the same. All credit card transactions are reviewed no less than monthly, and any staff usage of the credit card requires and secures pre-approval. Going forward, the CWSF Credit Card Usage Policy will be adjusted to provide clarity regarding credit card usage by staff and reflect the review process. With any staff usage of the credit card, documentation will be made of pre-approval along with receipt documentation of the purchase. Purchases made by staff will be documented as authorized by the Executive Director. 2. While approvals for these expenditures did occur per both the credit card usage and travel policies, the documentation was not attached with the corresponding receipt. In future, written emails or other approval documenting necessary authorization will be included with the corresponding receipts in the organizational and financial records. 3. Following the discovery of 1 income I-9 in staff personnel files during the course of the audit, a thorough review of all personnel files has already been undertaken to ensure that no other files are missing critical documentation, including I-9s and corresponding proof of identification. Moving forward, all personnel documentation for current and future staff will be maintained in hard copy as well as in electronic form and will be maintained in accordance with legal requirements for document retention.

View Audit 39962 Questioned Costs: $1

Finding 43009 (2022-004)

Significant Deficiency 2022

Northwood Deaconess Health Center

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2022-004 Federal Agency Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no informal documented review over the reserve fund reconciliation for the federal program. Responsible Individuals: Pete Antonson, CFO Corr...

Finding 2022-004 Federal Agency Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no informal documented review over the reserve fund reconciliation for the federal program. Responsible Individuals: Pete Antonson, CFO Corrective Action Plan: We have adopted a policy to enhance internal control to ensure the reserve fund reconciliation has a secondary review and approval that is documented. Anticipated Completion Date: October 30, 2023

View Audit 39287

Finding 42958 (2022-001)

None 2022

Commissioners of St. Mary's County

MD

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

Finding 2022-001 Planned Corrective Action: The grant management duties will be assigned to more than one person to avoid late reports being submitted in the future. Additionally, more than one staff member in Department of Public Works (DPWT) will have the ability to submit reports in the event th...

Finding 2022-001 Planned Corrective Action: The grant management duties will be assigned to more than one person to avoid late reports being submitted in the future. Additionally, more than one staff member in Department of Public Works (DPWT) will have the ability to submit reports in the event the lead grants manager is unavailable. If future reports are expected to be late, the Deputy Director of Finance will be notified as to why the report is late. Name of Contact Person: James Gotsch, Director/Department Head Anticipated Completion Date: The above actions will be implemented before the next quarterly report is due ? by April 30, 2023. The additional assigned staff member(s) for the above noted responsibilities will be reported to the Deputy Director of Finance and Chief Financial Officer by April 30, 2023.

View Audit 43882

Finding 42954 (2022-002)

Significant Deficiency 2022

Flagler College, Inc.

FL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-002 Educational Stabilization Fund ? Reporting ? HEERF reporting requirements. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the ...

2022-002 Educational Stabilization Fund ? Reporting ? HEERF reporting requirements. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Flagler is in the process of hiring a dedicated Grants & Compliance Manager that will be responsible for organizing and submitting reporting requirements moving forward. In the meantime, preparing of reporting will be completed, reviewed and published by current accounting personnel based on a reporting schedule created upon review of the award documents and related standards. Name(s) of the contact person(s) responsible for corrective action: Stacey Matthews and Tiffany Moore Planned completion date for corrective action plan: March 23, 2023

View Audit 40194

Finding 42944 (2022-003)

Material Weakness 2022

Manchester Community Schools

MI

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

FINDING 2022-003 Contact Person Responsible for Corrective Action: Darla Cain Contact Person Number: 260-982-7518 Views of Responsible Official: We concur with the findings. COVID-19 Education Stabilization Fund: Manchester Community Schools has established new controls for the mentioned above findi...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Darla Cain Contact Person Number: 260-982-7518 Views of Responsible Official: We concur with the findings. COVID-19 Education Stabilization Fund: Manchester Community Schools has established new controls for the mentioned above finding. The assistant business manager will prepare and print the reports. The treasurer will review the financial reports for accuracy. The treasurer will sign off on accurate documents and will file the paperwork for future reference. Anticipated Completion Date: The new internal controls will begin February 2023 and continue according to the grant schedule.

