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Corrective Action Plans

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Finding 388295 (2023-002)
Significant Deficiency 2023
Georgetown College
KY
Eligibility Special Tests & Provisions
A. Comments on the Finding and Recommendations: The College concurs with the finding of not providing the Right to Cancel notification to 5 students in the sample. Auditor Recommendation: We recommend the College update their notification to students to include wording about students right to cancel...
A. Comments on the Finding and Recommendations: The College concurs with the finding of not providing the Right to Cancel notification to 5 students in the sample. Auditor Recommendation: We recommend the College update their notification to students to include wording about students right to cancel their TEACH Grant. B. Actions Taken or Planned: The College will follow the auditor's recommendation to update the notification to students and notes that this as an isolated incident. The College will review and update their disbursement notification process for the TEACH Grant. The update will be aligned with the disbursement notification procedures used for the Direct Loan program. Additionally, the third-party servicer will perform internal control reviews during each pay period to verify accurate and timely dissemination of disbursement notifications for TEACH Grant.
View Audit 300086
Georgetown College
KY
Questioned Costs Eligibility Special Tests & Provisions
A. Comments on the Finding and Recommendations: The College concurs with this isolated finding for two students in the sample. Auditor recommendation: We recommend the College implement procedures and review the aggregate amount of TEACH Grant disbursed to all students to verify the student is not o...
A. Comments on the Finding and Recommendations: The College concurs with this isolated finding for two students in the sample. Auditor recommendation: We recommend the College implement procedures and review the aggregate amount of TEACH Grant disbursed to all students to verify the student is not over disbursed. B. Actions Taken or Planned: The College will follow the auditor's recommendation and review the current procedures to reduce the risk of human error. The College will implement a tracking mechanism for TEACH Grant awards to monitor the award limit statuses for students throughout their enrollment period. Training will be provided to the financial planning staff regarding the awarding and maximum eligibility for TEACH Grants. Additionally, the third-party servicer will perform internal control reviews during each pay period to verify accurate awarding of the TEACH Grant.
View Audit 300086 Questioned Costs: $1
Finding 388293 (2023-101)
Significant Deficiency 2023
Mohave County
AZ
Internal Control / Segregation of Duties
Agreed. The County will implement enhanced review for all external reporting. The reporting deficiency for the LATCF program arose from differences between the offline Excel-based reporting template and the data keyed into the online reporting portal (which was ultimately submitted to the U.S. Depar...
Agreed. The County will implement enhanced review for all external reporting. The reporting deficiency for the LATCF program arose from differences between the offline Excel-based reporting template and the data keyed into the online reporting portal (which was ultimately submitted to the U.S. Department of the Treasury). In the future, both the reporting template and the final submission will be reviewed by a member of management who is not involved in report preparation.
View Audit 300083
Finding 388290 (2023-001)
Significant Deficiency 2023
Shasta County Office of Education
CA
Subrecipient Monitoring Eligibility School Nutrition Programs
This error was due to clerical oversight. The program has reviewed the processes in place with the appropriate staff and has implemented additional layers of review to ensure compliance.
This error was due to clerical oversight. The program has reviewed the processes in place with the appropriate staff and has implemented additional layers of review to ensure compliance.
View Audit 300075
Finding 388289 (2023-002)
Significant Deficiency 2023
Shasta County Office of Education
CA
Allowable Costs / Cost Principles
This error was the result of inadvertent oversight. Initially, this resource allowed indirect costs and the validation tables from CDE allowed the account component combination. Information was subsequently changed by CDE to issue guidance to charge the indirect cost for the learning loss component ...
This error was the result of inadvertent oversight. Initially, this resource allowed indirect costs and the validation tables from CDE allowed the account component combination. Information was subsequently changed by CDE to issue guidance to charge the indirect cost for the learning loss component to the ESSER III Fund. CDE's website was updated on October 16, 2023, with this guidance well after the year end close was complete. Staff will implement additional processes to ensure valid application of indirect cost charges to grant programs.
