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Corrective Action Plans

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Finding 2309 (2023-001)
Material Weakness 2023
Terraces Assisted Living INC
MN
Questioned Costs HUD Housing Programs Material Weakness
2023-001 - Management Fees Name of contact person - Vicky Dwyer, CFO, Great Lakes Management Company Corrective action - Management began the process of requesting these changes from HUD prior to when the changes went into effect, working through the mortgage company. However, due to turnover at t...
2023-001 - Management Fees Name of contact person - Vicky Dwyer, CFO, Great Lakes Management Company Corrective action - Management began the process of requesting these changes from HUD prior to when the changes went into effect, working through the mortgage company. However, due to turnover at the mortgage company, the request for approval by HUD was never sent to HUD. As a result, management is now currently in the process of working with HUD and the mortgage company to obtain all necessary approvals. Proposed completion date - Management has put in the necessary requests with HUD and the mortgage company to receive the necessary approvals, and the finding will be corrected once HUD has issued its approval or other response to Management.
View Audit 3954 Questioned Costs: $1
Pontiac Academy for Excellence
MI
Cash Management Program Income Internal Control / Segregation of Duties
Finding and Recommendation - Finding: 2023‐001 (repeat finding 2022-002, 2021‐001 & 2020‐002) Finding Type: Noncompliance with laws and regulations. Condition: The Academy NSFSA’s fund balance exceeded the allowable three months’ average expenditures balance as of June 30, 2023. The Academy had a...
Finding and Recommendation - Finding: 2023‐001 (repeat finding 2022-002, 2021‐001 & 2020‐002) Finding Type: Noncompliance with laws and regulations. Condition: The Academy NSFSA’s fund balance exceeded the allowable three months’ average expenditures balance as of June 30, 2023. The Academy had approximately 4.96 months of expenditures as fund balance as of June 30, 2023. Recommendation: The Academy should ensure it has proper internal controls in place to comply with its annual external reporting requirements in accordance with state law. Corrective Action Plan - The management company for the Academy will work with the Academy leadership to increase expenditures in a manner necessary to spend down the excess fund balance in an allowable and timely fashion. The spend down plan will include improvements to the food service program, including adding an additional food service support position. The number of salad bar offerings and daily hot breakfast options will be increased for all grade levels. The Academy will also explore allowable options for spending funds on supplies, equipment and initiatives that will create sustainable improvements to the food service program for future years. Responsible Department - Finance department and Food Service department Responsible Persons - Melinda Benkovsky, VP of Finance Gwen Hovey, Food Service Coordinator Planned Completion Date (TBD or Date) - June 30, 2024
View Audit 3941
Finding 2292 (2023-002)
Material Weakness 2023
Bellin College, Inc.
WI
Reporting Internal Control / Segregation of Duties
Finding 2023-002 Pell Under Awarded It was discovered during the annual audit that Pell Grant awards for the 2022-2023 academic year were calculated on the original Pell Grant Payment Schedules released by the US Dept of Education. The financial aid office did not see the communication from the US ...
Finding 2023-002 Pell Under Awarded It was discovered during the annual audit that Pell Grant awards for the 2022-2023 academic year were calculated on the original Pell Grant Payment Schedules released by the US Dept of Education. The financial aid office did not see the communication from the US Dept of Education regarding the Revised Pell Grant Payment Schedules which were released later in the spring of 2022. As a result, students were under awarded. Corrective Action The Director of Financial Aid (DFA) contacted the US Dept of Education for guidance on how to rectify the issue. The DFA was instructed to request an extension of the 2022-2023 Pell Grant processing via a link on the COD website. The extension was approved. The DFA then manually processed a Pell Grant disbursement for each Pell Grant recipient to increase the total Pell Grant award for each to the amount entitled. Each of the 80 Pell Grant recipients was issued a check as payment for the balance of the Pell Grant award. The checks were distributed the week of October 16, 2023 to each student along with a written explanation of the oversight. Going forward, the DFA will periodically check the US Dept of Education Knowledge Center website to ensure any schedule revisions are obtained. Person Responsible for Corrective Action: Ginger Krummen Schraven Timing of Corrective Action: October 2023
View Audit 3929
Finding 2291 (2023-001)
Significant Deficiency 2023
Bellin College, Inc.
WI
Reporting Internal Control / Segregation of Duties
Finding 2023-001 Common Origination and Disbursement (COD) Reporting Two instances were found in which the disbursement date on COD did not match the date on the student ledger. Corrective Action Going forward, the Director of Financial Aid (DFA) will provide the Bursar with a report from the COD...
Finding 2023-001 Common Origination and Disbursement (COD) Reporting Two instances were found in which the disbursement date on COD did not match the date on the student ledger. Corrective Action Going forward, the Director of Financial Aid (DFA) will provide the Bursar with a report from the COD that reflects the disbursement date. Before posting federal award batches, the Bursar will verify the date on the batch matches the SIS system. Person Responsible for Corrective Action: Ginger Krummen Schraven Timing of Corrective Action: October 2023
View Audit 3929
Finding 2286 (2023-001)
Material Weakness 2023
Mitchell Public Schools
NE
Reporting Internal Control / Segregation of Duties
2023-001 SEGREGATION OF ACCOUNTING FUNCTIONS Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Education should constantly be aware of the possibil...
