Corrective Action Plans

Finding 10374 (2023-003)

Significant Deficiency 2023

NH

Condition: Vacancies and invoice processing experienced delays during the year. Plan: Management will design and follow policy to ensure timely completion of agent tasks even if understaffed. Anticipated Completion Date: Dec 31, 2023 ...

Condition: Vacancies and invoice processing experienced delays during the year. Plan: Management will design and follow policy to ensure timely completion of agent tasks even if understaffed. Anticipated Completion Date: Dec 31, 2023 Contact: Duska Noel, Director of Housing Michael Tabory, Chief Operating Officer

View Audit 14019

Finding 10371 (2023-002)

Significant Deficiency 2023

Kearsarge Elderly Housing, Inc.

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Reporting

Condition: Additional detail, documentation and approval/oversight is needed on some of time sheets for allocation to projects. Plan: To ensure proper allocations to projects, job duties will be documented for each position and sufficient detail will be provided on timesheets to reflect duties pe...

Condition: Additional detail, documentation and approval/oversight is needed on some of time sheets for allocation to projects. Plan: To ensure proper allocations to projects, job duties will be documented for each position and sufficient detail will be provided on timesheets to reflect duties performed. Anticipated Completion Date: Dec 31, 2023 Contact: Duska Noel, Director of Housing Michael Tabory, Chief Operating Officer

View Audit 14019

Finding 10370 (2023-001)

Significant Deficiency 2023

Kearsarge Elderly Housing, Inc.

NH

HUD Housing Programs Internal Control / Segregation of Duties

Condition: The certifier for HUD forms should be a current employee with oversight in the area the form pertains to. HUD forms must be certified by an authorized user. Plan: A procedure will be implemented to ensure that changes in certifiers on forms at Projects are made in a timely fashion. Ant...

Condition: The certifier for HUD forms should be a current employee with oversight in the area the form pertains to. HUD forms must be certified by an authorized user. Plan: A procedure will be implemented to ensure that changes in certifiers on forms at Projects are made in a timely fashion. Anticipated Completion Date: Completed June 30, 2023 Contact: Duska Noel, Director of Housing Michael Tabory, Chief Operating Officer

View Audit 14019

Finding 10356 (2023-007)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is aware of the requirement to perform direct loan reconciliation. We are now appropriately staffed with monthly reconciliation being performed by the Assistant Director and being sent to the Director of Accounting for review. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10352 (2023-006)

Significant Deficiency 2023

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10348 (2023-005)

Material Weakness 2023

Clatsop Community College

OR

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

View Audit 14009

Finding 10344 (2023-004)

Material Weakness 2023

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There i...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25

View Audit 14009

Finding 10343 (2023-003)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Eligibility § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disag...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is now appropriately staffed and extra time will be taken to ensure NSLDS is being reviewed prior to loan origination. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleysne & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10342 (2023-002)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: The...

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office and student accounts office will work together to clearly communicate the timing of aid being applied to student accounts and being reported to COD to ensure both actions are happening on the same day. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10340 (2023-001)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement wi...

Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All ESF funds were expended as of June 30, 2023, so there is no continuing reporting requirement. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10328 (2023-001)

Material Weakness 2023

Southwest R-V School District

MO

Internal Control / Segregation of Duties HUD Housing Programs

CORRECTIVE ACTION PLAN September 14, 2023 UNITED STATES DEPARTMENT OF EDUCATION UNITED STATES DEPARTMENT OF AGRICULTURE Southwest R-V School District respectfully submits the following corrective action plan for the year ended June 30, 2023. Contact information for the individual responsible fo...

CORRECTIVE ACTION PLAN September 14, 2023 UNITED STATES DEPARTMENT OF EDUCATION UNITED STATES DEPARTMENT OF AGRICULTURE Southwest R-V School District respectfully submits the following corrective action plan for the year ended June 30, 2023. Contact information for the individual responsible for the corrective action: Tosha Tilford, Superintendent Southwest R-V School District 300 N Myrtle Street Washburn, MO 65772 (417) 826-5410 Independent Public Accounting Firm: The CPA Group, PC, 217 4th Street, Monett, MO 65708 Audit Period: 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. FINDINGS – FINANCIAL STATEMENT AUDIT Material Weakness – Internal Control over Financial Reporting - Segregation of duties Finding 2023-001 Recommendation: We realize Because of limited resources and personnel, management may not be able to achieve a proper segregation of duties; however, our professional standards require that we bring this lack of segregation of duties to your attention in this report. Action Taken: The limited number of available personnel prohibits segregation of incompatible duties and the District does not have the resources to hire additional accounting personnel. Completion Date: Not applicable Sincerely, Tosha Tilford, Superintendent Southwest R-V School District

View Audit 14007

Finding 10327 (2023-001)

None 2023

Judson Independent School District

TX

Equipment & Real Property Management Procurement, Suspension & Debarment

Recommendation: The District should adhere to District policies and procedures to properly tag federally purchased assets to track them as federal and comply with the grant requirements. District’s Response: The District will tag all federally purchased assets and indicate the federal funds used to ...