View Audit 300075
Finding 388288 (2023-008)
Material Weakness 2023
Union Theological Seminary in the City of New York
NY
Student Financial Aid Matching / Level of Effort / Earmarking Reporting
This Repeat Finding has been acknowledged. Union has completed its implementation of our Corrective Action Plan for this item, which involved entering into a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as ...
This Repeat Finding has been acknowledged. Union has completed its implementation of our Corrective Action Plan for this item, which involved entering into a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timeline and consistent reporting to the National Student Loan Data System (NSLDS). As of January 2024, Union has completed the set-up and configuration of the new services. The new system will be managed by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. This back-up involves both the Academic and Financial Aid offices in order to improve our ability to address issues brought about by staff absences and/or turnover. UTS has completed enrollment reporting submissions via the NSC master service agreement on 12/20/23, 1/10/24, 2/05/24, 2/20/24 and 3/10.24 . Subsequent transmissions will continue to take place according to a pre-set schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission and notification of potential errors. Union’s new Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office and IT Department to ensure that all student records accurately and correctly configured.
View Audit 300074
Finding 388280 (2023-001)
Significant Deficiency 2023
City of Pomona
CA
HUD Housing Programs
The City will commence quality control re-inspections as soon as possible, either by contracting with another public housing agency, or by hiring or contracting with a part-time inspector.
The City will commence quality control re-inspections as soon as possible, either by contracting with another public housing agency, or by hiring or contracting with a part-time inspector.
View Audit 300062
Finding 388279 (2023-002)
Significant Deficiency 2023
Peralta Community College District
CA
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
Action taken in response to finding: The district in collaboration with the colleges has established procedures, notification protocols, adjusted business processes and trained financial aid staff over the past year to address this audit finding. The District will continue to work closely with each ...
Action taken in response to finding: The district in collaboration with the colleges has established procedures, notification protocols, adjusted business processes and trained financial aid staff over the past year to address this audit finding. The District will continue to work closely with each college to return funds to the Department of Education in a timely manner. Query reports have been created to identify funds to be slated for return. This effort is monitored on a regular basis by the college Dean of Student Services and their Business Service Office. Planned completion date for corrective action plan: March 31, 2024.
View Audit 300059
Finding 388278 (2023-001)
Significant Deficiency 2023
Peralta Community College District
CA
Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency § 200.303
Action taken in response to finding: The District continues to enlist the assistance of Huron and other vendors to assess our internal controls over financial aid federal awards. The district collaborates with external entities to engage in comprehensive training to district-wide staff involved in s...
Action taken in response to finding: The District continues to enlist the assistance of Huron and other vendors to assess our internal controls over financial aid federal awards. The district collaborates with external entities to engage in comprehensive training to district-wide staff involved in student financial aid processing. College FA staff are sent regular reminders to reconcile and perform R2T4 calculations. Management is actively recruiting to fill vacant positions in this area across the district. Planned completion date for corrective action plan: June 30, 2024.
View Audit 300059
Finding 388277 (2023-007)
Material Weakness 2023
Circle of Nations School INC
ND
Allowable Costs / Cost Principles § 200.430
A/B. Allowable Costs and Cost Principles/Activities Allowed or Unallowed Administrative Cost Grants for Indian Schools FFAL #15.046 Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: During the course of the engagement, Eide Bailly identif...
A/B. Allowable Costs and Cost Principles/Activities Allowed or Unallowed Administrative Cost Grants for Indian Schools FFAL #15.046 Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: During the course of the engagement, Eide Bailly identified four expenditures where payroll was not paid in accordance with employment letter. Corrective Action Plan: Anticipated Completion Date: The School will review internal controls surrounding allowable costs and activities to ensure they are adequate to identify unallowable expenditures. June 30, 2024
View Audit 300047
Finding 388276 (2023-008)
Material Weakness 2023
Circle of Nations School INC
ND
Allowable Costs / Cost Principles § 200.430
A/B. Allowable Costs and Cost Principles/ Activities Allowed or Unallowed Indian School Equalization FFAL #15.042 Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: During the course of the engagement, Eide Bailly identified five expenditu...