View Audit 39147

Finding 42913 (2022-003)

Material Weakness 2022

Hegg Memorial Hospital D/b/a Hegg Health Center

IA

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2022-003 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center?s fiscal year 2023 operating budget was not submitted during the period under audit and prior year audited financial statements we...

Finding 2022-003 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center?s fiscal year 2023 operating budget was not submitted during the period under audit and prior year audited financial statements were not submitted to USDA until USDA requested them, which was subsequent to the submission timeframe. Responsible Individual: Bill Slater, Chief Financial Officer Corrective Action Plan: A copy of the budget will be sent to USDA as soon as it is approved by the board and has been added to the year end procedures checklist. The audited financial statements will be provided to USDA upon finalization and within the 150 days of year end. Anticipated Completion Date: December 31, 2022

View Audit 39421

Finding 42884 (2022-004)

Significant Deficiency 2022

St. Luke's Hospital

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: One of the Hospital?s required reserve accounts was underfunded by approximately $45,000. Responsible Individuals: Jody Nelson, ...

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: One of the Hospital?s required reserve accounts was underfunded by approximately $45,000. Responsible Individuals: Jody Nelson, CEO and Megan Peterson, CFO Corrective Action Plan: Proper tracking of all reserve accounts will be put in place in order to make sure they are all properly funded throughout the year. Anticipated Completion Date: 6/30/2023

View Audit 48518

Finding 42864 (2022-001)

Significant Deficiency 2022

City of Evanston, Illinois

IL

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.320 § 200.327

Finding 2022-001 Procurement, Suspension and Debarment (Repeat Finding 2021-001) Federal Agency: U.S. Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Questioned Cost: N/A Corrective Action: We agree with the auditor?s comments, and a...

Finding 2022-001 Procurement, Suspension and Debarment (Repeat Finding 2021-001) Federal Agency: U.S. Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Questioned Cost: N/A Corrective Action: We agree with the auditor?s comments, and actions stated in the recommendation. The City of Evanston will: a. Implement structures to monitor external procurement service providers to ensure their procurement methods comply with applicable federal compliance requirements by: When using an external procurement services provider, Departments will review and retain procurement method and accompanying support, specifically: method of procurement (Bid, RFP, RFQ), history of procurement and accompanying support. b. Further expand Purchasing Manual to include policies and procedures for suspension and debarment searches and retaining support for suspension and debarment check by: The Purchasing Manual was revised during 2023 to incorporate procedures relating to suspension and debarment checks. The City will expand the Purchasing Manual to require suspension and debarment check support be retained in the vendor file. c. Communicate and reinforce its procurement policies and procedures to ensure compliance with applicable requirements by: Provide revised Purchasing Manual to staff with yearly reminder from Purchasing and Community Development Federal Grants Manager. d. Centralize the procurement process to ensure all departments are following applicable procedures in a uniform manner by: City staff will work with the City?s Purchasing Department to follow and adhere to applicable Procurement procedures. Contact Person: Hitesh Desai, Chief Financial Officer Anticipated Completion Date: December 31, 2023

View Audit 46234

Finding 42793 (2022-006)

Significant Deficiency 2022

Chicago State University

IL

Reporting Internal Control / Segregation of Duties § 200.303

The University has revised processes to ensure that grant reporting requirement are adhered to. 1) Review and enhance processes to ensure accurate and timely reporting.

View Audit 39988

Finding 42789 (2022-005)

Significant Deficiency 2022

Chicago State University

IL

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

The University will revise processes to ensure that notifications are received as required by the Code of federal regulations. 1) Perform a review of (implement enhancements to) current processes to ensure appropriate notification to students.

View Audit 39988

Finding 42786 (2022-003)

Significant Deficiency 2022

Chicago State University

IL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of studen...