Recommendation: The District should adhere to District policies and procedures to properly tag federally purchased assets to track them as federal and comply with the grant requirements. District’s Response: The District will tag all federally purchased assets and indicate the federal funds used to purchase them on the physical assets going forward. Responsible Person(s): Cecilia Davis, Deputy Superintendent of Innovation, Business & Operations; Assistant Superintendent of Technology, Dr. Lacey Gosch; Jodi Burton, Director of Federal Compliance

View Audit 13988

Finding 10326 (2023-002)

Material Weakness 2023

Illinois Central College District 514

IL

Subrecipient Monitoring § 200.303

A procedure has been established and in place for future awards involving sub-recipients. The College closely monitors grant activity to ensure compliance with underlying grant provisions and notes that there is no financial exposure to the College or the granting agency.

View Audit 13983

Finding 10322 (2023-001)

Significant Deficiency 2023

Illinois Central College District 514

IL

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in pl...

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.

View Audit 13983

Finding 10320 (2023-002)

Significant Deficiency 2023

Chicano Federation of San Diego County, Inc.

CA

Reporting

The Fiscal Reports are prepared by the Senior Accounting Specialist. The Staff Accountant will prepare a reconciliation of the Fiscal Reports to the internal profit and loss statements. The Director of Accounting will review and approve the reconciliations of the Fiscal Reports to the internal profi...

The Fiscal Reports are prepared by the Senior Accounting Specialist. The Staff Accountant will prepare a reconciliation of the Fiscal Reports to the internal profit and loss statements. The Director of Accounting will review and approve the reconciliations of the Fiscal Reports to the internal profit and loss statements. The anticipated completion date is February 1, 2024

View Audit 13968

Finding 10311 (2023-003)

Significant Deficiency 2023

Chicano Federation of San Diego County, Inc.

CA

Reporting

During the proposal process, or subsequent to the award of funding from a new source, Federation Staff will obtain documentation from the funder of the source of the funds. The anticipated completion date is December 13, 2023

View Audit 13968

Finding 10305 (2023-001)

Significant Deficiency 2023

Chicano Federation of San Diego County, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles

The Federation has instituted a system of review for all allocations. The initial allocations are prepared by the Senior Accounting Specialist or the Staff Accountant. These allocations are also calculated independently by the Director of Accounting. Any differences are resolved to ensure that the p...

The Federation has instituted a system of review for all allocations. The initial allocations are prepared by the Senior Accounting Specialist or the Staff Accountant. These allocations are also calculated independently by the Director of Accounting. Any differences are resolved to ensure that the proper allocations method has been used. The anticipated completion date is July 1, 2023

View Audit 13968 Questioned Costs: $1

Finding 10297 (2023-002)

Significant Deficiency 2023

University of South Carolina

SC

Matching / Level of Effort / Earmarking Reporting Significant Deficiency

HEERF ANNUAL REPORTING Recommendation: We recommend that the University monitor the reporting requirements of all grants, to ensure they stay in compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The...

HEERF ANNUAL REPORTING Recommendation: We recommend that the University monitor the reporting requirements of all grants, to ensure they stay in compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will monitor reporting requirements for HEERF funds for its annual report and will amend the prior report as needed for compliance. Name(s) of the contact person(s) responsible for corrective action: Mandy Kibler, Associate Vice President and University Controller Planned completion date for corrective action plan: The University will submit the final HEERF Annual Report for CY2023 in spring 2024 and will amend the CY2022 in spring 2024 to ensure reporting requirements are met.

View Audit 13962

Finding 10295 (2023-001)

Significant Deficiency 2023

University of South Carolina

SC

Cash Management

HEERF CASH MANAGEMENT Recommendation: We recommend that the University continuously enhance its monitoring control over administration and disbursement of HEERF money, in order to ascertain complete and accurate compliance with cash management principles and requirements. We also recommend that the...

HEERF CASH MANAGEMENT Recommendation: We recommend that the University continuously enhance its monitoring control over administration and disbursement of HEERF money, in order to ascertain complete and accurate compliance with cash management principles and requirements. We also recommend that the University determines if any interest earned on these funds before expenditure should be returned to ED. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University worked with the Aiken and Salkehatchie campuses to ensure all expenditures and lost revenue were documented for the HEERF funds that were drawn in accordance with cash management principles and requirements. In addition, the University will review its cash management policies with regard to federal funds to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Mandy Kibler, Associate Vice President and University Controller Planned completion date for corrective action plan: The University has documented all expenditures and lost revenue for the HEERF funds that were drawn in accordance with cash management principles and requirements and will determine if any interest should be returned to ED before December 31, 2023.

