Corrective Action Plans

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Corrective Action Planned: Management agrees with the auditor’s findings and has completed the revision of the Organization’s accounting manual to align with the regulatory requirements. The former Director of Finance, Vannam Khen, worked directly with the Organization’s assigned Fiscal Compliance A...
Corrective Action Planned: Management agrees with the auditor’s findings and has completed the revision of the Organization’s accounting manual to align with the regulatory requirements. The former Director of Finance, Vannam Khen, worked directly with the Organization’s assigned Fiscal Compliance Analyst from Legal Services Corporation (LSC) to ensure policies and procedures are aligned with LSC’s Financial Guide. Name(s) of Contact Person(s) Responsible for Corrective Action: Former Director of Finance – Vannam Khen CEO – Micaela Schuneman Anticipated Completion Date: On or before December 31, 2026
The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inven...
The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inventory taken. In addition, if prescribed by other funding sources the organization may do an annual inventory and reconcile it with the previous year as well. Disposal policies will include methods of disposition as required by the various funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Fourth Quarter - ending Dec. 2026
The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inven...
The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inventory taken. In addition, if prescribed by other funding sources the organization may do an annual inventory and reconcile it with the previous year as well. A form will be created to ensure that all requirements of inventory are met: date of purchase, description of item, purchase price, vendor, location, grant award number. Responsible Individual: Program Directors Estimated Completion Date: December 2026, thereafter June of odd years
The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Octob...
The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: October 31, 2026
The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the ...
The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the funding source. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date:
The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization...
The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization feels that it was able to show the funds that were passed-through to the contractor. Responsible Individual: Chief Financial Officer– Scott Korba Estimated Completion Date
The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission....
The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission. The organization CEO may review be included in the review process. Responsible Individual: Chief Financial Officer- Scott Korba Estimated Completion Date: End of next quarter – September 2026
Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HI...
Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HIC Certification. In addition, the Program Director has a list of debarred contractors that he reviews periodically to ensure that contractors are not on the list. The organization will take the auditors recommendation of copying the debarred alphabetical page indicating that the contractor is not on the debarred or suspended listing and placing it in the contractors file. Responsible Individual: Energy Director Zack Porrecca and Housing Director Vickie Bucker Estimated Completion Date: September 30, 2026
The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide...
The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide training to management staff on the procurement policies. Responsible Individual: Chief Financial Officer – Scott Korba Estimated Completion Date: October 2026-December 2026
While the organization has a written leave policy it does not address specific leave benefits for the CEO. The CEO has drafted a CEO Compensation and Benefits Policy to be reviewed by the Board and revised or approved at the October 21, 2026 Board of Directors meeting. Responsible Individual: Chief ...
While the organization has a written leave policy it does not address specific leave benefits for the CEO. The CEO has drafted a CEO Compensation and Benefits Policy to be reviewed by the Board and revised or approved at the October 21, 2026 Board of Directors meeting. Responsible Individual: Chief Executive Officer – Wilma Torres Estimated Completion Date: October 21, 2026
Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirem...
Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirements. The untimely reports identified in the finding occurred during a period of significant personnel turnover within the State Division. Management recognizes that regulatory compliance and reporting continuity should not depend upon the knowledge or availability of any one employee.Accordingly, UCP has begun transitioning from individually maintained deadline tracking to a more centralized and transparent reporting-control process. Approximately six months ago, UCP implemented a requirement that State Programs staff enter all grant-related reporting deadlines and other critical compliance dates into the County/Urban County shared electronic calendar. This calendar is accessible to State Programs staff and management and provides department-wide visibility of upcoming deadlines, thereby reducing reliance on individual calendars or institutional memory. In addition to this existing control, UCP will implement the following measures specifically for Section 3 reporting: • Establish internal preparation deadlines at least 5 calendar days before each required Section 3 submission date. • Assign primary responsibility for preparation and submission of each Section 3 report to the applicable State Grant Coordinator, with supervisory review by the State Programs Manager/Coordinator or other designated supervisor prior to submission. • Designate and cross-train at least one additional State Programs employee as backup personnel for Section 3 reporting to ensure continuity during vacancies, leave, employee transitions, or other absences. • Maintain a centralized reporting log for each applicable grant documenting the reporting period, regulatory or contractual due date, internal preparation deadline, responsible employee, supervisory review date, actual submission date, and confirmation or other evidence of submission. • Maintain supporting Section 3 reporting documentation within the applicable grant's official administrative file in accordance with applicable record-retention requirements. • Include upcoming reporting deadlines as a standing compliance item during State Programs staff meetings so that approaching deadlines, assignments, and outstanding reporting requirements can be reviewed collectively. • Require supervisory follow-up when a report has not reached the review stage by its established internal deadline, allowing management sufficient time to intervene before the external submission deadline. • Periodically review the shared reporting calendar and reporting log to verify that required reports have been submitted timely and that supporting documentation has been retained. These controls are intended to establish multiple levels of accountability—deadline visibility, assigned responsibility, supervisory review, backup coverage, documentation of submission, and management oversight—so that required reporting continues timely despite employee turnover or other staffing changes. UCP will also incorporate Section 3 reporting procedures into written State Programs standard operating procedures and employee cross-training materials so that the reporting process becomes documented institutional knowledge available to current and future staff. Proposed Completion Date - Existing shared calendar control (implemented and currently in use); Remaining corrective measures (September 30, 2026 - Implementation will begin immediately and be incorporated into State Program operating procedures and reporting practices). Contact Person - Steven De La Cruz, Assistant Director, Urban County Program
2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have bee...
2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Organization. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Organization review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Organization has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Board of Directors before the end of fiscal year 2026. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026
2025-005 – Lack of Documentation for SAM.gov Exclusion Checks Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Organization did not retain documentation to support that the exclusion checks...
2025-005 – Lack of Documentation for SAM.gov Exclusion Checks Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Organization did not retain documentation to support that the exclusion checks were performed for vendors. As a result, there is no evidence that the Organization verified whether these parties were suspended or debarred prior to entering covered transactions. Auditor Recommendation. We recommend that the Organization retain evidence that SAM.gov exclusion checks are being completed for vendors to document that vendors are not suspended or debarred prior to entering covered transactions. Corrective Action. The Organization will begin retaining documentation for its SAM.gov exclusion checks that it completes for vendors to verify whether these parties were suspended or debarred prior to entering covered transactions. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026
2025-001 Financial Reporting – Material Adjustments Criteria: Internal controls over financial reporting should be designed and implemented to ensure that financial statements are free from material misstatement, whether due to error or fraud, and that such misstatements are prevented or detected an...
2025-001 Financial Reporting – Material Adjustments Criteria: Internal controls over financial reporting should be designed and implemented to ensure that financial statements are free from material misstatement, whether due to error or fraud, and that such misstatements are prevented or detected and corrected on a timely basis. Condition: During the audit, material audit adjustments were proposed and accepted by management. The adjustments were necessary to correct material misstatements in the financial statements that had not been identified by the organization’s internal control processes. Significant adjustments included: • Recording loan forgiveness, which corrected the overstatement of liabilities and understatement of revenues • Reclassifying HOME program assistance from revenue to deferred loan liability, which corrected the overstatement of revenues and changes in net assets and the understatement of liabilities • Reclassifying development costs from expenses to property and equipment, which corrected the understatement of assets and overstatement of expenses. Cause: The Organization’s internal control processes did not identify or correct these misstatements prior to the audit. This suggests certain review and reconciliation procedures may not be operating effectively. Effect: Financial statements generated from the accounting system and provided to the board may contain error(s), which could potentially affect decision-making and oversight. Auditor’s Recommendation: We recommend that management review and enhance its financial reporting processes, including implementing more robust review procedures and reconciliations, to help ensure that misstatements are identified and corrected prior to the audit. Auditee’s Response: Management agrees with this finding and agrees with the recommendation. Management will evaluate current procedures and implement improvements to strengthen the accuracy and completeness of financial reporting. Contact Person: Brad Hinkfuss Anticipated Completion: December 31, 2026
The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appoi...
The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appointed Town Administrator has been made aware we are required to file the SF-425 when a grant award mandates the submission. Corrective action has began, the Town Administrator and Treasurer have been working together to get in compliance with our required reporting across all State and Federal Agencies that have awarded the Town grant funds. Trainings have taken place and the newly hired Administrator is aware of the required reporting and is able to perform this task on time when required.
