Corrective Action Plans

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2025-002 Initial Fiscal Year End, 2025 Summary of Finding- During the audit, it was noted the University could not provide support for the last day of attendance to complete the return of Title IV funds for one of the students tested. This lapse in communication between departments led to a variance...
2025-002 Initial Fiscal Year End, 2025 Summary of Finding- During the audit, it was noted the University could not provide support for the last day of attendance to complete the return of Title IV funds for one of the students tested. This lapse in communication between departments led to a variance in the reported last day of attendance, which in turn did not provide a firm last day for calculating return of funding. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The Finance Department will implement a compliance checklist to be used when a student begins the withdrawal process or when their absence becomes noticed. This checklist will comply with the Federal Student Aid handbook. This procedure will ensure compliance between Academic and Financial Aid Departments. This data path will begin with notification of respective departments and initiation by the Academic Department passing to Financial Aid with parallel communication with the Finance Department for compliance and accuracy of dates and ultimately the return of the accurate amount of Title IV funds. Anticipated Completion Date- Feb 28, 2026
2025-001 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe which resulted in non-adherence to the 45-day window. Name and Title of Responsible Cont...
2025-001 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe which resulted in non-adherence to the 45-day window. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The finance department has been building back proper procedures and protocol after experiencing several transitions in key departments. The university will institute a compliance checklist that will ensure adherence to the dates for Title IV funding to be returned. This checklist will have the oversight of the Finance department to ensure that action and calculations are done accurately and in a timely manner adhering to the Financial Aid handbook. Anticipated Completion Date- Feb 28, 2026
Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Explanation of disagreeme...
Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Explanation of disagreement with audit finding: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.403(f). Action planned in response to finding: Corrective action will be taken. The Department revised the policies and procedures for cash disbursements within the Administrative Services Division. Effective immediately, upon running the monthly query of federal expenditures for the cash reimbursement for federal grants, the Federal Financial Analyst will submit the query to the Budget Director and the Accountant/Auditor. A reconciliation to the General Ledger will be completed by them prior to the Federal Financial Analyst requesting the cash reimbursement. Name(s) of the contact person(s) responsible for corrective action: Paul Varela, CFO Planned completion date for corrective action plan: July 31, 2026
Recommendation: We recommend that the Department develop and implement a written policy for leave allocation consistent with federal regulations. Also, we recommend that the Department provides training to ensure employees understand and comply with the written policy. Explanation of disagreement wi...
Recommendation: We recommend that the Department develop and implement a written policy for leave allocation consistent with federal regulations. Also, we recommend that the Department provides training to ensure employees understand and comply with the written policy. Explanation of disagreement with audit finding: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.405(d). Action taken in response to finding: Corrective action was taken. The Department revised the procedures and will no longer charge any type of leave activity to a grant, effective July 1, 2025, and for the foreseeable future. An email was sent out by the CFO on June 26, 2025 advising all Department employees about this change. The Federal Aid Cost Tracking System (FACTS) has also been changed to block access to all grants for any leave time reporting code entries. If a system is developed in the future to enable the allocation of leave consistent will the federal regulations, training will be provided for all employees. Name(s) of the contact person(s) responsible for corrective action: Paul Varela, CFO Planned completion date for corrective action plan: July 31, 2026
February 26, 2026 Federal Awards Finding 2025-001: Child Nutrition Cluster (CFDA 10.553, 10.555) Compliance Requirement - Procurement Condition – The School District made purchases charged to the Child Nutrition Program in excess of $20,000 without obtaining competitive bids as required by the Schoo...
February 26, 2026 Federal Awards Finding 2025-001: Child Nutrition Cluster (CFDA 10.553, 10.555) Compliance Requirement - Procurement Condition – The School District made purchases charged to the Child Nutrition Program in excess of $20,000 without obtaining competitive bids as required by the School District’s procurement policy. Corrective Action Plan – The school lunch manager will monitor expenses for the Child Nutrition Program to ensure no purchases will be made in excess of $20,000 that have not been competitively bid for the 2025-2026 school year. For the 2026-2027 school year, the school lunch manager will competitively bid the products for all vendors that may exceed $20,000 for the school year. Responsible School District Official – Emily M. Sanders, School Business Administrator Completion Date – July 1, 2026
Condition: The City failed to file their CAPER within the 90 day reporting window. Planned Corrective Action: The City will ensure that all future reporting requirements under this program are met, including reporting deadlines. Contact person responsible for corrective action: Monique Guerrero Anti...