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of student files to verify completeness of records.

View Audit 39988

Finding 42782 (2022-004)

Significant Deficiency 2022

Chicago State University

IL

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

The University will perform a risk assessment that is inclusive of the requirements outlined in the GLBA.

View Audit 39988

Finding 42767 (2022-001)

Material Weakness 2022

Town of Shirley

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Teresa Hester ? Clerk/Treasurer Contact Phone Number: 765-738-6381 Views of Responsible Official: We concur with finding: As stated in the Finding 2022-001 this finding is also a finding in the 2021-002. All of the transactions were ...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Teresa Hester ? Clerk/Treasurer Contact Phone Number: 765-738-6381 Views of Responsible Official: We concur with finding: As stated in the Finding 2022-001 this finding is also a finding in the 2021-002. All of the transactions were already complete when the 2021 finding was noted. Difficult to change what already was. Internal controls were in place overall with the Grant Writer, Engineering Firm and Clerk/Treasurer, but the town was not provided with direct access to copies of the semi-annual reports. These reports were not accessible because OCRA does not give all unit?s rights to view. (Not being able to have access is where Government Officials should take into consideration when requiring units to be compliant.) Screen shots of the activity were provided to auditor. Description of Corrective Action Plan: The semiannual and other reporting was the responsibility/authority of our grant management. (Town officials have no log-in rights for the records) For future endeavors moving forward we will be implementing a more efficient internal controls. Collaborating with the grant management in knowing when the reports are being filed and that the Clerk/Treasurer is sent a copy of the reports for review. Anticipated Completion Date: This particular project has been finalized, therefore there is no an anticipated completion date. For future endeavors we will implement a more detailed and diversified internal controls process.

View Audit 39079

Finding 42743 (2022-002)

Significant Deficiency 2022

County of Stanislaus

CA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that that County establish an internal control process for reviewing and approving indirect costs allocated in accordance with Uniform Guidance. Explanation of disagreement with audit finding: There is n...

2022-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that that County establish an internal control process for reviewing and approving indirect costs allocated in accordance with Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Regarding the review of indirect costs, management acknowledges that our internal control documentation fell short of the necessary standards. While the County?s documents effectively track the indirect costs associated with State and Local Fiscal Recovery Funds (SLFRS), management recognize that we were not utilizing the de minimis rate rule calculations as prescribed by federal regulations. Going forward, the County will ensure that the indirect costs are in full compliance with the de minimis rate rule. The County have established robust controls over indirect costs for SLFRS to mitigate any potential discrepancies and ensure that we are in alignment with federal guidelines by tracking the de minimis indirect cost rates using various spreadsheets and review by multiple approvers. Name(s) of the contact person(s) responsible for corrective action: Jian Ou-Yang Planned completion date for corrective action plan: December 31, 2023

View Audit 41890

Finding 42730 (2022-001)

Material Weakness 2022

St. Vincent Charity Medical Center and Subsidiaries

OH

Subrecipient Monitoring Material Weakness Reporting § 200.303

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Depar...

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS June 11, 2021, post-payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Planned Corrective Action: Chief Financial Officer will insure that all guidance available for PRF reporting (FAQ's etc.) is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions. Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: August 1, 2023

View Audit 46954

Finding 42727 (2022-004)

Material Weakness 2022

Greene County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and mainta...

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

View Audit 46952

Finding 42726 (2022-003)