Corrective Action Planned: The material misstatements detected as a result of audit procedures were corrected by management. The Authority will review all adjusting entries posted and make all such necessary adjustments in the future. The Executive Director will continue to monitor all financial act...
Corrective Action Planned: The material misstatements detected as a result of audit procedures were corrected by management. The Authority will review all adjusting entries posted and make all such necessary adjustments in the future. The Executive Director will continue to monitor all financial activity and adjust account balances as needed throughout the year and at year end to prevent misstatements. Completion Date: December 31, 2026
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing
Condition Summary: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Of the forty stu...
Condition Summary: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Of the forty student records tested for NSLDS withdrawal reporting, we identified the following: • One student where the effective date of withdrawal was reported as the end of the semester rather than the student's actual withdrawal date. • Six students where the effective date of withdrawal was reported as the date the student was notified rather than the actual effective withdrawal date. • One student where the student's withdrawal was not reported timely and was not included on the first enrollment roster following the withdrawal. Management Response / Corrective Action Plan: Management concurs with this finding. Turnover within the Financial Aid office resulted in a breakdown in the process for timely and accurate submission of reporting enrollment changes within NSLDS. Staff previously responsible for this function are no longer employed at the institution, and the engaged consulting firm has assumed interim responsibility for identifying enrollment status changes and completing NSLDS reporting within the required 60-day period. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Condition Summary: 2 of 3 students selected for verification lacked evidence that required verification procedures were performed, and controls to track verification completion were not operating during the academic year. Management Response / Corrective Action Plan: Management concurs with this fin...
Condition Summary: 2 of 3 students selected for verification lacked evidence that required verification procedures were performed, and controls to track verification completion were not operating during the academic year. Management Response / Corrective Action Plan: Management concurs with this finding. The University has directed the engaged consulting firm to complete a full review of 2025-2026 verification activity, obtain and document outstanding verification records, and complete any required corrections to FAFSA data. A dedicated verification tracking log, maintained by the consulting firm, now records each selected student's status from selection through completion. Staff previously responsible for monitoring verification completion are no longer employed at the institution. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Condition Summary: The Data Collection Form was submitted to the Federal Audit Clearinghouse after the required deadline, with no documented extension obtained. Management Response / Corrective Action Plan: Management concurs with this finding. The University has implemented a compliance calendar, m...
Condition Summary: The Data Collection Form was submitted to the Federal Audit Clearinghouse after the required deadline, with no documented extension obtained. Management Response / Corrective Action Plan: Management concurs with this finding. The University has implemented a compliance calendar, maintained by the engaged consulting firm, that tracks all federal reporting deadlines, including the DCF submission date, with milestone reminders beginning 60 days in advance of each deadline. Responsibility for final submission has been assigned to the consulting firm for the current cycle to ensure the deadline is met while the University's internal compliance-monitoring function is rebuilt. Responsible Party - Michael DeWees, Vice-President for Finance and Administration Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Condition Summary: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 o...
Condition Summary: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 of 4 students had R2T4 calculations that were performed incorrectly, resulting in $691 of net over returned Title IV aid. Management Response / Corrective Action Plan: Management concurs with this finding. Turnover within the Financial Aid office resulted in a breakdown in the process used to identify withdrawn students and timely complete R2T4 calculations. As part of the University's full review of 2025-2026 withdrawal activity, all R2T4 calculations have been recalculated and confirmed for accuracy, and any additional funds due have been returned. Staff previously responsible for this function are no longer employed at the institution, and the engaged consulting firm has assumed interim responsibility for identifying withdrawals and completing R2T4 calculations within the required 45-day period, with a secondary review of every calculation prior to submission. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Federal Direct Loan FY24-25: Award # P268K252023 Pell Grant FY24-25: Award # P063P242023 SEOG FY24-25: Award # P007A243392 Condition Summary: SEOG, Federal Direct Loan, and Pell funds were drawn down in excess of immediate disbursement needs at various points during the year, and SEOG and Federal Di...
