Corrective Action Plans

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Finding 369499 (2023-001)
Significant Deficiency 2023
Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The fin...
Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT Finding 2023-001 - Student Financial Assistance Cluster Compliance Requirement N. Gramm-Leach-Bliley Act-Student Information Security Recommendation: Our auditors recommend that we conduct a formal risk assessment and update our written information security program (WISP) to ensure the seven required elements are addressed. As part of this process, Information Technology (IT) policies should be updated to align with our current IT environment and be formally approved and implemented throughout the College. Action Taken: Wells College is partnering with Grey Castle Security to do a Risk Assessment and Penetration test. This will be completed in February. Additionally, Grey Castle has helped to redraft our Incident Response Plan. This has been completed, and training on this plan is scheduled for later in January, with Tabletop simulations occurring with the Wells College Emergency Planning Team and IT in February. Over the next couple of months, IT will be refreshing its policies in collaboration with the Wells College Technology Advisory Group (TAG), a committee representing all areas of the college. Once TAG has approved policies, they will go to the Cabinet for approval. Multiple policies will be merged to create the WISP as a self-contained document, rather than the multiple policies in place. The Chief Financial Officer, Robert Cree, is responsible for implementing this plan by June 30, 2024, and can be reached at (315) 364-3408 or rcree@wells.edu .
Finding 369498 (2023-002)
Significant Deficiency 2023
Identifying number: 2023-002 Significant Deficiency Federal Emergency Management Finding: Procedures were in place to identify and report eligible employee costs but not appropriately followed or reviewed which resulted in certain questioned costs. Action taken or planned: In fiscal year 23-24 the...
Identifying number: 2023-002 Significant Deficiency Federal Emergency Management Finding: Procedures were in place to identify and report eligible employee costs but not appropriately followed or reviewed which resulted in certain questioned costs. Action taken or planned: In fiscal year 23-24 the City moved all grant administration to a designated grant department. The duties of the grant administration department are to track, vet and confirm compliance with applicable guidelines on the grants the City applies for. Additionally, the grant administration department will actively assist with submission and seek new grant opportunities and will be available to train City employees on proper grant documentation and substantiation. The City engages outside consultants to review grant submission and the City is engaging this outside consultant to review the grant submissions more often throughout the year than previously engaged to allow more time to adequately review and obtain all necessary information for grant compliance. Any questions regarding this plan should be directed to Kathy Panas, Finance Director at 405.359.4521.
View Audit 290770 Questioned Costs: $1
Finding 369497 (2023-003)
Significant Deficiency 2023
Identifying number: 2023-003 Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds Finding: Procedures had not been fully established to ensure accurate quarterly reporting of costs and obligations incurred. Action taken or planned: Reporting of the quarterly ARPA submissions is ...
Identifying number: 2023-003 Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds Finding: Procedures had not been fully established to ensure accurate quarterly reporting of costs and obligations incurred. Action taken or planned: Reporting of the quarterly ARPA submissions is based on recorded transactions as of the due date of the quarterly report. The finance software posts invoices based on the invoice date rather than posting when the invoice is paid. Upon reconciliation of the difference noted above, it was discovered that invoices that were dated as of a particular quarter were paid and recorded well after the due date of the quarterly ARPA submission so could not be included in the quarterly report. Moving forward, we will reconcile to reflect only what is actually paid in time to be included in the ARPA submission so our internal records agree to the submission. We will not report to ARPA any funds that have not been expended because circumstances such as pricing, abandonment of a project, etc. can change before payment and if these items are reported before paid, it would cause erroneous reporting of ARPA funds. Any questions regarding this plan should be directed to Kathy Panas, Finance Director at 405.359.4521.
Finding 2023-002 Waiting List for Public Housing: Corrective Action Plan: Beginning February 2024, the waiting list will be printed monthly by staff and retained for a two year period.
Finding 2023-002 Waiting List for Public Housing: Corrective Action Plan: Beginning February 2024, the waiting list will be printed monthly by staff and retained for a two year period.
Finding #2023-001 - Limited Segregation of Duties (Prior Year Finding #2022-001) Condition:The available office staff precludes a proper segregation of duties in the following control areas: payroll, cash receipts, and cash disbursements. Effect:Because of the lack of segregation of duties, errors o...
