Corrective Action Plans

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Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Cap...
Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024
View Audit 300191 Questioned Costs: $1
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are reme...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are remediated and brought into compliance. Some of these have already been remediated. We will work with other departments who administer third party vendor accounts to enforce MFA where there are gaps. A penetration test and the standing up of a tool to continuously monitor our network internally and those of third party vendors are already in startup phases Our information security program and risk assessment will be updated to reflect any recommendations offered by our auditors to fill any existing gaps in the 2023 audit. Person Responsible for Corrective Action Plan: Ron Loneker, Jr., Director, IT Special Projects Anticipated Date of Completion: May 31, 2024
Finding 388461 (2023-002)
Significant Deficiency 2023
2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the ...
2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. Corrective Actions Taken: Julie Brown, the Registrar will be given access to the NSLDS database to verify the information submitted through the National Student Clearinghouse is reported completely and accurately, particularly in relation to enrollment statuses that change during the non-required summer terms. This is part of an ongoing process as this information is updated multiple times per year. The Registrars Office will also draft a policy including timelines for uploading information to the National Student Clearinghouse and dates for verification of information in NSLDS. Responsible party: Julie Brown, Registrar. 718-780-7918 julie.brown@brooklaw.edu
Finding 388460 (2023-001)
Significant Deficiency 2023
2023-001 Program Eligibility—Significant Deficiency United States Department of Education - ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s ac...
2023-001 Program Eligibility—Significant Deficiency United States Department of Education - ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s accreditation and authorized by the State and the US Department of Education. Condition: The Law School disbursed federal student aid to 63 students, totaling approximately $2,115,747, enrolled in an ineligible program; the LL.M. program. Context: The impact was to 63 students over a four-year period. Cause: The Master of Laws (LL.M) Program was included in the Law School’s ECAR which was approved by the Department of Education. The Law School’s accreditation by the American Bar Association does not cover programs outside of the Juris Doctorate program. As such, the LL.M program was not properly accredited and therefore not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in an ineligible program which resulted in the Law School entering into a settlement agreement with the U.S. Department of Education pursuant to which the Law School reimbursed and paid a fine to the US Department of Education. Questioned Costs: $2,115,747 Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. Corrective Actions Taken: Upon notification from Department of Education regarding this concern, the Law School discontinued disbursement of Title IV funds to students of the LL.M. program and will not disburse those funds to students of that program until it receives additional accreditation. The Law School is currently working on obtaining accreditation from the Middle States Commission on Higher Education for its existing LL.M. and future Master’s degree programs. Responsible Person: David D. Meyer, President and Dean, (718) 780-7901, david.meyer@brooklaw.edu
View Audit 300177 Questioned Costs: $1
Significant Deficiency
Significant Deficiency
Finding 2023-002
Finding 2023-002
Eligibility
Eligibility
U.S. Department of Health and Human Services
U.S. Department of Health and Human Services
HIV CARE Formula Grants
HIV CARE Formula Grants
CFDA No. 93.917
CFDA No. 93.917
During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomp...
During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that:
·         For one of the 60 clients selected, the letter HHHRC received indicating that the client was homeless was not verified and documented in the file.
·         For one of the 60 clients selected, the letter HHHRC received indicating that the client was homeless was not verified and documented in the file.
·         For 6 of the 60 client files selected, the files contained lab reports; however no follow up confirmation forms from a medical provider for HIV verification were documented.
·         For 6 of the 60 client files selected, the files contained lab reports; however no follow up confirmation forms from a medical provider for HIV verification were documented.
·         For one of the 60 client files selected, the file contained a confirmation form for HIV verification that was not signed by a physician.
·         For one of the 60 client files selected, the file contained a confirmation form for HIV verification that was not signed by a physician.
Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration’s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification ...
Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration’s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter.
Per HHHRC’s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an inte...
Per HHHRC’s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver’s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC’s policy states that they must, at a minimum, assess and re-assess the client’s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage.
HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2023-001, HHHRC updated thei...
HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2023-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager.
HHHRC did not comply with the RWB program eligibility requirements for the instances noted above.
HHHRC did not comply with the RWB program eligibility requirements for the instances noted above.
Questioned Costs
Questioned Costs
No questioned or known costs were identified.
No questioned or known costs were identified.
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