Corrective Action Plans

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There are 10 audit findings total in calendar year 2022 and are all connected to a former staff person in the accounting function and also in the Trio Upward Bound program. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropr...
There are 10 audit findings total in calendar year 2022 and are all connected to a former staff person in the accounting function and also in the Trio Upward Bound program. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also reviewed and signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements. A new Trio Upbound Bound Director was also hired in fall 2023. Contact person(s) responsible for corrective action: Cassandra Turner, Manager of Account Services, and Sheila M. Brooks, Controller/Director of Business Services (new January 2024) Anticipated Completion Date: Immediate
The college will implement a two-step process to verify the FWS earnings reported on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the F...
The college will implement a two-step process to verify the FWS earnings reported on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the FISAP. Contact person(s) responsible for corrective action: Yvette McGee, Director of Financial Aid Anticipated Completion Date: August 30, 2024
FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, pre...
FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows:  The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain expenditures for the reporting period, however according to the School Corporation's records there were expenditures for ESSER I and ESSER II during this period.  The ESSER I, Year 3, ESSER II, Year 2, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To address and ensure Education Stabilization Funds are properly reported by the treasurer the treasurer will print out the form that was completed by the treasurer and must be signed by the superintendent or department head for review before submittal and filed for record keeping. Anticipated Completion Date: 3/11/2024
FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or...
FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or the pass-through entity. In addition, with prior approval by the ED or the passthrough entity, recipients and subrecipents may use ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. The School Corporation had not established policies or procedures to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirements. The School Corporation purchased two servers and completed a HVAC project using ESF funds however those items were not included on property records that included all the required information (including a description, source of funding, percentage of federal participation, location, and use and condition of the property). In addition, a physical inventory was not completed after the equipment was purchased. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure property records are maintained for equipment and real property purchased with federal funds and a physical inventory to be completed at least every two years. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Lewis Cass does have an asset management documentation but it has not been updated since October 2020. Lewis Cass has been actively pursuing an asset management vendor to perform a thorough review and update our current property. The items listed on this finding have been add to the property records. Lewis Cass has the task of finding a new asset management firm and update property records. This task will be completed by fiscal year 2025. Anticipated Completion Date: 6/30/2024
FINDING 2023-006 Finding Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Summary of Finding: Finding: The School Corporation had established policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds in...
FINDING 2023-006 Finding Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Summary of Finding: Finding: The School Corporation had established policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause prior to management signing the contract, however the School Corporation's policies did not include a system of internal controls to ensure that the required certified payrolls were submitted by the contractors. One construction contract, totaling $629,800 was paid from the Education Stabilization Fund grant funds. The one contract did contain the required prevailing wage rate clause however the School Corporation had not obtained the required payroll and statements of compliance related to the one contract. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the school distrcit. Recommendation: We recommended that the School Corporation's management establish a system of internal controls over the wage rate requirements and include the wage rate requirement clause in construction contracts. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. The controls were described in the contract for the contractor to provide weekly payroll verification but were not followed by the contractor or requested by Lewis Cass Schools. Lewis Cass Schools has put in place a letter to be sent to all contractors who meet the finding. This letter will address the finding for the remaining balance of the federal grant funds This letter will ensure weekly payrolls are sent from the contractors(s) to the Lewis Cass Schools for the duration of the project. Anticipated Completion Date: March 31, 2024
FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly de...
FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly designed and implemented internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles. There was not an oversight or review to ensure that the vendor claims were properly approved. The vendor claims were reviewed and approved by the department head and the Treasurer. However, during our review of the 40 vendor claims, there were 17 Accounts Payable Vouchers that were not approved by the department head and the Treasurer. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. To address and ensure vendor claims are properly approved by the department head and treasurer Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To ensure the internal control process is currently being followed, several vendor claims were pulled and reviewed. This review found there to be no vendor claims that were not verified by the department head and treasurer. Anticipated Completion Date: July 1, 2023V
FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured...
FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. Prior to entering subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non‐procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the audit period, sufficient internal controls were deficient in specific areas which prevented comprehensive program compliance. To address and rectify the issues as presented, vendor verification will be completed on an annual basis. The Food Service Director and Treasurer will confirm through documentation that vendors are not suspended or debarred using resources available. Documentation representing oversight and compliance will be retained and referenced as needed for verification. Anticipated Completion Date: Q2 2024 (6/30/2024)
FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities ...
FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities Allowed and Unallowed. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Lewis Cass Schools makes every effort to ensure proper documentation is obtained before processing vendor claims. To prevent oversight and strengthen internal controls, each level of management oversight has implemented stringent safeguards. All food service vendor claims will not be processed for payment without the authorization of the Food Service Director. Upon confirmation of the Food Service Director’s documented authorization, the Deputy Treasurer will document the authorization, and prepare the claim for the Treasurer. The Treasurer will ensure documented authorization of the Food Service Director and the Deputy Treasurer, along with the proper budget account code applied before releasing authorization for payment. The application of the procedures above will apply to all vendor claims for payment. Therefore, vendors meeting the thresholds for suspension and debarment will also be included. Anticipated Completion Date: Q2 2024 (6/30/2024)
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and is working to establish a clear understanding of the grant eligibility requirements with the grant coordinators to ensure eligibility requirements for the Uniform Guidance are fol...
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and is working to establish a clear understanding of the grant eligibility requirements with the grant coordinators to ensure eligibility requirements for the Uniform Guidance are followed. Anticipated Completion Date: This corrective action will be implemented by June 30, 2024.
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and is working to establish a clear understanding of the grant reimbursement process to ensure the proper amounts are charged to each grant. Anticipated Completion Date: This correcti...
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and is working to establish a clear understanding of the grant reimbursement process to ensure the proper amounts are charged to each grant. Anticipated Completion Date: This corrective action will be implemented by June 30, 2024.
View Audit 299575 Questioned Costs: $1
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and will implement the recommended procedures as soon as possible. Anticipated Completion Date: This corrective action will be implemented by June 30, 2024.
Contact Person: Interim Executive Director Fred Bazemore Corrective Action: The Organization agrees with the finding and will implement the recommended procedures as soon as possible. Anticipated Completion Date: This corrective action will be implemented by June 30, 2024.
Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United State...
Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the requirements applicable to the ESSER program.
View Audit 299573 Questioned Costs: $1
Finding # 2023-022 Title of Finding Activities Allowed or Unallowed Contact Person Jody Johnson, Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board has developed procedures to ensure that all purchase orders are approved before ord...
Finding # 2023-022 Title of Finding Activities Allowed or Unallowed Contact Person Jody Johnson, Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.
View Audit 299573 Questioned Costs: $1
Finding # 2023-021 Title of Finding Special Tests and Provisions Contact Person Anthony McDaniels Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will develop a Food Service Collection Policy and attempt to collect the outstanding balances on the receivables rel...
Finding # 2023-021 Title of Finding Special Tests and Provisions Contact Person Anthony McDaniels Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will develop a Food Service Collection Policy and attempt to collect the outstanding balances on the receivables related to the National School Lunch Program.
View Audit 299573 Questioned Costs: $1
Finding 387414 (2023-003)
Significant Deficiency 2023
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Respo...
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We are working to formalize this process by creating a written participant file review policy and procedure. Anticipated Completion Date: March 31, 2024
Finding 387412 (2023-002)
Material Weakness 2023
Finding Summary: There was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: Our Associate Director, Business Direct...
Finding Summary: There was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon completion of training, the team will provide the Finance Committee of the Board of Directors with suggested updates to our current policy. Anticipated Completion Date: March 31, 2024
Finding 387391 (2023-001)
Significant Deficiency 2023
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible...
