Corrective Action Plans

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Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred w...
Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred within the designated performance period, and that proper documentation must be retained for audit purposes. Corrective Actions 1. Improved Period-of-Performance Verification: The University has strengthened its review procedures to ensure all expenses are confirmed as occurring within the applicable grant period before being charged to the award. Both grants management and accounting staff now verify dates prior to posting. 2. Enhanced Documentation Requirements: A shared electronic repository is being used to ensure all supporting documents are uploaded and retained before any expenditure is approved. Transactions submitted without documentation are now automatically rejected. 3. Staff Training: Relevant staff have received targeted training on allowable-cost rules, documentation standards, and period-of-performance requirements under Uniform Guidance. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to verify continued compliance and ensure that all costs charged to federal awards are timely, appropriate, and fully supported, and charged within the required time periods. The University believes these actions address the issues noted and will strengthen internal controls over federal expenditures moving forward.
Return of Title IV Funds (R2T4) Calculation The University acknowledges the finding related to errors and missing documentation in the Return of Title IV Funds (R2T4) process. We recognize the importance of accurate withdrawal date determination, proper calculation of earned versus unearned aid, and...
Return of Title IV Funds (R2T4) Calculation The University acknowledges the finding related to errors and missing documentation in the Return of Title IV Funds (R2T4) process. We recognize the importance of accurate withdrawal date determination, proper calculation of earned versus unearned aid, and timely retention of supporting documentation in accordance with federal requirements. Corrective Actions 1. Immediate Corrections and Reconciliation: The University has reviewed the identified cases and will recalculate the R2T4 amounts where required, and process the return of the $18,016 owed to the U.S. Department of Education. Additional reviews are underway to identify any other students who may have been affected. 2. Strengthened Documentation and Record Retention: Procedures have been updated to ensure that withdrawal dates, last dates of attendance, and all supporting documentation are retained and readily available for audit and compliance review. 3. Revised R2T4 Calculation and Review Process: A standardized calculation template and checklist have been implemented to ensure consistency in determining payment period days, institutional charges, and earned aid. All R2T4 calculations will undergo a secondary review prior to processing. 4. Improved Coordination Between Offices: The University has enhanced communication procedures between Financial Aid, the Registrar, and Student Accounts to ensure timely access to enrollment, grade, and withdrawal information necessary for accurate R2T4 processing. 5. Staff Training and Compliance Oversight: Financial Aid staff have received updated training on R2T4 regulatory requirements, documentation standards, and calculation procedures. Periodic internal monitoring will be conducted to validate continued compliance. The University believes these corrective actions will address the root causes identified and strengthen overall compliance with federal R2T4 regulations going forward.
Pell Grant Calculations The University acknowledges the finding regarding errors in Pell Grant calculations for Summer 2025. We acknowledge the importance of ensuring that Pell Grant awards are calculated accurately in accordance with federal regulations. Corrective Actions 1. Immediate Corrections:...
Pell Grant Calculations The University acknowledges the finding regarding errors in Pell Grant calculations for Summer 2025. We acknowledge the importance of ensuring that Pell Grant awards are calculated accurately in accordance with federal regulations. Corrective Actions 1. Immediate Corrections: The University has reviewed the affected student accounts and has processed the remaining Pell funds owed to each student. 2. Strengthened Review Controls: A secondary review process has been implemented to verify Pell Grant calculations prior to disbursement, including confirmation of enrollment status, cost of attendance, and formula application. 3. Staff Training: Financial Aid staff are receiving additional training on Pell awarding requirements and payment schedule usage to ensure the correct application of formulas. 4. Broader File Review: The University is conducting a wider review of Pell disbursements outside the audit sample to identify and correct any similar errors. The University believes these actions will prevent future calculation errors and ensure ongoing compliance with federal regulations.
FISAP Reporting The University acknowledges the finding related to the FISAP report. During the reporting period, newly hired Financial Aid staff had limited access to required U.S. Department of Education systems. Because these employees had not yet been fully authorized by the Department of Educat...
FISAP Reporting The University acknowledges the finding related to the FISAP report. During the reporting period, newly hired Financial Aid staff had limited access to required U.S. Department of Education systems. Because these employees had not yet been fully authorized by the Department of Education, they were unable to enter FISAP data or view the system-generated error notifications that are normally used to validate and finalize the report. This contributed to delays in completing the FISAP and in maintaining the supporting documentation needed for audit review. Corrective Actions 1. Resolution of System Access Issues: The University is working with the Department of Education to ensure all relevant staff will soon have full and active system credentials, allowing timely FISAP data entry and error review. 2. Strengthened Reporting Procedures: Internal processes have been updated to ensure supporting documentation for the FISAP is compiled, retained, and stored in a centralized digital repository. 3. Staffing and Oversight Improvements: Responsibilities for FISAP preparation have been reassigned and supplemented with supervisory review to prevent delays during staffing transitions or access lapses. 4. Accounting Entries: The accounting office will continue to update the general ledger to agree with the activities generated from the ECSI report and be prepared to provide the relevant data to the auditors upon request. 5. Earlier Internal Deadlines: The University has established internal timelines ahead of the federal deadline to allow adequate time for review, corrections, and document retention. The University believes these measures will prevent future access related delays and ensure timely, accurate, and fully documented FISAP submissions in compliance with federal requirements.
Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional j...
Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional judgment to support additional unsubsidized eligibility. Corrective Actions 1. Strengthened Documentation Requirements: Effective immediately, financial aid staff will maintain complete professional judgment documentation, including the rationale, supporting evidence, and approval, in the student’s file before any additional unsubsidized loan is awarded. 2. Verification Controls: A mandatory checklist has been implemented to ensure that a PLUS denial or documented professional judgment is obtained and reviewed prior to disbursement of any loan amount exceeding standard limits. 3. Staff Training: The Office of Financial Aid will conduct targeted training to reinforce Title IV loan limit rules and proper documentation standards. 4. Ongoing Monitoring: Supervisory review will be performed on all professional judgment decisions and on any loan increases exceeding the standard $2,000 annual limit. The University believes these corrective measures will address the root cause of the finding and ensure full compliance with federal loan regulations going forward.
Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret ...
Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret that the requested documentation was not supplied within the audit timeframe. Corrective Actions Taken / Planned 1. Process Redesign and Timeliness Controls The University has implemented revised internal procedures to ensure that all requested enrollment reports are generated promptly. This includes establishing defined timelines for responding to audit requests and assigning responsibility to specific staff members to track and manage reporting obligations. 2. System and Reporting Enhancements We are reviewing and updating our reporting workflow within our student information system to strengthen data retrieval capabilities and reduce delays in report generation. Additional user training will be provided to ensure staff can efficiently extract the required information. 3. Improved Communication With the Guaranty Agency The University will review past enrollment status submissions and implement additional checks to ensure that future enrollment reporting to the guaranty agency is complete, accurate, and timely. A 45-day reconciliation process has been added to verify that all required status updates have been transmitted. 4. Ongoing Monitoring The University has established ongoing oversight to ensure consistent compliance with reporting requirements. Internal reviews will be performed periodically to confirm that corrective actions remain effective. Management Conclusion We believe these measures will address the root causes identified in the finding and will ensure the timely delivery of required information for future audits. The University is committed to maintaining full compliance with federal and state reporting standards.
Processes have been developed and implemented to ensure both receipt of funds and return of interest to the grantor is done on a timely and consistent basis.
Processes have been developed and implemented to ensure both receipt of funds and return of interest to the grantor is done on a timely and consistent basis.
Audit Finding 2025-001: Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,452. A receivable was reco...
Audit Finding 2025-001: Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,452. A receivable was recorded for the overpaid management fees at December 31, 2025. The excess fees were refunded to the Project on March 12, 2026. - Name and Title of contact person responsible for corrective action: -Steve Colella, Making a Difference in Property Management, LLC - Management Agent - 6800 Park Ten Blvd, Ste 184-W - San Antonio, TX 78213
During the year ended December 31, 2025, four tenant move-out files of former tenants could not be located by the staff and management at the Project site. - Management asserts that this was a one-time incident where the previous community director, at the time of leaving, may have inadvertently des...
During the year ended December 31, 2025, four tenant move-out files of former tenants could not be located by the staff and management at the Project site. - Management asserts that this was a one-time incident where the previous community director, at the time of leaving, may have inadvertently destroyed or misplaced the files for the tenants who had moved out.
Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $2,629. A receivable was recorded for the overpaid ma...
Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $2,629. A receivable was recorded for the overpaid management fees at December 31, 2025. The excess fees were refunded to the Project on March 13, 2026.
The monthly deposit for repayment of loan from the replacement reserve was not done for December 2025. - The correcting deposit was made on February 11, 2026.
The monthly deposit for repayment of loan from the replacement reserve was not done for December 2025. - The correcting deposit was made on February 11, 2026.
The Organization concurs with the recommendation, and notes that accounting department turnover limited resources during the year. As vacant roles have been filled, we do not anticipate a recurrence of this condition. We are now in the process of evaluating and revising our existing reconciliation p...
The Organization concurs with the recommendation, and notes that accounting department turnover limited resources during the year. As vacant roles have been filled, we do not anticipate a recurrence of this condition. We are now in the process of evaluating and revising our existing reconciliation processes necessary to be consistent with available staffing resources. Anticpated Completion Date: June 30, 2026
2025-002 Corrective Action: We will correct the application of indirect costs and reduce the very next future request for reimbursement by the overcharged indirect costs. We have also changed the circumstances that caused the limitation to be overlooked related to this specific contract.
2025-002 Corrective Action: We will correct the application of indirect costs and reduce the very next future request for reimbursement by the overcharged indirect costs. We have also changed the circumstances that caused the limitation to be overlooked related to this specific contract.
Management will review reports more closely in the future to ascertain the forms are correctly reporting expenditures.
Management will review reports more closely in the future to ascertain the forms are correctly reporting expenditures.
Finding 2025-007 Finding Summary: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding obtaining rate quotations or maintaining sole source vendor documentation, if applicable. In addition, contracts were ...
