Corrective Action Plans

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Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program (PELL) P063P202209, P063P212209, P063P222209 Finding 2023-003 – Eligibility – Material Weakness Finding Summary: Two instances identified in which the s...
Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program (PELL) P063P202209, P063P212209, P063P222209 Finding 2023-003 – Eligibility – Material Weakness Finding Summary: Two instances identified in which the student was eligible to receive Federal Pell assistance but was not awarded the assistance. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: Partake in additional training in the awarding of summer PELL. Update procedures on how information is communicated between the Registrar’s Office and Financial Aid to improve awareness of summer reporting and grade change updates. Recondition the reporting process to improve accuracy of delivered information. Anticipated Completion Date: January 1st, 2024
View Audit 6701 Questioned Costs: $1
Finding 2023-005 Federal Agency Name: U.S. Department of Education Passed through the Nevada Department of Education Program Name: Gaining Early Awareness and Readiness for Undergraduate Programs CFDA #84.334 Finding Summary: The U.S. Department of Education requires the Nevada Department of Educati...
Finding 2023-005 Federal Agency Name: U.S. Department of Education Passed through the Nevada Department of Education Program Name: Gaining Early Awareness and Readiness for Undergraduate Programs CFDA #84.334 Finding Summary: The U.S. Department of Education requires the Nevada Department of Education to collect and report student demographic and academic progress data; student/parent participation data; and student follow‐up data at participating schools under the program. Therefore, an Interim Performance Report is required to be submitted by the Nevada Department of Education. Participation totals were reported inaccurately to the Nevada Department of Education. The District did not have adequate internal controls to ensure the Interim Performance Reports were accurate. Responsible Individuals: Deb Hegna, Director III, Grants Development and Administration Corrective Action Plan: The following controls were developed to ensure Clark County School District Interim Performance Reports are accurate. Anticipated Completion Date: June 30, 2024
Finding 2023-004 Federal Agency Name: U.S. Department of the Treasury U.S. Department of Education Program Name: Passed through the Nevada Department of Agriculture COVID‐19: Education Stabilization Fund Passed through the Nevada Department of Education COVID‐19: Coronavirus State and Local Fiscal R...
Finding 2023-004 Federal Agency Name: U.S. Department of the Treasury U.S. Department of Education Program Name: Passed through the Nevada Department of Agriculture COVID‐19: Education Stabilization Fund Passed through the Nevada Department of Education COVID‐19: Coronavirus State and Local Fiscal Recovery Fund CFDA #21.027 #84.425 Finding Summary: Amounts were reported incorrectly on the SEFA. The District did not have adequate internal controls to ensure all federal expenditures were reported with the correct assistance listing number. Prior to correction, the total federal expenditures for the Education Stabalization Fund were overstated by $19,366,000 and the total federal expenditures for the Coronavirus State and Local Fiscal Recovery Fund were understated by $19,366,000. Responsible Individuals: Jason Goudie, Chief Financial Officer Corrective Action Plan: The following controls were developed to ensure that Clark County School District reports correct assistance listing numbers on the SEFA. Anticipated Completion Date: September 30, 2024
Finding 2023-001 Correc􀆟ve Ac􀆟on Plan This is a response to Finding 2023-001 listed in the Schedule of Findings and Ques􀆟oned Costs for Federal Awards. Unity Environmental University agrees with this finding and has taken the following correc􀆟ve ac􀆟ons to prevent recurrence of such findings. While t...
Finding 2023-001 Correc􀆟ve Ac􀆟on Plan This is a response to Finding 2023-001 listed in the Schedule of Findings and Ques􀆟oned Costs for Federal Awards. Unity Environmental University agrees with this finding and has taken the following correc􀆟ve ac􀆟ons to prevent recurrence of such findings. While tes􀆟ng the return of Title IV funds, a nonsta􀆟s􀆟cal sample of 25 students was tested for proper return calcula􀆟ons. During the tes􀆟ng, 1 of 25 calcula􀆟ons were incorrectly calculated. The error did not result in addi􀆟onal funds to be returned. The student in ques􀆟on had a􀆩ended one module of two in the graduate program payment period. When the recalcula􀆟on was performed, the full payment period was used. The student had earned 100% of aid due to comple􀆟ng 60% of the period. The error was not caught by the second reviewer. This occurred during a 􀆟me of low staffing in the financial aid office and a high volume of ac􀆟vity. The calcula􀆟on was corrected but no addi􀆟onal funds needed to be returned as the student s􀆟ll earned 100% of aid due to comple􀆟ng 60% of the module. In an abundance of cau􀆟on, the financial aid staff reviewed R2T4 calcula􀆟ons completed for all graduate students. No addi􀆟onal errors were found. The financial aid staff met to discuss the finding and management emphasized the impact to the student and ins􀆟tu􀆟on when these errors occur. We believe this was an isolated incident and the staff understands the importance of the second reviewer role to avoid such errors. Responsible Person: Sherry Watson Correction Date: 06/27/23
Management has reviewed the finding and is in agreement with the reported deficiency as a result of staffing levels. Corrective action will include evaluation of existing accounting staffing levels, review of current accounting policies related to separation of duties, and the addition of a requirem...
