Corrective Action Plans

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Pell Awards Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of verifying students’ enrollment status. Person Responsible for Corrective Action Plan: Cathy Morgan Anticipated Date of Compl...
Pell Awards Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of verifying students’ enrollment status. Person Responsible for Corrective Action Plan: Cathy Morgan Anticipated Date of Completion: March 1, 2024
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: For the vendor that does not have multi factor authentication (National Clearinghouse), we are implementing their new platform, Myhub, to ensure compliance. We anticipate completion by 3/1/24. Additionally, we engaged a firm tha...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: For the vendor that does not have multi factor authentication (National Clearinghouse), we are implementing their new platform, Myhub, to ensure compliance. We anticipate completion by 3/1/24. Additionally, we engaged a firm that will serve as a virtual Chief Information Security Officer to manage the continuing GLBA updates for regulatory compliance. Person Responsible for Corrective Action Plan: Judy Rentz, V.P of Operations/Chief Operating Officer Anticipated Date of Completion: March 1, 2024
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete R2T4s. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not real...
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
Item 2023-002 - Special Tests Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. To train all staff involved with the calculation of sliding f...
Item 2023-002 - Special Tests Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. To train all staff involved with the calculation of sliding fees on the policies and procedures to ensure: ► The sliding fee guidelines document is known. ► Understanding of the methodology for calculating fees, including how family size and income are considered. ► Documentation required to support income and family size information provided by clients. This may include tax returns, pay stubs, or other relevant documents. ► To use the standardized form (checklist) to ensure all necessary information is collected and verified. 2. To perform a monthly audit review, utilizing a selected sample to identify any discrepancies and make necessary corrections in a timely manner. 3. To ensure the sliding fee scale is clearly communicated to clients. Responsible Party: Director of Patient Services/RCM Director Target Completion Date: 04/30/2024 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Hewart Tillett, CFO at 1-314-882-1463, or email at htillett@phcenters.com.
Finding 371022 (2023-004)
Significant Deficiency 2023
2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period com...
2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 35 students that received all failing grades in a term, we tested five students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: The Provost’s Office has drafted a memo to faculty explaining the requirement to enter the last day attended for any student receiving a failing grade.  The Registrar’s Office has added this requirement to their routine reminders to faculty about entering grades.  The Clerk of the Faculty has agreed to bring this change in policy to the faculty to add to the Faculty Handbook in section 3.1.10 Reading Day, Final Examinations, and Course Grades.  Plan for auditing effectiveness of corrective action: The Register’s Office is turning on the requirement in Bannerweb (student system) that any F or NC grade cannot be entered in the system without a last date of attendance. An audit report will be able to be generated on this data. Responsible Party: Provost, Registrar, and Faculty, under the supervision of the Provost is responsible for implementing this corrective action plan and ensuring compliance. Point of Contact: Maria Rosales, Provost, mrosales@guilford.edu, 336-316-2205 Expected date of correction: April 2024
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. ...
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward.
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. ...
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, the University has reviewed all procedures for identifying official and unofficial withdrawals, adding a new requirement for all faculty members to include a last date of attendance for all unsatisfactory grades input into our student information system. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done on a timely basis going forward.
Finding Number: 2023-002 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Contact Person: Norine Bowers, Federal Programs Director and Jennifer Bosch, Finance Director Anticipated Completion Date: December 31, 2024 Planned Corre...
Finding Number: 2023-002 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Contact Person: Norine Bowers, Federal Programs Director and Jennifer Bosch, Finance Director Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District does not believe that an internal control issue exists but does acknowledge that procedures will be implemented in order to maintain adequate backup supporting documentation for grant programs in the future.
Finding Number: 2023-001 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Mercedes Villafana, Procurement Director and Kim Polyhronakis, Purchasing & Warehouse Coordinator Anticipated Completion Date: December 31, 2024 Pl...