Material Weakness 2022

Greene County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-003 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Secondary Contact: County Attorney, currently Marvin Abshire Secondary Contact Phone Number: 812-384-0081 Views of Responsible Official: We concur with the fin...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Secondary Contact: County Attorney, currently Marvin Abshire Secondary Contact Phone Number: 812-384-0081 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: Corrective action will need to be taken to review the Sam.gov verification website in the future. We will be verifying that current and future Greene County vendors are not barred or suspended on the Sam.gov verification website before using their services. As county attorney is responsible for virtually all contract drafting or approval, county attorney has added to the public works contract checklist the determination whether or not federal funds are used in fulfillment of the contract and if so, that the contract will contain a suspension and debarment paragraph applicable to contractor and subcontractors. Further, should the county submit a request for qualifications for a design-build public works project, attorney will endeavor to assure that the request for qualifications requires information concerning debarment, disqualification, or removal of the design-builder or a team member from a federal, state, or local government public works project. Attorney will perform the sam.gov verification for qualifying contracts or matters implicating suspension and debarment; will date and initial or sign the verification; and will ask his assistant to review the verification and initial or sign and date same. Either a paper copy or a PDF of the confirmed verification will be maintained in the contract file. Heather N. Perry Greene County Auditor Anticipated Completion Date: 09/01/2023

View Audit 46952

Finding 42678 (2022-001)

Significant Deficiency 2022

Florida Living Options, INC

IL

Reporting Internal Control / Segregation of Duties § 200.303

Identifying Number: 2022-001 Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management reviews the reported grant expenditures. Management believes this review process to be adequate.

View Audit 54111

Finding 42676 (2022-002)

Material Weakness 2022

Wabash County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Wabash County Auditor, Marcie Shepherd Contact Phone Number: 260-563-0661 We concur with the finding. Description of Corrective Action Plan: We were unaware that once you elected to receive the funding as the standard revenue loss al...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Wabash County Auditor, Marcie Shepherd Contact Phone Number: 260-563-0661 We concur with the finding. Description of Corrective Action Plan: We were unaware that once you elected to receive the funding as the standard revenue loss allowance that you would still need to verify for the suspension and debarment compliance requirement. Moving forward when a request for funding is being presented to the County Commissioners/Council, Commissioners/Council will require the office that is requesting funding to provide the Auditor?s office with a Suspension and Debarment form which is signed and dated from SAM.gov. The form will be kept in the ARPA binder. Anticipated Completion Date: August 8, 2023

View Audit 54060

Finding 42673 (2022-001)

Material Weakness 2022

Marshall County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Angela C. Birchmeier, County Auditor Contact Phone Number: (574) 935-8555 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County and Auditor?s ...

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Angela C. Birchmeier, County Auditor Contact Phone Number: (574) 935-8555 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County and Auditor?s office were unaware of the requirement that a contract over $25,000 needed verification that the contractor had not been suspended or disbarred. Now that we are aware, each contract will be verified by either checking the EPLS (Excluded Parties List System) or that the clause for disbarment or suspension is included in the contract. The Department requesting the contract will verify if the clause is in the contract. The Claims Deputy will also verify during the claims process for payment and the 1st Deputy will also verify. Anticipated Completion Date: We have already implemented this procedure effective April 2023.

View Audit 54392

Finding 42651 (2022-001)

Significant Deficiency 2022

Cabot Performing Arts Center, INC

MA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management has been making updates to its policies and procedures throughout 2022 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 51333

Finding 42635 (2022-006)

Material Weakness 2022

Chicot Memorial Medical Center

AR

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Finding 2022-06 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible expenses internally within a spreadsheet. The spreadsheet incl...

Finding 2022-06 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible expenses internally within a spreadsheet. The spreadsheet included errors in the calculation of allowable expenditures, which were included on the Period 1 report to the Health Resources and Services Administration (HRSA). Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track expenses are free of errors. Anticipated Completion Date: 3/31/2023

View Audit 47261

Finding 42634 (2022-005)

Material Weakness 2022

Chicot Memorial Medical Center

AR

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Finding 2022-05 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible patient care revenues internally within a spreadsheet. The rev...

Finding 2022-05 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible patient care revenues internally within a spreadsheet. The revenues included in the spreadsheet and on the Period 1 report to HRSA, which were utilized to calculate lost revenues, contained an error. Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track revenue are free of errors. Anticipated Completion Date: 3/31/2023

View Audit 47261

Finding 42629 (2022-001)

Material Weakness 2022

Ivy Tech Community College of Indiana

IN

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements relate...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

View Audit 43389

Corrective Action Plans

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