Management has reviewed the finding and is in agreement with the reported deficiency as a result of staffing levels. Corrective action will include evaluation of existing accounting staffing levels, review of current accounting policies related to separation of duties, and the addition of a requirement for secondary approval related to journal entries, SEFA preparation, and draw requests for/from federal grant programs. To be completed within fiscal year 2024.
Finding 4290 (2023-001)
Significant Deficiency 2023
Recommendation: We recommend the College evaluate and enhance the college’s financial aid awarding procedures to prevent future instances of over-awarding. We recommend the College establish a system for ongoing monitoring of financial aid awards to identify and address discrepancies in a timely man...
Recommendation: We recommend the College evaluate and enhance the college’s financial aid awarding procedures to prevent future instances of over-awarding. We recommend the College establish a system for ongoing monitoring of financial aid awards to identify and address discrepancies in a timely manner. Regularly review and update policies and procedures to adapt to changes in regulations and best policies. Corrective Action: The college financial aid office will review and update policies and procedures in the Clarendon College Financial Aid Handbook to establish system for ongoing monitoring of financial aid awards in order to identity and address discrepancies and potential over-awards in a timely manner. The system will include monitoring Cost Of Attendance, enrollment status, and unmet need. The policy/procedure will be reviewed and submitted for adoption by the CC Board of Regents for the Clarendon College Financial Aid Handbook by February 2024.
Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently i...
Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently in communication with HUD discussing options of a possible waiver for the required deposit or the possibility of making the deposit with promise of approval for immediate release
Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently i...
Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently in communication with HUD discussing options of a possible waiver for the required deposit or the possibility of making the deposit with promise of approval for immediate release
The Hingham Public Schools’ general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.
The Hingham Public Schools’ general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.
Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.
Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that ...
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.
View Audit 6595 Questioned Costs: $1
Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 stu...
Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 students where the Enrollment and Admissions Departments discovered submission of fraudulent documents to verify residency. City Colleges performed a thorough investigation of student enrollment and verified that no aid was disbursed for these identified fraudulent enrollments Cause City Colleges experienced turnover in the Admissions Department and was training a new employee. The new employee did not have enough training or experience to identify fraudulent documents when the students enrolled with the college and registered for classes. City Colleges was not aware that this issue was required to be reported to the Department of Education. Corrective Action Taken or Planned: The College will review and monitor the Department of Education regulations. The Student Financial Aid will continue to train employees on the regulations and will timely report issues to the Department of Education. Contact Person: Tiffany Morrison, Associate Vice Chancellor – Financial Aid & Scholarship Anticipated Completion Date: In progress
Finding 2023-007 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Annual Reporting Condition City Colleges did not accurately report certain information required in the calendar year 2022 annual report. The following instances of noncompliance were identified: • HEER...
Finding 2023-007 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Annual Reporting Condition City Colleges did not accurately report certain information required in the calendar year 2022 annual report. The following instances of noncompliance were identified: • HEERF Institutional Portion: City Colleges submitted the annual report for Olive Harvey for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $234,118 which was a result of a figure being double counted in the total. • HEERF Institutional Portion: City Colleges submitted the annual report for Malcolm X for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $5,580,216 which was a result of a figure being double counted in the total. Cause City Colleges did not have effective internal controls in place to ensure reports were submitted accurately. Corrective Action Taken or Planned Finance will validate and review the OH and MX 2023 annual report for HEERF prior to submission in 2024. Financial Aid will submit the required HEERF Annual Reporting Correction for OH and MX. In addition, will submit the final required 2023 HEERF annual report. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: December 31, 2023
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic i...