A/B. Allowable Costs and Cost Principles/ Activities Allowed or Unallowed Indian School Equalization FFAL #15.042 Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: During the course of the engagement, Eide Bailly identified five expenditures Corrective Action Plan: Anticipated Completion Date: where payroll was not paid in accordance with employment letter. The School will review internal controls surrounding allowable costs and activities to ensure they are adequate to identify unallowable expenditures. June 30, 2024
View Audit 300047
Governors State University
IL
Reporting § 200.303
2023-005 FINDING: FAILURE TO FILE REAL PROPERTY STATUS REPORT Corrective Action Plan: The University already has existing procedures in place to ensure that required reports are submitted. The report not being submitted was just a misunderstanding on the part of the employee submitting the report...
2023-005 FINDING: FAILURE TO FILE REAL PROPERTY STATUS REPORT Corrective Action Plan: The University already has existing procedures in place to ensure that required reports are submitted. The report not being submitted was just a misunderstanding on the part of the employee submitting the report as there was no real property acquired from the Early Head Start grant funds. The University believes that this matter did not have a direct and material effect on the University’s compliance with federal requirements. Responsible University Personnel: Andrea Middleton, Director of Financial Services/Assistant Controller; Villalyn Baluga, Associate Vice President for Finance. Anticipated completion date: Already implemented.
View Audit 300046
Finding 388274 (2023-004)
Significant Deficiency 2023
Governors State University
IL
Questioned Costs Allowable Costs / Cost Principles Reporting § 200.303 § 200.430
2023-004 FINDING: INADEQUATE CONTROLS OVER PAYROLL EXPENDITURES AND NONCOMPLIANCE WITH ALLOWABLE COST & COST PRINCIPLES REQUIREMENTS APPLICABLE TO THE HEAD START CLUSTER Corrective Action Plan: The University has updated its process to collect time and effort information on a semi-annual basis ra...
2023-004 FINDING: INADEQUATE CONTROLS OVER PAYROLL EXPENDITURES AND NONCOMPLIANCE WITH ALLOWABLE COST & COST PRINCIPLES REQUIREMENTS APPLICABLE TO THE HEAD START CLUSTER Corrective Action Plan: The University has updated its process to collect time and effort information on a semi-annual basis rather than quarterly, which relieves some burden from staff, but still complies with federal regulations. By collecting time and effort information on a semi-annual basis, staff will have more time to reconcile time and effort against actual payroll expenditures. The University has also redesigned the time and effort collection form to show the 100% distribution of work. Further, the University now has a full-time financial research administrator who will help ensure that payroll related adjustments are done timely. The financial research administrator will work with the Early Head Start program management to ensure that the related payroll reports are reviewed and reconciled timely, in accordance with existing University procedures. Responsible University Personnel: Erin Soto, Executive Director of Family Development Center; FeMia Norwood, Director of Office of Sponsored Programs and Research; Jessica Braddy, Financial Research Administrator. Anticipated completion date: Already implemented.
View Audit 300046 Questioned Costs: $1
Finding 388266 (2023-003)
Significant Deficiency 2023
Governors State University
IL
Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303
2023-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University is currently drafting the incident response plan and is working to secure a contract with an incident response firm. Additionally, the University recently hired an Information Security Analyst, a ne...
2023-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University is currently drafting the incident response plan and is working to secure a contract with an incident response firm. Additionally, the University recently hired an Information Security Analyst, a newly created position designed to address smaller-scale alerts and incidents. Responsible University Personnel: Charles Pustz, Associate Vice President for Information Technology Services and Chief Information Officer; David Weissbohn, Director of Information Security and Compliance. Anticipated completion date: Upon the Illinois Public Higher Education Cooperative’s (IPHEC) vendor decision and upon approved funding, ITS is hoping to have a firm engaged by end of Fiscal Year 2024.
