Corrective Action Plans

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Finding 390442 (2023-003)
Significant Deficiency 2023
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Explanation of disagreeme...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. 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 required information is provided to the U.S. Department of Education. Additionally, Management will work to ensure that the required contract URL is provided the U.S. Department of Education, following the agency’s requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
Finding 390441 (2023-002)
Significant Deficiency 2023
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue...
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. 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 regarding stale-dated federal student financial aid outstanding checks. Management will implement additional procedures, returning checks issued directly by the University that stale-dated, similar to policies and procedures followed by the University’s third-party credit balance refund vendor. As part of this procedure, management will engage in student communication and outreach, similar to the University’s regular escheatment procedures. Management believes that a consistent practice between University-issued checks and third-party credit balance refund vendor-issued checks is in the best interest of students while also adhering to U.S. Department of Education timing requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
Finding 390438 (2023-001)
Significant Deficiency 2023
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting i...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. 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 enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: We recommend that management ensure the HUD contract renewal application is completed accurately and submitted timely in order to receive HUD approval at the start of the fiscal year. This is extremely important to ensure t...
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: We recommend that management ensure the HUD contract renewal application is completed accurately and submitted timely in order to receive HUD approval at the start of the fiscal year. This is extremely important to ensure the timely submission of the audited financial statements to REAC. Corrective Action: Upper Bay Counseling and Support Services, Inc. will have Senior Management and Financial staff working together via scheduled internal meetings to ensure the HUD approval at the start of the fiscal year is obtained. The contract renewal application and required follow up will be on the agendas of the internal HUD meetings. Proposed Completion Date: Management is implementing the above recommendation. UPDATE – as of March 20, 2024 this process is in place now as we plan to submit this information within the next few days. Thus this is considered implemented as we are working with various staff to ensure a timely and accurate submission in next few days.
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: The Project should accurately maintain the monthly rental schedule and reconcile the HUD voucher activity and tenant payments to the general ledger and bank statements. The rental activity should be reconciled monthly and t...
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: The Project should accurately maintain the monthly rental schedule and reconcile the HUD voucher activity and tenant payments to the general ledger and bank statements. The rental activity should be reconciled monthly and the Director of Finance should review the rental schedule monthly to ensure the reconciliation is accurate and all activity is properly accounted for during the year. Corrective Action: Upper Bay Counseling and Support Services, Inc. will implement monthly HUD financial meetings providing the oversight and review needed. Financial staff will submit a report to Senior Management of HUD financial matters on a regular basis. Proposed Completion Date: Management is implementing the above recommendation. UPDATE – March 20, 2024 A financial reporting package is in the process of being developed. There are regular monthly sessions between the Clinical and Financial staff to discuss financial matters. Thus, this is considered implemented.
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: Replacement reserve account should be reconciled monthly and reviewed to ensure all required deposit activity is made and there are no unapproved withdrawals from the account. Corrective Action: Upper Bay Counseling and S...
Contact person: Katherine Dannenfelser, Director of Finance Recommendation: Replacement reserve account should be reconciled monthly and reviewed to ensure all required deposit activity is made and there are no unapproved withdrawals from the account. Corrective Action: Upper Bay Counseling and Support Services, Inc. will implement monthly reporting of Replacement Reserve Account and other HUD information as part of an effort to improve internal financial reporting overall. Proposed Completion Date: Management is implementing the above recommendation. UPDATE-March 20, 2024 – This reporting requirement will be included in financial reporting package being developed. Information is being communicated in monthly meetings and emails as we have increased communication between Clinical and Financial staff. Anticipate supplemental schedules being added to basic financial package on or before June 30, 2023. Moving monthly amount for Reserves during March 2024 and will move on the first few business days of every month going forward.
To adjust as soon as possible and ensure it is not an issue in the future.
To adjust as soon as possible and ensure it is not an issue in the future.
To adjust as soon as possible and ensure it is not an issue in the future.
To adjust as soon as possible and ensure it is not an issue in the future.
To work with fee accountant in making the corrections necessary and recommended by the auditor.
To work with fee accountant in making the corrections necessary and recommended by the auditor.
2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: ...
2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director will reevaluate the controls and set in place policies and procedures for SEFA completion. Name(s) of the contact person(s) responsible for corrective action: Director of Restricted Funds Accounting, Symone Merritt Planned completion date for corrective action plan: October 2024
2023-008 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F – Cash Management Recommendation: We recommend the University formally document, establish controls and monito...
2023-008 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F – Cash Management Recommendation: We recommend the University formally document, establish controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will formally document, establish controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II Planned completion date for corrective action plan: June 2024
View Audit 301226 Questioned Costs: $1
2023-007 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F - Reporting Recommendation: We recommend the University enhances its procedures, controls, and review policie...