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We will be updating our cash receipts process as part of an overall review of our accounting and financial policies and procedures that will include improvements in our internal control system. Anticipated Completion Date: Updated accounting and finance policies and procedures will be completed and implemented by the end of FY24.
Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expe...
Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expenditure approval process, as well as the process for maintaining records supporting all transactions. The policies in place require WISH management to approve all expenditures utilizing a requisition request form which includes a signature field for the initiator, a supervisor, and the Executive Director. WISH management will mandate that all requisition forms are signed (physically or digitally) to ensure compliance with the policy. In order to ensure compliance, WISH will conduct sessions to review the policies with staff and assign a team member to monitor adherence to the policies. Additionally, WISH policies require expenditure support for each transaction including physical and digital receipts and invoices. WISH management will conduct sessions to ensure knowledge of the existing procedures with staff. WISH will assign a team member to review compliance on a monthly basis to ensure compliance. Proposed Completion Date: June 30, 2024
The College will purchase a new physical inventory system to replace the existing system. During the beginning of COVID 19, the staff member working on equipment inventory was no longer assigned to the inventory management process Morris College. A new staff member has been assigned to the inventory...
The College will purchase a new physical inventory system to replace the existing system. During the beginning of COVID 19, the staff member working on equipment inventory was no longer assigned to the inventory management process Morris College. A new staff member has been assigned to the inventory process as of March 15, 2024
View Audit 299554 Questioned Costs: $1
Management will take necessary steps to adhere to the procurement policy. A new procurement policy has been implemented that complies with federal procurement regulations and is currently in effect as of July 1, 2023.
Management will take necessary steps to adhere to the procurement policy. A new procurement policy has been implemented that complies with federal procurement regulations and is currently in effect as of July 1, 2023.
View Audit 299554 Questioned Costs: $1
Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a time...
Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Superintendent, Dr. Angela Piazza and the Director of Grants, Eric Knebel. The corrective action will be implemented starting immediately.
Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technolo...
Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technology will tag the equipment and notify the Director of Grants, Treasurer and Superintendent when the fixed asset inventory is completed and updated. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel, Director of Technology Brandon Shafter, Director of Facilities Zac Moore, Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.
Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to...
Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to track the ESF activity for each year. The Treasurer will use the underlying funds ledgers to then determine the amount of ESF draws to request in each respective period. This will ensure that funds are not drawn in advance of expenditures taking place. Employee contracts will be maintained on file and when applicable, timecards will be completed and reviewed timely to ensure the time recorded to the ESF grant is accurate. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel and Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.
View Audit 299547 Questioned Costs: $1
Contact Person: Carla Maria Ratico, Registrar Corrective Action: With regards to Error #2023-007, some of the findings were related to incorrect reporting of graduation status, graduation date, and program begin date. We identified that some dates had not been correctly entered. We are working with ...
Contact Person: Carla Maria Ratico, Registrar Corrective Action: With regards to Error #2023-007, some of the findings were related to incorrect reporting of graduation status, graduation date, and program begin date. We identified that some dates had not been correctly entered. We are working with our student information system software consultants and National Student Clearinghouse personnel to ensure that all staff understand reporting requirements, and we have taken steps to correct errors before we submit reports. Another finding was that error records were not corrected within the required timeframe. There has been a change in staffing in the office since the time periods of the audit findings, so a different person is now correcting error records. That individual has been made aware of the audit findings and has committed to work with office personnel and National Student Clearinghouse on correcting reported errors promptly. Anticipated Completion Date: October 1, 2024
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: The issue has been addressed and reviewed. Going forward the Director of Financial Aid will set up and review all periods of enrollment and dates in the return of funds calculation on COD prior to the start of the academi...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: The issue has been addressed and reviewed. Going forward the Director of Financial Aid will set up and review all periods of enrollment and dates in the return of funds calculation on COD prior to the start of the academic year. Anticipated Completion Date: January 3, 2024
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