Federal Direct Loan FY24-25: Award # P268K252023 Pell Grant FY24-25: Award # P063P242023 SEOG FY24-25: Award # P007A243392 Condition Summary: SEOG, Federal Direct Loan, and Pell funds were drawn down in excess of immediate disbursement needs at various points during the year, and SEOG and Federal Direct Loan remained in an overdrawn position at year-end. Management Response / Corrective Action Plan: Management concurs with this finding. The lack of routine reconciliation between the University's internal systems and federal drawdown systems allowed overdrawn positions to persist. The University's full review of 2025-2026 activity included reconstructing drawdown history and bringing all programs current. Going forward, the consulting firm engaged by the University is performing a documented reconciliation between institutional records and G5 drawdown activity on no less than a bi-weekly basis, with any variance requiring same-week resolution. Personnel who previously held responsibility for cash management are no longer employed at the institution. Responsible Party - Michael DeWees, Vice President for Finance and Administration, Controller (Vacant) & Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Condition Summary: 5 of 40 credit balance refunds were processed outside the required 14-day timeframe, controls over review and approval were not operating for the full year, and the University could not produce a report distinguishing Title IV credit balances from other funding sources. Management...
Condition Summary: 5 of 40 credit balance refunds were processed outside the required 14-day timeframe, controls over review and approval were not operating for the full year, and the University could not produce a report distinguishing Title IV credit balances from other funding sources. Management Response / Corrective Action Plan: Management concurs with this finding. As part of the University's full review of 2025-2026 cash management activity, a revised credit-balance workflow has been established requiring supervisory approval and a system-generated report that separately identifies balances attributable to Title IV funds. Staff associated with the prior lapse in controls are no longer employed at the institution, and the engaged consulting firm is providing interim monitoring of the 14-day refund requirement, with weekly exception reporting until the control is demonstrated to be operating effectively on a sustained basis. Responsible Party - Ebony Martin, Associate Director of Student Accounts Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Condition Summary: Customer data was not encrypted, periodic data inventories were not performed for a portion of the year, and elements of the annual risk assessment were not satisfactorily implemented. Management Response / Corrective Action Plan: Management concurs with this finding. The absence ...
Condition Summary: Customer data was not encrypted, periodic data inventories were not performed for a portion of the year, and elements of the annual risk assessment were not satisfactorily implemented. Management Response / Corrective Action Plan: Management concurs with this finding. The absence of adequate internal controls and monitoring procedures left gaps in the University's information security program required under the GLBA Safeguards Rule. To remediate this finding and safeguard the institution from further harm, the University has engaged an outside consulting firm with information-security expertise to complete a full review of 2025-2026 data-security practices, implement encryption of customer data at rest and in transit, reinstate periodic data inventories, and close the gaps identified in the prior risk assessment. Personnel previously responsible for information security oversight are no longer employed at the institution, and the consulting firm is providing interim GLBA program management, including board-level reporting, while a permanent qualified individual is identified. Responsible Party - Candice Santell, CampusWorks, Ray Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firms Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
Federal Direct Loan FY24-25: Award # P268K252023 Pell Grant FY24-25: Award # P063P242023 Condition Summary: Untimely and inaccurate reporting of Pell Grant and Federal Direct Loan disbursements to COD, and inaccuracies in the initial FISAP submission. Management Response / Corrective Action Plan: Ma...
Federal Direct Loan FY24-25: Award # P268K252023 Pell Grant FY24-25: Award # P063P242023 Condition Summary: Untimely and inaccurate reporting of Pell Grant and Federal Direct Loan disbursements to COD, and inaccuracies in the initial FISAP submission. Management Response / Corrective Action Plan: Management concurs with this finding. The turnover experienced within the Financial Aid office during the period disrupted the continuity of the University's COD and FISAP reporting processes. As part of the corrective actions described in the overview above, the University has completed a full review of 2025-2026 disbursement and reporting activity to confirm that COD submissions are made within the required 15-day window and that FISAP data is accurate prior to submission. Staff previously responsible for this function are no longer employed at the institution, and the University has engaged an outside consulting firm to provide interim management of Title IV reporting functions, including a documented weekly COD reconciliation and a formal FISAP review-and-sign-off procedure, until permanent, adequately trained staff are in place. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.
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