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of December 2023. Corrective Action Taken or Planned CCC will refresh the current data inventory and instate periodic inventory refresh procedures by December 31, 2023. Contact Person: Zarko Njakara, Interim CIO Anticipated Completion Date: December 31, 2023
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campus...
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that review controls were performed over the transfer, carryforward, carryback, and administrative cost calculations in the Fiscal Operations Report and Application to Participate (FISAP) for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. • Reporting: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that secondary review controls were performed over FISAP data for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. Cause City Colleges did not formally document the additional reviews and approvals over the department’s review of the FISAP. Corrective Action Taken or Planned Financial Aid will develop and document a review/approval process that will detail accurate reporting, secondary reviews, and review/approval of FISAP submissions and completions. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through Jan...
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Kennedy King College had excess cash for the Direct Loan Program ranging from $1,349 to $4,318 during the period of November 29, 2022 through December 13, 2022, from $1,508 to $3,948 during the period of January 6, 2023 through January 16, 2023 and from $3,207 to $5,137 during the period of June 15, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns, however, amounts were not returned within a seven-day period. • Truman College had excess cash for the Pell Grant Program ranging from $164,625 to $262,034 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Truman College had excess cash for the Direct Loan Program ranging from $2,731 to$8,669 during the period of January 20, 2023 through February 16, 2023 and from $752 to $10,028 during the period of April 28, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned within a seven-day period. Cause The College drew down funds available in the G5 system as opposed to drawing down expected student disbursement amounts. Corrective Action Taken or Planned District Office Financial Aid will develop and implement better controls and procedures for monitoring the timing of the draw downs and student disbursements as well as controls to monitor the return of excess cash, if any, within the 7-day period. During the middle of a semester, timely reconciliations will be prepared, reviewed and approved prior to the next draw down to ensure the acceptable amount is drawn down and disbursed timely to the students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
View Audit 6574 Questioned Costs: $1
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements we...
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements were reported one day late. Cause The financial aid office inadvertently miscalculated the reporting date. Corrective Action Taken or Planned Financial Aid will add additional monitoring controls of COD files to ensure timely reporting. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The...
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The financial aid office did not follow-up on the gainful employment of students. Corrective Action Taken or Planned The Financial Aid Office will work with campus leadership and staff to ensure an accurate reporting process is in place to track gainful employment and completion. Documentation will be required by campus leadership to show communication efforts for students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause Th...
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Corrective Action Taken or Planned City Colleges sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports CCC enrollment data to NSLDS. City Colleges (Records, Financial Aid, Decision Support and the Office of Information Technology) continues to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: May 1, 2024
Finding 4263 (2023-004)
Material Weakness 2023
Management believes that the previous Director of Finance drew down the funds in error. Going forward, a record of all funds drawn will be maintained and will include documentation to support the amount of the drawdown.
Management believes that the previous Director of Finance drew down the funds in error. Going forward, a record of all funds drawn will be maintained and will include documentation to support the amount of the drawdown.
View Audit 6573 Questioned Costs: $1
U.S. Agency for International Development 2023-001 Collaboration for African Biodiversity (ABCG III) – Assistance Listing no. 98.001 Recommendation: Management should ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible...
U.S. Agency for International Development 2023-001 Collaboration for African Biodiversity (ABCG III) – Assistance Listing no. 98.001 Recommendation: Management should ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: AWF management agrees with the finding and recommendation set forth and has developed a corrective action plan. The procurement and contracts manager is now ensuring that AWF captures the date when taking a screenshot from the OFCCP Debarred Companies list when conducting background checks on vendors so as to document that the search has been performed prior to entering into a contract with the vendor.
The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated C...
The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated Completion Date: The corrective action was completed on September 6, 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659
View Audit 6551 Questioned Costs: $1
The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances authorization, the credit balance refunds requested are proces...
The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances authorization, the credit balance refunds requested are processed timely. Anticipated Completion Date: The corrective action was completed in May 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659
Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholar...
Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholarship to avoid overawards. All state and federal aid and endowed scholarships are applied first and then the scholarship covers the remaining tuition cost. The corrective action was completed in September 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659
View Audit 6551 Questioned Costs: $1
Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticip...
Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticipated Completion Date: The corrective action was completed on October 27, 2023 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659
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