View Audit 300046
Finding 388265 (2023-002)
Significant Deficiency 2023
Governors State University
IL
Reporting Matching / Level of Effort / Earmarking Student Financial Aid § 200.303
2023-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University has already identified a method to report directly to the U.S. Department of Education’s National Student Loan Data System (NSLDS) all enrollment changes occurring after the end of the term. The University will continue...
2023-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University has already identified a method to report directly to the U.S. Department of Education’s National Student Loan Data System (NSLDS) all enrollment changes occurring after the end of the term. The University will continue to update timely the NSLDS enrollment history as needed when the situation of late withdrawals occurs beyond the reporting dates. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Already implemented.
View Audit 300046
Anne Arundel County, Maryland
MD
Subrecipient Monitoring Special Tests & Provisions
2023-004: 20.205 – WB&A Trail (highway Planning and Construction) • Recommendation: We recommend that the County formalize its agreement with the pass-through entity to clarify the responsibilities for the special test’s requirements. • Explanation of disagreement with audit finding: There is no dis...
2023-004: 20.205 – WB&A Trail (highway Planning and Construction) • Recommendation: We recommend that the County formalize its agreement with the pass-through entity to clarify the responsibilities for the special test’s requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Purchasing Division will follow Federal regulation to ensure all requirements are addressed either in the solicitation documents or in the project manual. • Name of the contact person responsible for corrective action: Catrice Parsons, Purchasing Agent – Central Services, Purchasing Division. • Planned completion date for the corrective action plan: June 30, 2024.
View Audit 300045
Anne Arundel County, Maryland
MD
Subrecipient Monitoring § 200.332
2023-003: 21.027 – COVID-19 – American rescue Plan Act Funds (US Treasury ARPA) • Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Explanation of disagreement with audit finding: There is no dis...
2023-003: 21.027 – COVID-19 – American rescue Plan Act Funds (US Treasury ARPA) • Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will create a written plan to ensure that subrecipients are aware of all the needed Uniform Guidance requirements. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance. • Planned completion date for the corrective action plan: June 30, 2024.
View Audit 300045
Anne Arundel County, Maryland
MD
Reporting Subrecipient Monitoring
2023-002: 14.218 – CDBG – Entitlement Grants Cluster • Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Cor...
2023-002: 14.218 – CDBG – Entitlement Grants Cluster • Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: Management agrees to review the current procedures for submitting the required information through the Federal Funding Accountability and Transparency Act Subaward Reporting System to ensure the requirement for submission is met. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance
View Audit 300045
Finding 388244 (2023-001)
Material Weakness 2023
Anne Arundel County, Maryland
MD
Questioned Costs Subrecipient Monitoring § 200.331 § 200.332
2023-001: 172.258, 17.259, 17.278 – WIOA Cluster • Recommendation 1: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Recommendation 2: We recommend the County performs the monitoring of the subrecipients and e...
2023-001: 172.258, 17.259, 17.278 – WIOA Cluster • Recommendation 1: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Recommendation 2: We recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will (1) develop a written plan to ensure that subrecipients are aware of all the Uniform Guidance requirements; (2) due to the pandemic and the recent retirement and resignation of the top two Grant department staff members, the monitoring was not conducted during the audit period. Management will make sure that the required monitoring will be conducted and ensure compliance and proper documentation is maintained onsite. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance and Charles Knapp, Anne Arundel Workforce Development Corporation. • Planned completion date for the corrective action plan: June 30, 2024.
View Audit 300045 Questioned Costs: $1
William Peace Universirty
NC
Eligibility
The Financial Aid Department will review processes and put proper procedures and training in place to ensure the proper calculation for cost of attendance is being used. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Complet...
The Financial Aid Department will review processes and put proper procedures and training in place to ensure the proper calculation for cost of attendance is being used. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Completion Date: September 2024
View Audit 300044
William Peace Universirty
NC
Student Financial Aid Eligibility
The Financial Aid Department will review processes and put proper procedures and training in place to ensure Federal Pell Grant awards are properly calculated and awarded. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Compl...
