Corrective Action Plans

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The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department ...
The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department concurs with paragraph B - The finding was a result of personnel turnover and medical issues. The Department has hired and trained additional program staff and updated policies to ensure programmatic monitoring and subsequent reports are done in a timely manner. The Department partially concurs with paragraph C. Fiscal monitoring was done for all 3 subrecipients during the federal program year. However, 1 subrecipient monitoring fell outside the state fiscal year so was not covered during the audit period. The Department has changed the wording on its risk assessment procedures to ensure no misinterpretation of the timeframe each subrecipient will be monitored in accordance with its risk assessment. The Department has also changed the requirements of the frequency of fiscal monitoring in each of the risk assessment categories. The Department Concurs with paragraph D – The Department is reviewing policies and procedures and will update them to ensure compliance with 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.521. The Department also created a tracking mechanism to ensure we receive, review, and issue management decisions (if required) in a timely manner. The Department concurs with Paragraph E - The Department is reviewing policies and procedures for both reporting and subrecipient monitoring to ensure data is tested and verified. The Department has already gained increased access to data in current software and is in the process of selecting a vendor for new software that will provide more testing and enhanced internal controls.
The Department concurs with paragraph A that some of the cash draws were not performed in a timely manner. The finding was due to a shortage of trained personnel. The Department is in the process of hiring and training additional personnel and reviewing its policy and procedures on cash draws. Th...
The Department concurs with paragraph A that some of the cash draws were not performed in a timely manner. The finding was due to a shortage of trained personnel. The Department is in the process of hiring and training additional personnel and reviewing its policy and procedures on cash draws. The Department concurs with paragraph B. The Department can show that the subrecipients disburse payments for program advances within a few weeks from original receipt starting with the first check runs to fuel vendors shortly after receiving the advance. However, the Department will work on reviewing its policies and procedures to ensure the Department monitors the subrecipients’ written procedures to minimize the time elapsing between the transfer of funds and disbursement by the subrecipient. The Department is also creating a tracking method to show the time elapsed when an advance is originally paid to the subrecipient and when it is fully disbursed.
The Department continues to work with its federal partners to ensure timely access to required reports.
The Department continues to work with its federal partners to ensure timely access to required reports.
Corrective Action Planned: The Bureau of Employment Supports has undergone significant programmatic changes over the past 3 years. As part of those changes, our Work Verification Plan was updated and submitted for approval on July 8, 2022. It was approved by the Administration of Children and Famil...
Corrective Action Planned: The Bureau of Employment Supports has undergone significant programmatic changes over the past 3 years. As part of those changes, our Work Verification Plan was updated and submitted for approval on July 8, 2022. It was approved by the Administration of Children and Families on February 9, 2024, making the updates to the NH work verification plan in effect back to July 9, 2022. The audit period in question is from July 1, 2022 to June 30, 2023. Trainings, supports and guidance have taken place throughout that time to correct hour errors such as those identified through this audit. Uploading documents into the e-folder was found to be error prone, therefore, on March 1, 2023, NHEP leadership provided guidance and training on a specific process of indexing and scanning documents to ensure that moving forward the Career Counselors are checking their e-folder’s to ensure that documents are properly uploaded and visible. In addition, a statewide training took place on May 5, 2023, to look in depth at past audit findings, during which, strategies were identified to help alleviate these errors from re-occurring. An additional statewide training also took place on December 15, 2023, which involved discussion around the audit, which was about to begin, including what the general focus of the audit has historically been. As of April 2023, an additional Quality Assurance Specialist was hired to help monitor and support newly hired career counselors in their first year of employment. This additional Specialist has allowed for guidance to be available not only to newly hired staff, but also to seasoned staff throughout the state. The need for an extra layer of training throughout the year for newly hired Career Counselors was identified in the summer of 2023 and the NHEP Leadership Team developed a weekly Quality Assurance meeting. These weekly meetings started August 30, 2023. These meetings provide real time training to review best practices and further career counselors understanding of federal and state policies. The meetings have been successful and are now bi-weekly. As of February 28, 2024, the meetings have been opened to all career counselors throughout the state, not just those under 9 months of employment. The meetings ensure that there is consistent messaging across the state and also provide an opportunity for statewide collaboration between career counselors. Through cursory investigations, we believe that these new supports and processes, have already shown to be effective in improving the accuracy of supporting and recording hours. The last audit yielded 15% discrepancies in hour errors. This audit period had a decrease of 12%, indicating 3% discrepancies in hour errors. NHEP leadership has also been working with the NEW HEIGHTS system to streamline the process of uploading documents to further decrease the potential for errors. A change request form was submitted approximately two years ago. In order to address the audit findings, within the next 90 days, NHEP leadership is holding a statewide mandatory staff training to review the audit process and findings that were identified. During the meeting, in regards to the over reporting hours error, the Leadership Team will reiterate and discuss the importance of uploading documents prior to inputting hours. In regards to the under reporting hours error, the meeting will also include further training about the importance of justification for any differences in hours than what is reported on the activity tracker. Further, that any differences need to be documented in either a sticky note or a RID note. In addition, the Quality Assurance meetings will continue to be held bi-weekly to address issues or trends in the moment. Our continuous transparency will further ensure buy-in from the staff to put systems in place for themselves as well as to increase self-monitoring practices and in turn, decrease errors in the future.
Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the ...
Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the requested subrecipient monitoring. The Department provides annual training on the Subrecipient Monitoring Policy. We will reinforce the requirements of the Policy and the ramifications for the Department for the non-compliance in this year’s annual training. Regarding the incomplete Risk Assessment Tool, we will update the Subrecipient Monitoring Policy to include a secondary review of the Tool prior to implementation, as part of our internal controls. Condition B: DHHS does not concur. The Department employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. The Department’s review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system Standard language for the submission of expenditure detail is included in all templates for legal agreements. These subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient monitoring. Subrecipient monitoring activities are memorialized in the legal agreements. The Risk Assessment Tool provides a space for the monitoring activities to be selected, however, the Subrecipient Monitoring Policy does require the memorialization of the activities on the Tool for compliance, only to be memorialized in the legal agreement. Condition C DHHS partially concurs. As the subrecipient’s audit report had no findings, we are not required to issue a management decision letter. However, we will be updating our procedures to include contacting the vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.
This function (FFATA reporting) has now been designated to our Federal Reporting Group, which will allow for redundancy in personnel. A new policy and procedure, which will include internal controls, will be developed and implemented.
This function (FFATA reporting) has now been designated to our Federal Reporting Group, which will allow for redundancy in personnel. A new policy and procedure, which will include internal controls, will be developed and implemented.
NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were i...
NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were in fact some items that were charged outside the period of performance. This happened prior to us receiving the FY22 audit finding and putting in place new controls to prevent. We have since put into place DOE-OBM-33 to ensure payments are being reviewed closely to the period of performance at multiple times. We have also corrected any items charged to the wrong CAN. The NHED concurs with the findings identified with expenditures of $816. We will look into the district returning these funds or other enforcement actions. In addition to the DOE-OBM-033 process, the Division of Learner Support has created and implemented a transfer of funds procedure.
View Audit 301259 Questioned Costs: $1
The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission a...
The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission and a secondary certification for accuracy verification, and a division wide process for FFATA filing and verification. Division wide training occurred on October 26, 2023. Due to grant award notification (GAN) changes and development within our grants management system (GMS), the FFATA process has also been developing and shifting; therefore the FFATA process will be revisited annually and updated as needed. A revised procedure for FFATA reporting will be completed prior to additional training being offered. To ensure that processes are being followed, newly hired staff is trained appropriately, and updates to the GAN process are considered within the FFATA process we will hold another training this spring, March 14th, 2024, prior to new subawards being issued.
Corrective Action Planned: The Office of ESEA Title Programs’ accountant identified when the miscalculation first took place in 2021-2022 and made changes to the workbook formula to correctly calculate the LEA allocations. The office administrator and the bureau administrator both thoroughly review...
Corrective Action Planned: The Office of ESEA Title Programs’ accountant identified when the miscalculation first took place in 2021-2022 and made changes to the workbook formula to correctly calculate the LEA allocations. The office administrator and the bureau administrator both thoroughly reviewed the Title I, Part A allocation workbooks and relayed questions, comments and concerns to the accountant, to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. This three-step review ensures that formulas are executed as required under Title I, Part A legislation. As a part of the corrective action plan, the Office intends to establish internal controls that ensure the three-step review will take place annually prior to awarding allocations to LEAs. Each level of review will be passed forward via email documenting that the allocation review has taken place and allocations are approved, in order of; 1. Accountant, 2. Office Administrator, 3. Bureau Administrator. Once all three reviews are completed and approved via the same email chain, the email will be saved on the department’s common drive for auditing purposes.