Finding 2025-007 Finding Summary: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding obtaining rate quotations or maintaining sole source vendor documentation, if applicable. In addition, contracts were missing required provisions per Appendix II to Part 200 for contracts under federal awards. Corrective Action Plan: The District has set required approvals based on spending thresholds to ensure procurement requirements are met. Responsible Individual: Cassandra Stahlke Chief Financial Officer Anticipated Completion Date: Completed
Finding 2025-006 Finding Summary: Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, e...
Finding 2025-006 Finding Summary: Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Elko County School District did not have sufficient internal controls to ensure all documentation for the removal of students from the cohort was maintained. Corrective Action Plan: The District will provide training to all registrars and create a consistent form that will be available to all school sites for tracking purposes Responsible Individual: Ray Smith Director of Special Education Anticipated Completion Date: June 2026
Finding 2025-005 Finding Summary: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Elko County School District did not have sufficient internal controls to ensure level of effort tracki...
Finding 2025-005 Finding Summary: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Corrective Action Plan: The Grants Department will develop a centralized level of effort calculation worksheet and submit it to the Finance Department for review and sign off. Responsible Individual: Megan Cox Grant Manager Anticipated Completion Date: June 2026
Finding 2025-004 Finding Summary: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of Title I fund amounts disbursed were being appropriately followed. Corrective Action Plan: The grants department will update allocation procedures to ensure ...
Finding 2025-004 Finding Summary: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of Title I fund amounts disbursed were being appropriately followed. Corrective Action Plan: The grants department will update allocation procedures to ensure equitable distribution of Title I funds to all eligible schools in rank order by low-income student count. Responsible Individual: Megan Cox Grant Manager Anticipated Completion Date: June 2026
Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund o...
Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund of credit balances. Further, management will reinforce control ownership and provide targeted training to individuals responsible for compliance. The actions will help to ensure that appropriate controls are in place and responsibilities are clearly defined, and instances of noncompliance are mitigated to support controls. Contact Person: Terry Nixon, Assistant Comptroller, Student Business Services Anticipated Completion Date: June 15, 2026
Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status ...
Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status issues were addressed and updated during the Fall 2025 term merge project. We will work with IT to enhance the information included in the Comprehensive Graduation Report (CRT) to ensure complete, accurate and timely repmiing.Contact Person: Regina Cotter, University Registrar Anticipated Completion Date: June 15, 2026
Corrective Action: The University agrees with the findings. The project Directors will continue to validate data input into the system prior to the submission of the APR. We will establish a cut-off date for rolling the system fmward to prevent these administrative clerical errors. Contact Person: M...
Corrective Action: The University agrees with the findings. The project Directors will continue to validate data input into the system prior to the submission of the APR. We will establish a cut-off date for rolling the system fmward to prevent these administrative clerical errors. Contact Person: Mikael Davis, SSS Director And Dr Ferguson Gregg, Upward Bound Director Anticipated Completion Date: June 15, 2026
Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn f...
Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn form that requires her to sign that she has communicated to both offices. Hear is the updated for: Add/Drop/Withdrawn Form
FINDING 2025-002: Wage Rate Compliance (Repeated 2024-003) Response: The vendors noted in the audit had completed their work before the conclusion of the fiscal year 2024 audit, and the District was unable to obtain all required payroll and wage-rate documentation from those contractors before the 2...
FINDING 2025-002: Wage Rate Compliance (Repeated 2024-003) Response: The vendors noted in the audit had completed their work before the conclusion of the fiscal year 2024 audit, and the District was unable to obtain all required payroll and wage-rate documentation from those contractors before the 2023-2024 audit was finalized. To prevent recurrence, the following procedures will be implemented: • A contractor checklist will be implemented to document the type of work to be performed, the funding source, and whether Davis-Bacon wage requirements or Montana prevailing wage rates apply before work begins. • Accounts payable staff will verify that all required contractor documentation is received and retained before final payment is issued.
iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Managem...
iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Management will establish written procedures for indirect cost recovery, implement a formal review and reconciliation process prior to submission, and provide staff training on Uniform Guidance requirements. These corrective actions will be in place for the fiscal year ending June 30, 2026. Responsible Official: Mr. Coban, Chief Financial Officer
JUBILEE SENIOR HOMES INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for th...
JUBILEE SENIOR HOMES INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Timely Deposit of Annual Residual Receipts No. 14.157. Program –Section 202 Supportive Housing for Elderly Personal Significant Deficiency Jubilee should reevaluate its policies and procedures to ensure that required residual receipts deposits are made timely each year. Action Taken: This was an isolated incident for fiscal year ending 6/30/24. As soon as the oversight was realized, we took action to remedy it. In addition, we have updated our process to send out residual receipts deposits once we have a draft audit completed versus waiting until after the final audit to ensure deposits are made before the 9/30 deadline. If there are any changes post audit completion, they should be immaterial and would be deposited as soon as we have final numbers. This will ensure timely deposits. Confirmation of deposits are tracked and will be followed up on regularly to ensure we do not miss the residual receipts distributions from surplus cash in the future. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development
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