Corrective Action Plans

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Finding 2024-004 – Child Nutrition Cluster – Special Tests and Provisions – Paid Lunch Equity Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action...
Finding 2024-004 – Child Nutrition Cluster – Special Tests and Provisions – Paid Lunch Equity Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will complete the Paid Lunch Equity spreadsheet, provide the spreadsheet and all supporting documents to the controller for review. Once approved, it will be submitted to the Indiana Department of Education. The supporting documents will either be scanned in or paper documents will be retained for future audit. Anticipated Completion Date: November 19, 2024
Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educationa...
Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025
Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will p...
Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will pull the End of Day Summary Reports from Lunchtime and input the information into the Child Nutrition Portal. All reports will be provided to the controller to confirm accuracy. Once reviewed and approved, the food service director will submit the report through the Child Nutrition Portal. All documents will be scanned together and be retained for audit. Anticipated Completion Date: October 2, 2024
View Audit 329409 Questioned Costs: $1
Finding 2024-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: School corporation personnel w...
Finding 2024-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: School corporation personnel will conduct an annual review of the income eligibility guidelines used by the food service software. The review will ensure that the guidelines are current, accurate, and consistent with federal and state requirements. The results of the review will be documented, and any necessary updates or changes will be implemented promptly. Anticipated Completion Date: November 13, 2024
Finding 509710 (2024-003)
Significant Deficiency 2024
Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...
Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024
Finding 509709 (2024-002)
Significant Deficiency 2024
Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...
Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024
View Audit 329370 Questioned Costs: $1
Finding 509708 (2024-001)
Significant Deficiency 2024
Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the acad...
Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the academic year are being reported on a timely basis Financial Aid Office will manually check and enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates Financial Aid Office and Registrar’s Office have been continually working together to ensure timely and accurate reporting of withdrawal dates. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1.     We will ensure a signature and date are included on all paperwork needing review and approval going forward. ...
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1.     We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.2.     All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If ...
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.
Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for ...
Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Condition - During our testing for Reporting, it was noted that 2 out of 2 reports selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbur...
Condition - During our testing for Reporting, it was noted that 2 out of 2 reports selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and_ date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, ...
Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due...
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due diligence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For 22-23, the third-party servicer provided the compliance report in March 2024. For 23-24, the third-party servicer states the report should be available by the end of December 2024. Name(s) of the contact person(s) responsible for corrective action: Michael Dorner Planned completion date for corrective action plan: Already in place
Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University review its current procedures for awarding Title IV funds a...
Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has reviewed its current procedures for awarding Title IV funds and modified edit reports to find Pell-eligible students who had previously been inactivated or not yet awarded for an aid period to be reviewed and awarded accordingly. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Planned completion date for corrective action plan: 09/18/2024
Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.033, 84.268, 84.063, 84.007 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend that the University implement proced...
Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.033, 84.268, 84.063, 84.007 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters 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. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: The Office of the Registrar is following the best practices for reporting official withdrawals. We are recording the actual withdrawal date initiated online by the student. We do not have a problem in recording unofficial withdrawals taken from Moodle (as determined by Financial Aid) as long as there is a consensus from Enrollment Management on changing the practice used. I suggest the Financial Aid, Registrar, and Enrollment Management get together to determine the best course of action. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: 09/01/2024
Procurement Federal Program Title: Research & Development Cluster Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to do...
Procurement Federal Program Title: Research & Development Cluster Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for obtaining competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Accounting and Purchasing will both review requisitions within Jaggaer to make sure appropriate bids, and or exemptions are documented or attached. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024
View Audit 328453 Questioned Costs: $1
Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its...
Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton , Director of Grant Accounting. Planned completion date for corrective action plan: Implemented for FY25
Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional contr...
Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 suspension and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be initiated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. We are also adding the S&D clause to all contracts. Name(s) of the contact person(s) responsible for corrective action: : Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024
2024-003 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The Dis...
2024-003 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The District did not have adequate internal controls in place to ensure that all certified Payrolls were obtained or reviewed for both the contractor and subcontractor, so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure Compliance. Grants Dept. personnel met with Capital Construction and Procurement Personnel to discuss the processes and procedures to implement, and internal controls that would ensure this. The District’s Grants Department will: 1. Require departments/teams utilizing federally funded grants which involve construction/labor, to designate two staff members responsible for collection of wage-rate payroll certifications. 2. Conduct a meeting/training that involves all responsible parties, prior to any work being done, to establish processes/procedures to obtain, track, monitor, and review certified payrolls and compare them to prevailing wage rates. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Review of process began in October 2024. Adjustments and revisions to initial processes will be made as needed, but will be completed by June 30, 2025.
2024-002 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The D...
2024-002 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. The inadequate internal controls that caused the inconsistency in supporting payroll information involved the End-of-Year Closeout process. The District will ensure End-of-Year Closeout procedures are up to date and adhered to. These procedures will include a second review of calculations used to determine the expenditure amount in accruals, to ensure it recalculates. The District will also conduct a second review of the supporting detail used to determine Indirect Costs to ensure they are consistent with CDE recommendations and District policies and procedures. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Review of department End-of Year Closeout process began in September 2024. Adjustments and revisions will be made to these processes as needed, prior to End-of-Year Closeout, June 30, 2025.
View Audit 328203 Questioned Costs: $1
Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originat...
Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehe...
The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
Finding 505309 (2024-001)
Significant Deficiency 2024
Planned Action: Family Pathways Food Access and Finance staff will communicate the audit finding to the appropriate authoritative TEFAP bodies: the Minnesota Department of Human Services, as administrator of Minnesota’s TEFAP program and issuer of Minnesota’s TEFAP Policy and Operations Manual, as w...
Planned Action: Family Pathways Food Access and Finance staff will communicate the audit finding to the appropriate authoritative TEFAP bodies: the Minnesota Department of Human Services, as administrator of Minnesota’s TEFAP program and issuer of Minnesota’s TEFAP Policy and Operations Manual, as well as Second Harvest Heartland, as pass-through agent and contractor of TEFAP food distribution. In addition to communicating the audit finding, Family Pathways will confirm what authorities exist for Family Pathways, as a TEFAP provider, to implement additional internal controls, including but not limited to: modifying current DHS TEFAP forms and applications, and/or requiring additional client application forms. Family Pathways would like to note that the current DHS TEFAP Policy and Operations Manual 2023, effective for the audit period indicated above, states that “additional eligibility criteria cannot be imposed on participants” and that “TEFAP Providers agree to make it as easy as possible for those in need to access food.”
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: C...
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review, revise and implement procedures for cost of attendance, award packaging, and R2T4, in addition to the review of the process of all monthly reconciliations related to Pell, Direct Loans, SEOG and FWS along with G5 drawdowns annotated and reconciled with the Finance Department. The 2024-2025 year has started off with a strong process to avoid these findings. The Director of Financial Aid & Scholarships is in communication with NASFAA about policy and procedure development services. All Policies & Procedures (P&P) will be revised and updated to reflect processes within the new student information system. In February of 2025 a proposal will be made for an additional staff member for a total of four full-time staff members in the Financial Aid & Scholarships department. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: Ongoing
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