Finding #2023-001 - Limited Segregation of Duties (Prior Year Finding #2022-001) Condition:The available office staff precludes a proper segregation of duties in the following control areas: payroll, cash receipts, and cash disbursements. Effect:Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: Due to the small size of the District there is only one person in the bookkeeping department, who records all transactions and performs reconciliations. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstatements on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the District's operations. Response:We agree with this finding but due to the size of our District and financial constraints do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Board of Education and Administration personnel review monthly treasurer reports, and approve disbursements monthly. Any concerns or questions are addressed throughout the year. Management will review various accounting functions periodically.
Planned Corrective Action - The BCSD will require the Davis-Bacon Act provision clause in future contracts for federally funded contracted services. The wage rate clause will be required along with requiring weekly payrolls to be submitted to the district finance office to ensure the federal wage r...
Planned Corrective Action - The BCSD will require the Davis-Bacon Act provision clause in future contracts for federally funded contracted services. The wage rate clause will be required along with requiring weekly payrolls to be submitted to the district finance office to ensure the federal wage rates established by the United States Department of Labor are followed. The BCSD will report questioned costs or corrective action needed to the FDOE. Anticipated Completion Date - 1/31/2024 Responsible Contact Person - Shannon Rodriguez, Director of Finance
View Audit 290732 Questioned Costs: $1
Identifying Number: 2023-001 Finding: The provisions of 36 CFR Section 686.31(e) were not followed. Notifications were not sent to TEACH Grant recipients to inform the student of their right to cancel their TEACH Grant and to inform the student of the procedure and time by which the student must not...
Identifying Number: 2023-001 Finding: The provisions of 36 CFR Section 686.31(e) were not followed. Notifications were not sent to TEACH Grant recipients to inform the student of their right to cancel their TEACH Grant and to inform the student of the procedure and time by which the student must notify the institution that he or she wishes to cancel their TEACH Grant or TEACH Grant disbursement. Corrective Actions Taken: We agree with this finding. University staff worked with the University's Enterprise System consultants, Ellucian, to develop a procedure to ensure notifications required by 36 CFR Section 686.31(e) are sent to students who receive TEACH Grant funds, Notifications were updated to include language about the right to cancel TEACH Grants, the procedures and time by which the student must notify the institution that he or she wishes to cancel the TEACH Grant or TEACH Grant disbursement. This procedure was implemented to fully comply with 36 CFR Section 686.31(e) on January 30, 2024. Name of Responsible Person: Dr. Heidi Neal, Assistant Vice President of Enrollment Management Completion Date: January 30, 2024
Pivot, Inc. (“Pivot” or “Organization”), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. Audit period: As of and for the...
Pivot, Inc. (“Pivot” or “Organization”), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. Audit period: As of and for the year ended June 30, 2023. The findings from the June 30, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS – INTERNAL CONTROL Identifying Number: 2023-001; Recognition of Revenue Recommendation: We recommend that the Organization continue to evaluate its procedures to ensure proper revenue recognition performed as part of its monthly and year-end closing processes. Action Taken: At this time we have put into new procedures to review and post all outstanding revenue during our monthly close process in order to ensure proper revenue recognition. Monthly reimbursements are checked off as invoiced in order to be sure that all are completed and posted in the correct month. Anticipated completion date: January 18, 2024 Name of contact person and title: Carolyn Gonzalez, Director of Finance & Accounting FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS – COMPLIANCE FINDINGS Recommendation: We recommend management continue to perform written income certifications for all future participants. Further, we suggest that the certifications include signatures of the staff completing the reviews. Action Taken: We agree with the above finding and plan to continue to require income certification reviews. Anticipated completion date: January 18, 2024 Name of contact person and title: Carolyn Gonzalez, Director of Finance & Accounting
Finding 369473 (2023-003)
Significant Deficiency 2023
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhan...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhancing the documentation and reporting of our internal security audits. Person Responsible for Corrective Action Plan: Sean Gordon, Director of Information Technology Operations and Software Development Anticipated Date of Completion: June 30, 2024
Finding 369472 (2023-002)
Significant Deficiency 2023
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to trac...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024
View Audit 290692 Questioned Costs: $1
Department of Justice 2023-001 Crime Victim Assistance Program Auditor's Recommendation: We recommend Community Crisis Center, Inc. review its files to ensure that all client files contain the required confidentiality and intake forms. We also recommend Community Crisis Center, Inc. implement a new...