Finding Number: 2023-001 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Mercedes Villafana, Procurement Director and Kim Polyhronakis, Purchasing & Warehouse Coordinator Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District does not believe that an internal control issue exists but does acknowledge that an error occurred while reviewing the capital project documentation. The purchasing and accounts payable departments will collaborate and review all of the capital expenditures to ensure that documentation is included in the review of the applicable capital asset reporting totals.
There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS...
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to...
There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
We agree with the finding. We have previously established procedures that will be reinforced with our management and compliance personnel to ensure proper use of the EIV system. Training for all staff has occurred, and a HUD checklist has been implemented into our operations. The Executive Director ...
We agree with the finding. We have previously established procedures that will be reinforced with our management and compliance personnel to ensure proper use of the EIV system. Training for all staff has occurred, and a HUD checklist has been implemented into our operations. The Executive Director will perform a 100% quality control review of the EIV reports until further notice.
The district will ensure to have all Title I fully funded personnel fill out a Bi-Annual Certification going forward
The district will ensure to have all Title I fully funded personnel fill out a Bi-Annual Certification going forward
The district has already correcting this finding in the 23-24 school year. All Title I Funded personnel are included on a board resolution
The district has already correcting this finding in the 23-24 school year. All Title I Funded personnel are included on a board resolution
Eligibility: The Authority is full staff and moving forward there will be documentation to show that files are being reviewed to stay in compliance with program eligibility.
Eligibility: The Authority is full staff and moving forward there will be documentation to show that files are being reviewed to stay in compliance with program eligibility.
HQS Quality Control: The Authority now has a new ED and has put in place quality control/re-inspect procedures with the new Section 8 Coordinator.
HQS Quality Control: The Authority now has a new ED and has put in place quality control/re-inspect procedures with the new Section 8 Coordinator.
VMS System: Going forward all VMS monthly reports on the 1st and any payments there after will be reviewed by the ED and submitted to the financial agency who works for the Authority and keeps the financial records.
VMS System: Going forward all VMS monthly reports on the 1st and any payments there after will be reviewed by the ED and submitted to the financial agency who works for the Authority and keeps the financial records.
Depository Agreements: The Authority is in the process of updating the depository agreements with our financial institutions with the HUD required form. Once completed will be kept on file.
Depository Agreements: The Authority is in the process of updating the depository agreements with our financial institutions with the HUD required form. Once completed will be kept on file.
Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all ...
Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all R2T4 calculations. We have developed additional procedures to ensure institutionally scheduled breaks are being considered in determining a student's percentage of Title IV aid earned. The procedures include participation in training webinars and updates to the policies and procedures manual with detailed instructions on how to calculate the number of days in the semester and formal review and approval of all R2T4 calculations. The procedures also include secondary check by the Director or designate, of entered dates in the calculation set up. The training and updated policies and procedures were completed on September 14, 2023, effective with the Fall 2023 term and forward.
Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications...
Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications being sent prior to the disbursements being processed to ensure all requirements for this program are met. Timeline for Implementation of Corrective Action Plan: These process and system updates will be implemented before the end of fiscal year 2024.
Finding 370986 (2023-001)
Significant Deficiency 2023
Action taken in response to finding: The Organization will continue to monitor its systems and personnel records to ensure that payroll and fringe benefits fully comply with federal cost principles. The Organization has approximately 312 employees and approximately 20 different grants that require a...
Action taken in response to finding: The Organization will continue to monitor its systems and personnel records to ensure that payroll and fringe benefits fully comply with federal cost principles. The Organization has approximately 312 employees and approximately 20 different grants that require allocation updates any time there is a change on a PAN form. There are procedures in place for monitoring that the information in the PAN forms and vouchering system agree. Due to the volume of payroll related transactions, management will increase the number of payroll items that are tested on a quarterly basis. Name of the contact person responsible for corrective action: Carmen Ziegler, CFO Planned completion date for corrective action plan: March 31, 2024
FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing...
FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. 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 the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024
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