Condition: The City failed to file their CAPER within the 90 day reporting window. Planned Corrective Action: The City will ensure that all future reporting requirements under this program are met, including reporting deadlines. Contact person responsible for corrective action: Monique Guerrero Anticipated Completion Date: June 30, 2026
Condition: The City did not accurately prepare a SEFA that included all federal expenditures in fiscal year 2025, which resulted in a difference of approximately $7.6 million. Planned Corrective Action: The City will ensure that all future expenditures of federal awards are included on the SEFA by a...
Condition: The City did not accurately prepare a SEFA that included all federal expenditures in fiscal year 2025, which resulted in a difference of approximately $7.6 million. Planned Corrective Action: The City will ensure that all future expenditures of federal awards are included on the SEFA by assigned staff to prepare and review the SEFA and track the amounts throughout the year. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026
Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all fut...
Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance and under ARPA guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026
Condition: The City initially reported $30,000 of expenditures on the SEFA that related to activity not related to fiscal year 2025. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance with CDBG guidelines. Contact person responsible for corr...
Condition: The City initially reported $30,000 of expenditures on the SEFA that related to activity not related to fiscal year 2025. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance with CDBG guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Muth, Centralized School Lunch Treasurer and Courtney Brown, Corporation Treasurer Contact Phone Number and Email Address: 812-723-4717 and muthl@paoli.k12.in.u...
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Muth, Centralized School Lunch Treasurer and Courtney Brown, Corporation Treasurer Contact Phone Number and Email Address: 812-723-4717 and muthl@paoli.k12.in.us or brownc@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Centralized School Lunch Treasurer will ensure that all vendors are not presently suspended or debarred or otherwise excluded from or ineligible for participation in the Child Nutrition Program. The Corporation Treasurer will ensure that all documentation required for vendors is on file. Anticipated Completion Date: February 2026 INDIANA
Corrective Action: The Housing Authority will implement a targeted Quality Control (QC) review process under the oversight of the Housing Operations Director to ensure utility allowances are calculated, documented, and applied in accordance with HUD requirements, the Authority's approved utility all...
Corrective Action: The Housing Authority will implement a targeted Quality Control (QC) review process under the oversight of the Housing Operations Director to ensure utility allowances are calculated, documented, and applied in accordance with HUD requirements, the Authority's approved utility allowance schedule, and HUD Form 52667. The QC process will ensure that the lower of the approved voucher bedroom size or the actual unit bedroom size is consistently applied. Implementation: • The Housing Operations Director will oversee selective QC reviews of key HCV transactions, including: o New admissions o Selected annual reexaminations o Selected interim reexaminations impacting rent or utility allowances o Selected Housing Assistance Payment (HAP) contracts prior to approval • Reviews will verify: o Correct bedroom size determination o Accurate utility allowance calculations o Proper system entry and supporting documentation maintained in the tenant file and HAP registry • Management will review and correct the tenant files identified in the audit sample and document revised calculations as needed. • A standardized utility allowance calculation worksheet will be required in tenant files. • Staff will receive refresher training on utility allowance calculation and documentation requirements. • Periodic internal monitoring will be conducted to ensure ongoing compliance.
Finding Description: Per the VOCA contract, the grantee is required to submit quarterly fiscal and programmatic reports by the 15th calendar day of the month following the end of the quarter to the State of NJ. Testing of the compliance requirement indicated that several reports were not submitted t...
Finding Description: Per the VOCA contract, the grantee is required to submit quarterly fiscal and programmatic reports by the 15th calendar day of the month following the end of the quarter to the State of NJ. Testing of the compliance requirement indicated that several reports were not submitted timely. Corrective Action and Method of Implementation: The Organization is currently in a transition phase and plans to reorganize job duties and adjust staffing within the Finance Department to support the preparation and timely submission of quarterly fiscal and programmatic reports. These delays resulted from postponed contract approvals by the contracting entity, as well as staff turnover, which affected the timely filing of complete and accurate reports. Name of Responsible Person: Diane Hobbs, Chief Financial Officer Anticipated Completion Date: June 2026
Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: ...
Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction. b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. The corrective action above for student enrollment was underway during the fiscal year 2025 period under audit. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.
Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expen...
Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students, as well as a lunch provided to new teachers and staff. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. The district has also identified the main vendors from which picnic supplies are purchased and stopped charging expenditures from these vendors to food service account codes. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Scott Wold, Business Manager
Management will implement a process to ensure reserve deposits are made timely.
Management will implement a process to ensure reserve deposits are made timely.
Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.
Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.
Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.
Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.
The District will implement procedures to ensure that Davis-Bacon language is included for future projects with contractors or subcontractors to work on projects in excess of $2,000 financed by federal assistance funds.
The District will implement procedures to ensure that Davis-Bacon language is included for future projects with contractors or subcontractors to work on projects in excess of $2,000 financed by federal assistance funds.