The Financial Aid Department will review processes and put proper procedures and training in place to ensure Federal Pell Grant awards are properly calculated and awarded. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Completion Date: September 2024
View Audit 300044
Finding 388237 (2023-001)
Material Weakness 2023
William Peace Universirty
NC
Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
The Financial Aid Department will review processes and put proper procedures in place to ensure award notifications are sent out to students receiving direct loans. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Completion ...
The Financial Aid Department will review processes and put proper procedures in place to ensure award notifications are sent out to students receiving direct loans. Individuals Responsible for Corrective Action Plan: Damon Wade, VP for Enrollment Management and Marketing. Anticipated Completion Date: September 2024
View Audit 300044
Finding 388236 (2023-002)
Significant Deficiency 2023
The Haven, Inc.
LA
Internal Control / Segregation of Duties Significant Deficiency
Condition: A significant control deficiency in internal control over the major federal program related to the lack of segregation of duties. Recommendation: The Board of Directors of The Haven, Inc. should closely monitor the day-to-day activities of the major federal program and implement other con...
Condition: A significant control deficiency in internal control over the major federal program related to the lack of segregation of duties. Recommendation: The Board of Directors of The Haven, Inc. should closely monitor the day-to-day activities of the major federal program and implement other control procedures until it is cost beneficial to hire additional staff. Planned Action: The Board of Directors will closely monitor the day-to-day activities of the major federal program until it is cost beneficial to employ additional staff.
View Audit 300031
Finding 388235 (2023-001)
Significant Deficiency 2023
Heritage Valley Health System, INC
PA
Reporting Significant Deficiency Internal Control / Segregation of Duties
Finding 2023-001—Significant Deficiency in Internal Controls over Compliance and Noncompliance Finding: ALN#93.498 Provider Relief Fund and American Rescue Plan Rural Distribution Contact Person: Garrett Richardson, Associate Vice President of Finance Department; Haley Kotun, Supervisor of Finan...
Finding 2023-001—Significant Deficiency in Internal Controls over Compliance and Noncompliance Finding: ALN#93.498 Provider Relief Fund and American Rescue Plan Rural Distribution Contact Person: Garrett Richardson, Associate Vice President of Finance Department; Haley Kotun, Supervisor of Finance Department Views of Responsible Officials: Management agrees and acknowledges that Heritage Valley is responsible to enhance the control and process to ensure future federal reporting deadlines are met. For this late reporting instance, management will comply with HRSA’s reporting instructions when such instructions become available. Corrective Action Plan and Expected Completion Date Heritage Valley management will ensure controls surrounding the timeliness of federal grant reporting, including appropriate communication between finance personnel to comply with required federal reporting time periods, are remediated and operating effectively. To date, Heritage Valley has been in close contact with HRSA to seek approval for Request to Report Late Due to Extenuating Circumstances and such approval has been made verbally. Management expects to take immediate action once Heritage Valley receives written notification from HRSA for the status of approval and modified report submission deadline.
View Audit 300014
Finding 388234 (2023-003)
Significant Deficiency 2023
Community Capital New York, Inc.
NY
Reporting Allowable Costs / Cost Principles Internal Control / Segregation of Duties
Internal Controls over Compliance Requirements of Federal Awards Review process -- Recommendation We recommend that another level of review of the quarterly reporting be added to the review process. The person responsible for this additional review should be familiar with the grant budget and the un...
Internal Controls over Compliance Requirements of Federal Awards Review process -- Recommendation We recommend that another level of review of the quarterly reporting be added to the review process. The person responsible for this additional review should be familiar with the grant budget and the underlying supporting documentation that should be used to correctly calculate allowable salary and benefit costs. In the event that mistakes happen, the Organization should advise the federal agency on a timely basis and appropriately amend the reports. Corrective Action Plan -- The following procedures have been implemented: The Chief Executive Officer is reviewing quarterly Federal Awards reports before issuance, and comparing to supporting documentation.
View Audit 300013
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