Department of Justice 2023-001 Crime Victim Assistance Program Auditor's Recommendation: We recommend Community Crisis Center, Inc. review its files to ensure that all client files contain the required confidentiality and intake forms. We also recommend Community Crisis Center, Inc. implement a new policy to perform an annual internal audit of the client files for completeness. Action Taken: The Center's midnight Case Manager staff will continue to work through all the intake paperwork for the day to ensure all forms are present, including the confidentiality form for clients. In addition, a monthly audit of client files will be performed by the Compliance Manager and Program Coordinators to review and ensure client files have all necessary completed paperwork. If the funding agency has questions regarding this plan, please call me at 847-742-4088.
Names of Contact Persons: Kimberly Justus, Executive Director, Julie Brown, Fiscal and HR Manager Corrective Action Plan: We are in agreement with the finding and will ensure future submissions are completed timely. We completed the submission as soon as the requisite information was available in J...
Names of Contact Persons: Kimberly Justus, Executive Director, Julie Brown, Fiscal and HR Manager Corrective Action Plan: We are in agreement with the finding and will ensure future submissions are completed timely. We completed the submission as soon as the requisite information was available in July 2023. Expected Completion Date: See corrective action plan, all findings have been resolved.
THE DISTRICT DOES NOT HAVE DOCUMENTED PROCUREMENT PROCEDURES IN ACCORDANCE WITH THE PROCURMENT STANDARDS SET OUT AT 2 CFR SECTION 200.318 THROUGH 200.326. STATEMENT OF OCCURRENCE: MANAGEMENT AGREES WITH THE AUDIT FINDING CORRECTIVE ACTION: THE INTERIM EXECUTIVE DIRECTOR WILL DEVELOP A PROCURMENT PO...
THE DISTRICT DOES NOT HAVE DOCUMENTED PROCUREMENT PROCEDURES IN ACCORDANCE WITH THE PROCURMENT STANDARDS SET OUT AT 2 CFR SECTION 200.318 THROUGH 200.326. STATEMENT OF OCCURRENCE: MANAGEMENT AGREES WITH THE AUDIT FINDING CORRECTIVE ACTION: THE INTERIM EXECUTIVE DIRECTOR WILL DEVELOP A PROCURMENT POLICY IN ACCORDANCE WITH FEDERAL STANDARDS TO INCLUDE ALL GENERAL REQUIREMENTS SUCH AS OVERSIGHT OF CONTRACTORS' PERFORMANCE, MAINTAINING WRITTEN STANDARDS OF CONDUCT FOR EMPLOYEES INVOLVED IN CONTRACTING, AWARDING CONTRACTS ONLY TO RESPONSIBLE CONTRACTORS, MAINTAINING RECORDS TO DOCUMENT HISTORY OF PROCUREMENTS AND CONDUCTING PROCUREMENT TRANSACTIONS IN A MANNER PROVIDING FULL AND OPEN COMPETITION. PROJECTED COMPLETION DATE OF FINDING: FULL IMPLEMENTATION OF CORRECTIVE ACTION IS EXPECTED IN CALENDAR YEAR 2024. NAME OF CONTACT PERSON REGARDING FINDINGS: BRIAN KALOSKY, INTERIM EXECUTIVE DIRECTOR (860) 489-2535 BJKALOSKY@CT-TRANSWB.COM
Management has provided standard packets for initial, annual and interim packets including coversheets and checklist to assist in minimizing missing documentation in compliance with HUD regulations and CTHC policies. CTHC will also have files randomly audited by Executive Director and a 3rd party qu...
Management has provided standard packets for initial, annual and interim packets including coversheets and checklist to assist in minimizing missing documentation in compliance with HUD regulations and CTHC policies. CTHC will also have files randomly audited by Executive Director and a 3rd party quality control contractor who will review LIPH files for for errors. All staff will complete and pass rent calculation training every three (3) years. All utility allowances have been updated.
The Clinton Township Housing Commission Board has been reeducated, by our Fee accountant about the proper use of HUD Funding. The CTHC board understands that HUD funds CANNOT be used in to provide any type of Bonuses to staff and or any of its affiliates. All Commissioners will attend Commissioner’s...
The Clinton Township Housing Commission Board has been reeducated, by our Fee accountant about the proper use of HUD Funding. The CTHC board understands that HUD funds CANNOT be used in to provide any type of Bonuses to staff and or any of its affiliates. All Commissioners will attend Commissioner’s training to insure proper education on their roles and expectations.
View Audit 290651 Questioned Costs: $1
Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Fi...
Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Final Expenditure Reports were reopened and completed on September 11, 2023. Further, the District acknowledges the lack of timeliness of submitting the Final Expenditure Reports, and has implemented procedures to ensure all reporting surrounding final expenditures is completed and submitted to granting authority in accordance with terms of the agreement going forward. Contact person responsible for corrective action: Erica Ingles, Finance Director and Jennifer Mudge, Supervisor of School Improvement and Grant Programs Anticipated Completion Date: 9/11/2023
Comments on Finding and Recommendation: The Corporation acknowledges that the deposits were not made and agrees with the recommendation. The reason there were no additional deposits, other than the $1,000 in July 2022, was because the subsidy funds were not received starting October 2022. Actions Ta...
Comments on Finding and Recommendation: The Corporation acknowledges that the deposits were not made and agrees with the recommendation. The reason there were no additional deposits, other than the $1,000 in July 2022, was because the subsidy funds were not received starting October 2022. Actions Taken or Planned: The Corporation plans to make the required reserve deposits for the year ended June 30, 2024.
The Organization underwent a single audit as required by Uniform Guidance for the year that ended June 30, 2023. There were errors detected in payroll amounts which were charged to the grant. The Organization understands the importance of having strong controls over the payroll costs that get char...
The Organization underwent a single audit as required by Uniform Guidance for the year that ended June 30, 2023. There were errors detected in payroll amounts which were charged to the grant. The Organization understands the importance of having strong controls over the payroll costs that get charged to each grant and are very familiar with the requirements of the respective grant agreements. During the process of reviewing payroll, payroll entries other than regular pay will be noted. If said variances from regular pay require being allocated to a different program, the Payroll Allocation worksheet will be immediately updated to reflect the proper allocation. Additionally, the Organization will be especially diligent in checking the monthly payroll allocations to each grant to ensure their accuracy.
2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation th...
2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation that they are properly authorized. All employees should have timesheets to support the hours worked and charged to the grant. These timesheets should be formally approved by a supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women of Nations has updated its payroll policies and procedures to ensure that time and effort certifications are completed correctly and approved in a timely manner by supervisors. Name(s) of the contact person(s) responsible for corrective action: Charles Nelson Planned completion date for corrective action plan: June 1, 2023
View Audit 290620 Questioned Costs: $1
The District will review the expenditure reports and compare to the general ledger to ensure agreement before the reports are submitted.
The District will review the expenditure reports and compare to the general ledger to ensure agreement before the reports are submitted.
View Audit 290609 Questioned Costs: $1
Lack of Documentation of Exit Counseling Planned Corrective Action: Exit counseling letters have been emailed within 30 days of a student’s separation from Newberry College. A record of this notification is maintained in the financial aid software system for audit purposes. The senior associate...
Lack of Documentation of Exit Counseling Planned Corrective Action: Exit counseling letters have been emailed within 30 days of a student’s separation from Newberry College. A record of this notification is maintained in the financial aid software system for audit purposes. The senior associate director will be responsible for completing this process and the director will assist or complete, if necessary. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated...
Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated an individual to pull a statistical report from NSLDS to verify the reporting is updated for each period of enrollment. Person Responsible for Corrective Action Plan: Marilyn Eason, Registrar Anticipated Date of Completion: This problem should be resolved when Newberry moves to the J1 platform this spring. It is expected enrollment reporting will be automated by the summer of 2024.
Monthly Reconciliations of Pell Grant and Federal Direct Loans Planned Corrective Action: Monthly reconciliations for the Pell Grant and Federal Direct Loan Programs have been completed to date for the 23-24 academic year. The senior associate director is responsible for completing monthly reconc...
Monthly Reconciliations of Pell Grant and Federal Direct Loans Planned Corrective Action: Monthly reconciliations for the Pell Grant and Federal Direct Loan Programs have been completed to date for the 23-24 academic year. The senior associate director is responsible for completing monthly reconciliations and the director will perform if necessary. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Incorrect Pell Calculations Planned Corrective Action: The process for awarding and disbursing summer Pell Grants is being discussed. The new process will involve a thorough review of summer enrollment. Aid will disburse for session 1 and session 2 after the last day to add or drop a course. The ...
Incorrect Pell Calculations Planned Corrective Action: The process for awarding and disbursing summer Pell Grants is being discussed. The new process will involve a thorough review of summer enrollment. Aid will disburse for session 1 and session 2 after the last day to add or drop a course. The director will oversee summer awarding and the senior associate director will assist by providing necessary reports. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process will be finalized by June 2024.
View Audit 290607 Questioned Costs: $1
Finding 369428 (2023-004)
Significant Deficiency 2023
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
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