BEA will evaluate existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the expenditures reported in comparison to the expenditures incurred within the general ledger, account for precision level control when changing guidance ...
BEA will evaluate existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the expenditures reported in comparison to the expenditures incurred within the general ledger, account for precision level control when changing guidance exists, and that all documentation used to support the amounts reported on the federal report are properly maintained. Condition A has been completed. In January 2024, BEA evaluated internal controls related to the review and approval of expenditures. The following additional reconciliation step was added to the processes of preparation of expenditure draws and reporting preparation: • Broadband program Accountant II performs a data extract from NHFirst and reconciles the drawdown calculation totals as well as “dashboard” reporting totals to the NHFirst data extract to confirm accuracy of all data points. This second data validation step has been added to ensure all expenditures recorded in NHFirst are evaluated against program guidelines, submitted for reimbursement and included on required reports. Condition B & C to be completed no later than 12/31/2024.
Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 20...
Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 2022-002, the DAS had strengthened internal controls related to the review and validation of amounts reported by individual state agencies as pass through expenditures. This included an additional control specifically verifying SLFRF pass through expenditures reported by each agency. The DAS will offer additional training relative to identification and reporting of subaward expenditures in its annual statewide Single Audit training and re-evaluate the precision of execution of controls over the validation of pass through reporting in assembling the SEFA for fiscal year 2024. Corrective Action Planned (Conditions B through E): The State largely concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. The State has already begun this corrective action plan with the agencies. With regards to condition C, for a. and b. for payments by agencies, there are standard procedures for review and authorization of invoices and payments and those payments are documented. For c. The State has already implemented an agency wide framework for subrecipient monitoring. The State will provide re-training for those agencies that had not properly documented monitoring as outlined by the subrecipient risk assessments and ensure monitoring reports are documented. With regards to condition D, The State has already implemented an agency wide framework to help ensure policies and procedures are in place concerning Uniform Guidance Reports. We will work those agencies that had not documented the date received and the review of the Uniform Guidance Reports to ensure written documentation occurs. Where findings have been reported in the Uniform Guidance Report, ensure timely Management Letters are documented and provided with the summary review of Uniform Guidance Report.
Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts,...
Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts, including contracts deemed subawards, greater than $10,000 are subject to legislative and executive branch approval prior to final execution. The resulting contracts are managed within the State’s financial system using purchase orders which in turn encumber funds. To support the testing of procurements, the State provided a detailed listing of purchase orders initiated during the audit period and in doing so clearly expressed the resulting population would include contracts considered subawards. Accordingly, the State deems the portion of selections identified as subawards to be reasonable and appropriate given the population sampled. However, the DAS will re-evaluate the precision of execution of controls over the validation of the subrecipient population in fiscal year 2024. Corrective Action Planned (Condition B): The State concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies maintain and document the search of SAM.gov for suspension and debarment.
In order to meet the segregation of duties, the Department will explore the need to create a position to ensure requisite segregation of duties requirements. With regard to the segregation of duties, the SF-270 is required form that DMAVS submits to the National Guard Appendix Program Manager for re...
In order to meet the segregation of duties, the Department will explore the need to create a position to ensure requisite segregation of duties requirements. With regard to the segregation of duties, the SF-270 is required form that DMAVS submits to the National Guard Appendix Program Manager for reimbursement with all back up documentation. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense on behalf of DMAVS to request the cash draw. Prior to the submission of reimbursement of any funds, each billing and invoice is reviewed, entered into a ledger and reconciled by three members of the accounting team. Once reconciled, the SF-270 is prepared and signed by the Financial Administrator. The SF-270 is then submitted to the appendix program manager for concurrence and then to the federal fiscal agent (USPFO) for approval. No funds are drawn down until approved by the USPFO. If this is not a satisfactory level of review, the department will request a new position to ensure that there the business function has the proper level of staffing to meet the requirements for segregation of duties.
For clarity the Department will create a redundant manual ledger that duplicates the functions of the current ledger and Detailed Transaction Register (DTR). DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all tr...