View Audit 13962

Finding 10292 (2023-001)

Significant Deficiency 2023

St. Matthew Manor - West, Inc.

TN

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of condition 2023-001: During the year ended September 30, 2023, the Project paid expenses totaling $695 on behalf of an entity under common management without HUD approval. Recommendation: Management should have the other project reimburse $695. Action(s) taken or planned on the findi...

Statement of condition 2023-001: During the year ended September 30, 2023, the Project paid expenses totaling $695 on behalf of an entity under common management without HUD approval. Recommendation: Management should have the other project reimburse $695. Action(s) taken or planned on the finding: On December 18, 2023, the finding was cleared as $695 was repaid to the Project. Completion date: December 18, 2023

View Audit 13940 Questioned Costs: $1

Finding 10288 (2023-003)

Significant Deficiency 2023

Laramie County Community College

WY

Corrective Action: The College was aware of the new required elements for our comprehensive information security program procedure but missed the June 9 deadline to finalize the procedure changes. The required Gramm-Leach-Bliley Act procedures were in draft form at the time of the audit review. The ...

Corrective Action: The College was aware of the new required elements for our comprehensive information security program procedure but missed the June 9 deadline to finalize the procedure changes. The required Gramm-Leach-Bliley Act procedures were in draft form at the time of the audit review. The required procedures were finalized in July and approved by the President’s Cabinet on August 1, 2023, and were effective on that same date. The approved procedures address all elements as required by 16 CFR 314.4, and the College is now in full compliance with the Gramm-Leach-Bliley Act. Anticipated Completion Date: August 1, 2023 Contact Person: Chad Marley

View Audit 13927

Finding 10287 (2023-002)

Significant Deficiency 2023

Laramie County Community College

WY

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will...

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will be sent to a student (or parent) that is eligible for a PWD of Federal Direct Loan within 30 days of the date of determination. The type and amount of Title IV loan funds that will be credited to the student’s charges and the amount that will directly disburse will be offered to the student, or the parent in the case of a PLUS Loan. The notification will explain that the student or parent can accept all or part of the loan disbursement and will advise the student or parent that no post-withdrawal disbursement of Title IV loan funds will be made unless the school receives a confirmation response within the established timeframe of 14 days. Please note that loan PWDs are very rare at the College because the vast majority of our students that wish to borrow complete their loan requirements and receive their loan disbursement prior to their withdrawal date. In the case of the student noted in the finding, the student completed his loan requirements (i.e., master promissory note and loan entrance counseling) only a couple of days before the date he became ineligible. We acknowledge an advanced written notice was not sent, but please note that a written notification was sent to the student immediately following the loan disbursement informing the student about his right to cancel all or part of the loan and the procedures and timeframe in which to do so. Anticipated Completion Date: July 1, 2023 Contact Person: Brandi Payne Cervera

View Audit 13927

Finding 10286 (2023-004)

Material Weakness 2023

Clearfield County Career and Technology Center

PA

Reporting

Management agrees with the finding. While the Center did not provide the public with accurate data, the Center believed it had filed the reports correctly at the time. Since the finding was identified during the audit, the Center plans to submit the revised reports stated above.

View Audit 13921

Finding 10285 (2023-003)

Material Weakness 2023

Clearfield County Career and Technology Center

PA

Questioned Costs Reporting Cash Management

Management agrees, and is working to realign the grant process from formalizing the administration and determining the involvement of staff members. A timeline will be initiated between all involved staff to oversee, track, report and manage all of the Center's grant awards. Timeline will ensure tha...

Management agrees, and is working to realign the grant process from formalizing the administration and determining the involvement of staff members. A timeline will be initiated between all involved staff to oversee, track, report and manage all of the Center's grant awards. Timeline will ensure that budgets, reporting requirements and purchases are handled in a timely manner. Management is also revising the quarter ending September 30, 2022 report and the 2022 annual report and working with the U.S. Department of Education regarding the resolution of this matter.

View Audit 13921 Questioned Costs: $1

Finding 10272 (2023-004)

Significant Deficiency 2023

Western Wyoming Community College

WY

Student Financial Aid

WWCC cannot confirm that the Bank Mobile contract was provided to the Department of Education (ED) as required due to staff turnover. However, WWCC has ended the contract with Bank Mobile and beginning with the Spring 2024 semester, credit balance refunds will be issued by EFT using bank account inf...

WWCC cannot confirm that the Bank Mobile contract was provided to the Department of Education (ED) as required due to staff turnover. However, WWCC has ended the contract with Bank Mobile and beginning with the Spring 2024 semester, credit balance refunds will be issued by EFT using bank account information provided by the student or by check issued by WWCC if the student does not provide a bank account in TouchNet. TouchNet does not open any accounts or offer any debit cards to issue credit balance refunds to WWCC students. WWCC will ensure that all ED reporting requirements are met for the Touchnet contract. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management

View Audit 13919

Corrective Action Plans

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