2023-007 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F - Reporting Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Business & Finance will populate and upload the quarterly CARES HBCU and Institutional reports by the 10th day after the end of each calendar quarter. The Office of Student Accounts will create and upload the quarterly CARES Student Portion reports by the 10th day after the end of each calendar quarter. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II & Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: May 2024
2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...
2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will strengthen procedures and reporting practices to ensure timely submission to the National Student Clearinghouse (NSCL) & the National Student Load Data System (NSLDS). The Registrar’s Office will confirm and ensure the submissions to the National Student Clearinghouse (NSCL) corresponds with the timeframe the enrollment is rolled over to the National Student Loan Data System (NSLDS). Name(s) of the contact person(s) responsible for corrective action: Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: July 2024
2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation o...
2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Information Technology is reviewing the written policies and procedures needed to safeguard the University’s applications and data. This includes all 3rd party developed/ implemented applications as well. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russel Weaver & VP/ Chief Information Officer, Darrell McMillion. Planned completion date for corrective action plan: June 2024
2023-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...
2023-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Business & Finance will review the procedures and work collaboratively with teams to investigate, research, and resolve any outstanding refunds. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Student Accounts, Carold Boyer-Yancy. Planned completion date for corrective action plan: June 2024
COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds ...
COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds have been spent and reports are posted on the website. No additional reports will need to be posted. Name(s) of the contact person(s) responsible for corrective action: Brenda Schumacher Planned completion date for corrective action plan: Prior to Summer 2023
Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...
Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC SAP policy has been corrected and updated to meet federal requirements on calculating the pace a student must progress through their educational program. Moving forward Financial Aid Management will review their policies and procedures annually to ensure that we are meeting all Department of Education SAP requirements. Name(s) of the contact person(s) responsible for corrective action: Kelsey Scott Planned completion date for corrective action plan: Spring 2024
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit le...
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The Authority must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). During our testing of 40 HCV tenant files, we noted annual HQS inspections for all the tested units. However, the Authority did not perform the required quality control re-inspections.Auditor’s Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Anticipated Completion Date: June 30, 2024
Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned  Corrective  Action:  The  Business  Manager  will  imme...
Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned  Corrective  Action:  The  Business  Manager  will  immediately  ensure  that  all  payroll  withholdings/ deductions will be processed properly along with all stipends. This will correct the quarterly Form 941 that will be filed by the Business Manager. All time sheets will be reviewed by Business Manager to make sure all employees hours are correctly paid.
Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: ...
Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: April 30, 2024 Planned  Corrective  Action:  Business  Manager  did  get  clarification  from  auditors  and  BIE  around  prevailing wage rates documentation. Projects completed did not have sufficient documentation showing  wage  rates  and  Business  Manager  now  knows  exactly  what  kind  of  documentation  is  needed to justify wage rates. BIE has assisted the Business Manager in where to get current wage rates  on  Sam.gov.  All  construction  projects  moving  forward  will  have  correct  documentation  for  wage rates.
Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Busines...
Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Business Manager has corrected the dates for the SF‐425 reporting. SF‐425 reports are turned in on time and all current SF‐425 reports have correct dates.
Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Correc...
Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Corrective Action: School did not have an HR Manager for school year 2022‐23 and the School recently hired an HR Manager. The Business Manager, with the help of the HR Manager, will ensure that School policies with sealed bids will be followed. The Business Manager will maintain all quotes  and  documentation  from  vendors.  The  School’s  current  policy  will  be  reviewed,  and  language will be added to address quotes and thresholds.
Finding 390401 (2023-002)
Significant Deficiency 2023
Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs a) One (1) out of six (6) stu...
Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs a) One (1) out of six (6) students tested for R2T4 did not have Title IV funds returned to the Federal government within the required 45 days. Title IV HEA 34 CFR 668.22. b) The College was not reconciling between Financial Aid and Business Office on the monthly basis per SFA Handbook Ch. 5 CFR668.161-668.176. Auditor’s Recommendation – We recommend that the College ensure adequate documentation is obtained and kept on file as evidence that all expenditures meet allowable cost and other requirements under the grant program. Corrective Action – Management agrees with this finding. The College will place additional emphasis on the R2T4 of funds. Management is reviewing the timing of presentation of situations to Financial Aid that require returning funds to the Department. Additional focus will be placed on procedures to timely report withdraws to Financial Aid to support returned funds in the required 45 days. In addition, the College prepares monthly reconciliations between Financial Aid and the Business Office, but often delayed in completion. Going forward, the reconciliation will be noted on the monthly closing list and requires both the Assistant Vice President of Financial Aid and Controller to sign and date the reconciliation to demonstrate compliance with the monthly requirement.
The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon a...
The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon as practical.
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit le...
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The Authority must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). During our testing of 40 HCV tenant files, we noted annual HQS inspections for all the tested units. However, the Authority did not perform the required quality control re-inspections.Auditor’s Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Anticipated Completion Date: June 30, 2024
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