For clarity the Department will create a redundant manual ledger that duplicates the functions of the current ledger and Detailed Transaction Register (DTR). DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all transactions that reconciles every month to NH First Detail Transaction Register (DTR), Federal Fund tracking sheet, and Federal reimbursement tracking sheet with backup documents. The tracking sheet for the federal register is not intended to account for the state share of billing. The state share is accurately accounted for in the DTR, the cumulative accounting in the SF-270 and associated back up documentation. Supporting documentation to substantiate the accuracy of lines a, c, e, and f is in the DTR, the cumulative accounting of each SF-270, the supporting documentation sent with the billing to the Federal Government, and Year-end Agency Report for Federal Awards. This includes reconciliation and analysis of SADB expenditures and revenues to the Statement of Appropriations by each Program Accounting Unit. The SF-270 form is continuous cumulative data that starts Oct 1st and runs through the end of that Federal Fiscal Year. The SF-270 is the required federal form DMAVS submits to the Federal National Guard Appendix Program Manager for reimbursement. Back up documentation is submitted with the SF-270. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense to affect the cash draw. DMAVS does not unilaterally make cash draws to the federal government. The USPFO, who is substantially involved provides an independent review and reconciles any discrepancies prior to approving any requests for reimbursement. One possible explanation for the finding is that the selected test works were not continuous.
Department of Health and Human Services: Federal Financial Assistance Listing #93.498 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN #426037759 Activities Allowed or Unallowed and Allowable Costs/Cost Principles ...
Department of Health and Human Services: Federal Financial Assistance Listing #93.498 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN #426037759 Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: Guthrie County Hospital (the Hospital) reported expenses in the Department of Health and Human Services (HHS) special report for Period 4 that were not reduced by reimbursement from other sources or that other sources were obligated to reimburse. Additionally, the Hospital did not report its excess expenses as unreimbursed expenses attributable to Coronavirus in the HHS special report, did not report total interest earned on the ARP Rural Payments and Period 4 General Distribution Payments, and reported gross revenues/net charges from patient care by quarter for 2021 when net revenues should have been reported. In addition, there was no evidence retained that the HHS special report was reviewed by an individual separate from the preparer prior to submission. Planned Corrective Action: Management will implement an internal control policy for federal awards compliance to more diligently review the reporting of expenses and revenues to ensure all reporting requirements are met. However, had the errors in reporting of expenses and lost revenues been identified and corrected prior to reporting, the Hospital would have demonstrated that they had incurred eligible expenses and lost revenue in excess of the Period 4 funds received, including interest on such funds. Contact Person, Title and Phone Number: Christopher Stipe, Chief Executive Officer, (641)332-2201 Anticipated Date of Completion: June 30, 2024
2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation support...
2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation supporting that vendors were reviewed for suspension and debarment. There was also no documentation for review of the procurement transactions tested. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: Changing the personnel involved has solved much of the problem, also the full awareness of what needs to be retained has also been explained to management. Management intends to add a Director level executive in the spring of 2024 to fully review and revise where necessary all standard operating procedures, including that of procurement. If/when funds from federal sources are used, those expenditures will be reviewed monthly. Specifically, this will mean: -Maintain EIDL‐sourced funds in a separate bank/account - Have single authorization for any movement/usage of funds in EIDL account - If/when funds from EIDL are used, have a written statement for purposes and documentation produced for use at the time of request Responsible Individuals: -Maintain separate account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024
2023‐004 Material Weakness in Internal Control over Compliance – Other for Preparation of Schedule of Expenditures of Federal Awards Condition: The Organization does not have an internal control system designed to provide for the preparation of the schedule. There was no documentation of review of t...
2023‐004 Material Weakness in Internal Control over Compliance – Other for Preparation of Schedule of Expenditures of Federal Awards Condition: The Organization does not have an internal control system designed to provide for the preparation of the schedule. There was no documentation of review of the Schedule retained and the Schedule required adjustments. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: The weekly tracking of expenses as indicated in #3 will keep the issue top of mind throughout the year. The CEO will review all Schedules and reports prior to their submission for audit review. Responsible Individuals: - Accountability for understanding and management of the entire process – Marcia Meyer, CEO - Preparation of regular schedules during year – Jennie Myers - Preparation of quarterly schedule updates – Jennie Myers - Approval of quarterly schedules and presentation to Finance Committee – Marcia Meyer (approval) and Jennie Myers -Preparation of annual schedule in advance of the audit – Jennie Myers - Approval of annual schedule before submiting for audit – Marcia Meyer Anticipated Completion Date: This will be implemented immediately and will be up to date by June 2024
2023‐003 Material Weakness in Internal Control over Compliance with Actvities Allowed Unallowed and Allowable Costs/Cost Principles Condition: The Organiza􀆟on did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing av...