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has beg...
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has begun overhauling the information security policies to reflect current practices. The CISO has also created a preliminary draft of a WISP that reflects the Colleges current policies and procedures. This WISP is expected to be completed and implemented during fiscal year 2026, pending board review and approval. Timeline for Implementation of Corrective Action Plan Immediately. Contact Person Sharron Scott, CFO
Finding 1179021 (2025-001)
Material Weakness 2025
Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals who bring extensive knowledge and expertise to their ro...
Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals who bring extensive knowledge and expertise to their roles. These positions include a new Chief Executive Officer, Director of Operations, Chief Financial Officer, and Director of Human Resources. To address challenges in accounting and finance Heading Home had contracted with a local CPA firm specializing in nonprofit accounting and financial reporting to assist the CFO with daily accounting tasks, the monthly close, financial reporting to management and the board of directors, and to facilitate and ensure audits are completed timely each year. The new management group is committed to maintaining a skilled and competent team in key financial roles. Due to the backlog of billings at the opening of FY24, the quarterly reports for the first quarter were submitted late. With the new staff and assistance, these billings and quarterly reports were brought current as quickly as possible. They are now current and being submitted in a timely manner. Management’s corrective action plan was fully implemented by June 30, 2025, and anticipate that there will be no further issues. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, and Debbie Brickman, Chief Financial Officer.
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enroll...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An Ellucian consultant provided us with customized process documentation for our new SIS (Ellucian Colleague) which is saved in a shared drive to ensure consistency in the process. The Interim Dean of Students / Financial Aid Director is currently completing the reporting with our Director of Institutional Research receiving the reports and verifying completeness through National Student Clearinghouse, ensuring that there is an internal control. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Ian Wilson Planned completion date for corrective action plan: Implemented
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements a...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office provides a list monthly of the uncashed financial aid checks to the Financial Aid Office. The Financial Aid Office is contacting the students to remind them to cash their checks. The funds for the uncashed checks are returned to the College after 90 days and then returned to the source of the funding. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla and Layla Solar. Planned completion date for corrective action plan: Already implemented.
Recommendation The Center should establish a system of internal controls to review vendors in accordance with the Uniform Guidance requirements for suspension and debarment. These procedures should be reviewed with the appropriate staff to ensure compliance with requirements Action Taken Community H...
Recommendation The Center should establish a system of internal controls to review vendors in accordance with the Uniform Guidance requirements for suspension and debarment. These procedures should be reviewed with the appropriate staff to ensure compliance with requirements Action Taken Community Health and Wellness Center has a contract management process in place to review contracts, vendors and employees in accordance with Uniform Guidance requirements for suspension and debarment. The following action will be taken: 1. We will review the list of vendors and contractors quarterly to ensure the list is updated with active contractors or vendors. 2. We will include Disbarment checks on an annual basis or more frequently as new contracts are executed, on the Sam.Gov portal for all contractors and vendors so as not to miss any contracts that are supported with federal dollars. Having this process will also alleviate challenges and barriers of administrative oversight of having to carve out federal contracts and create greater efficiencies. 3. We will maintain the documentation of all the annual disbursement checks. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Joanne Borduas, CEO at (860) 387-0425
U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a por...
U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a portion of the sampled students. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. The Institution acknowledges that while reporting was completed within a timely manner by HCC, NSC did not update within the time allotted to be compliant. HCC remains committed to continuous improvement and compliance. Action taken in response to finding: As noted in the prior year's response, the College committed to full implementation of corrective actions by June 30, 2026, aligned with the conclusion of the 2025-2026 academic year. The institution is currently and actively working on the corrective action plan previously submitted. Actions underway or in progress include: Formal clarification of interdepartmental roles and responsibilities, establishing the Records, Registration and Veteran's Affairs (RRVA) as the primary enrollment reporting authority, with defined review and compliance support from Financial Aid Services. Enhanced reconciliation and quality control procedures, including routine cross-checks between RRVA and Financial Aid Services records prior to each enrollment reporting submission. Standardized review protocols for program-level enrollment changes, including graduates, withdrawals, and subsequent reenrollments in different academic programs. Ongoing monitoring and documentation of NSC errors and warning reports, with timely resolution and escalation when discrepancies appear to originate outside of the College's student information systems. Targeted training for RRVA and Financial Aid staff on enrollment reporting regulations, NSLDS requirements, and audit-risk mitigation. The College believes these actions, coupled with existing reporting practices, sufficiently address the concerns raised and will further strengthen enrollment reporting accuracy and documentation. Full implementation of the corrective action plan remains on schedule for completion by June 30, 2026, as originally committed. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Director and Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Servies Director at 443-518-4776.
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. Dur...
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.
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