2023‐003 Material Weakness in Internal Control over Compliance with Actvities Allowed Unallowed and Allowable Costs/Cost Principles Condition: The Organiza􀆟on did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: The CEO will add a regular discussion point to the weekly finance meetings in which the finance department reports on both the status of federal funds and the expenditures using those funds. Responsible Individuals: -Maintain separate tracking account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024
Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance req...
Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Planned Corrective Action - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Finding 390465 (2023-003)
Significant Deficiency 2023
Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student...
Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student Business Services, working with the Director of Financial Aid, will identify to the Vice-President of Business Affairs (VPBA) those students who are scheduled to receive special supplemental institutional aid (refer to Note below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required fourteen (14) day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (“The Godard Scholarship”). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their account. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Jerry Wright VP Business Affairs/CFO Anticipated Completion Date: Academic Year 2023-2024
Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students w...
Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Planned Corrective Action: The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Re status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty-eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third-party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. Re student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third-party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: Academic Year 2023-2024
Finding 390452 (2023-003)
Significant Deficiency 2023
Corrective Actions Taken or Planned: Going forward for payments, under the direction of the Executive Director, Rachel Erpelding, the Kim Wilson Housing Staff will sign-off on the access database check request sheets and have the Executive Director provide her physical signature as written evidence ...
Corrective Actions Taken or Planned: Going forward for payments, under the direction of the Executive Director, Rachel Erpelding, the Kim Wilson Housing Staff will sign-off on the access database check request sheets and have the Executive Director provide her physical signature as written evidence of the review and approval process for housing payments. For drawdowns, beginning July 2023, the Director of Fiscal Services, Linnea Cullumber, implemented a monthly reconcile process between the housing check payment requests and grant billing drawdown support provided by the Kim Wilson Housing Staff. The accounting staff now reconcile the payment and drawdown support, then retain the email correspondence supporting the drawdown process providing confirmation of review and approval. Rachel Erpelding, Executive Director of Kim Wilson Housing, and Linnea Cullumber, Director of Fiscal Services are responsible for this corrective action plan. The anticipated completion date is 3/31/24.
Finding 390451 (2023-002)
Significant Deficiency 2023
Corrective Actions Taken or Planned: Under the direction of the Executive Director, Rachel Erpelding, the Grant Specialist with Kim Wilson Housing is responsible for collecting data and tracking the grant match total in the housing access database. During the fiscal year ended June 30, 2023, there ...
Corrective Actions Taken or Planned: Under the direction of the Executive Director, Rachel Erpelding, the Grant Specialist with Kim Wilson Housing is responsible for collecting data and tracking the grant match total in the housing access database. During the fiscal year ended June 30, 2023, there wasn’t a 2nd level physical signature of approval on the match tracking documents. Going forward, the Grant Specialist will print and sign the match tracking document and the Executive Director will approve the printed tracking sheet from the housing database. Rachel Erpelding, Executive Director of Kim Wilson Housing, is responsible for this corrective action plan. The anticipated completion date is 3/31/24.
Condition: The District did not include the necessary suspension and debarment language required for Child Nutrition Cluster related contractors with bids in excess of $25,000. Upon further review, it was determined that the vendors were not suspended or debarred. Plan: Procedures have been implemen...
Condition: The District did not include the necessary suspension and debarment language required for Child Nutrition Cluster related contractors with bids in excess of $25,000. Upon further review, it was determined that the vendors were not suspended or debarred. Plan: Procedures have been implemented to ensure all vendors contracted in excess of $25,000 related to the Child Nutrition Cluster program are not suspended, debarred, or otherwise excluded from doing business, prior to procuring their services. Anticipated Date of Completion: July 2023 Name of Contact Person: Ron McCord, Superintendent Management Response: There is no disagreement with this finding. Upon being notified of the finding in the previous year, certifications regarding debarment and suspension were required with all bids returned by vendors. However, this control was not implemented in time for bids relating to the 2022-2023 school year. All vendors were verified to not be suspended or debarred, but contracts already in place were not updated to include the required language. This issue has now been resolved.
Finding 390445 (2023-004)
Significant Deficiency 2023
Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement ...
Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all student loan documentation is maintained per the U.S. Department of Education policies. Management will assign the respective loans back to the Department of Education as to be in compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
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