2023-001 SEGREGATION OF ACCOUNTING FUNCTIONS Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Education should constantly be aware of the possibility that errors or fraud could occur and continue current practices mitigating these possibilities and examine and implement other mitigating controls when appropriate. Action Taken: The District has assessed the benefits and costs associated with proper segregation of duties for the district and has determined that costs would outweigh benefits received. The District understands the inherent risks associated with improper segregation of accounting functions. Management has communicated the need for transactions to be well supported by documentation as well as seeking appropriate authorization when appropriate. The District requires monthly reporting to the Board of Education for all disbursements to ensure transactions are proper and potential errors and irregularities are identified on a timely basis. The District will continue to review accounting procedures and processes to further mitigate this internal control deficiency whenever possible and feasible.
View Audit 3928
Brownsburg Village, Inc. Dba Lakeview Place Apartments
IN
Reporting
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the security deposit trust account and ensure tha...
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the security deposit trust account and ensure that the tenant security deposit liability is fully funded by the trust cash account at all times, as required by the Regulatory Agreement. Action Taken: Management deposited the required deposit to the security deposit trust cash account on July 17, 2023.
View Audit 3920
Finding 2278 (2023-002)
Material Weakness 2023
Independent School District No. 435
MN
Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties
U.S. DEPARTMENT OF EDUCATION MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE 2023-002 – Special Tests and Provisions – Wage Rate Requirements Recommendation: We recommend that the District or its agent review their internal controls and policies over payments on contracts subject to the Dav...
U.S. DEPARTMENT OF EDUCATION MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE 2023-002 – Special Tests and Provisions – Wage Rate Requirements Recommendation: We recommend that the District or its agent review their internal controls and policies over payments on contracts subject to the Davis-Bacon Act provision to ensure the required weekly certified contractor and subcontractor payrolls and statements of compliance are obtained and compared to applicable approved wage rates before approving payment. Actions Planned/Taken: The District will establish controls to follow all applicable Uniform Guidance requirements, including the requirements of 29 CFR section 5.5 when applicable. Contact Person Responsible for Corrective Action: Michelle Heisler, Business Manager Planned Completion Date: November 2023
View Audit 3916
Finding 2276 (2023-001)
Material Weakness 2023
South Central Cooperative
SD
Internal Control / Segregation of Duties Material Weakness Reporting
The South Central Cooperative Director, Kristi Hilzendeger, is the contact person responsible for the corrective action plan for this finding. This finding is due to the size of the South Central Cooperative, which precludes staffing at a level sufficient to provide an ideal environment for interna...
The South Central Cooperative Director, Kristi Hilzendeger, is the contact person responsible for the corrective action plan for this finding. This finding is due to the size of the South Central Cooperative, which precludes staffing at a level sufficient to provide an ideal environment for internal controls. The Cooperative has developed policies to help monitor the lack of segregation of duties, but due to the size of the Cooperative it is not feasible, or fiscally responsible to implement anything else at this time. The Cooperative will continue to follow the controls currently in place.
View Audit 3913
Vermont State Colleges
VT
Student Financial Aid
Corrective Action Plan: New procedures to effectively collaborate and share information between financial aid and student accounts will be drafted to ensure unclaimed checks are processed within the required window. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sh...
Corrective Action Plan: New procedures to effectively collaborate and share information between financial aid and student accounts will be drafted to ensure unclaimed checks are processed within the required window. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO
View Audit 3911
Vermont State Colleges
VT
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Corrective Action Plan: CCV In June 2023 CCV implemented a new process to verify that student records reported to the Clearinghouse have been correctly and accurately reported to the National Student Database (“NSLDS”). VTSU In March 2023 VTSU implemented new procedures to ensure all enrollment stat...
Corrective Action Plan: CCV In June 2023 CCV implemented a new process to verify that student records reported to the Clearinghouse have been correctly and accurately reported to the National Student Database (“NSLDS”). VTSU In March 2023 VTSU implemented new procedures to ensure all enrollment status changes were processed consistently. Since implementation, no new findings were identified. Timeline for Implementation of Corrective Action Plan: Immediately
View Audit 3911
Vermont State Colleges
VT
Student Financial Aid Matching / Level of Effort / Earmarking
Corrective Action Plan: CCV CCV implemented new processes in March and June of 2023 to address these issues. The first process verifies that a student’s aid has been updated and recalculated before closing the record. The second process ensures additional training and controls to make sure student w...
Corrective Action Plan: CCV CCV implemented new processes in March and June of 2023 to address these issues. The first process verifies that a student’s aid has been updated and recalculated before closing the record. The second process ensures additional training and controls to make sure student withdrawals occur within the appropriate timeframe. VTSU VTSU reprocessed the error return to the Title IV funds with the correct information and cancelled the loan completely. Training with all staff has been reinforced. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO
View Audit 3911
Vermont State Colleges
VT
Student Financial Aid
Corrective Action Plan: VTSU A new process for verifying last date of attendance by the registrar’s office was implemented for the 2023-2024 academic year. The new process includes verifying last date of attendance supplied by the student on their withdrawal form with faculty. The verified date will...
Corrective Action Plan: VTSU A new process for verifying last date of attendance by the registrar’s office was implemented for the 2023-2024 academic year. The new process includes verifying last date of attendance supplied by the student on their withdrawal form with faculty. The verified date will be used for all transactions of record. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO
View Audit 3911
Vermont State Colleges
VT
Student Financial Aid Eligibility
Corrective Action Plan: VTSU This was an isolated instance and attributed to human error. Training with all staff has been reinforced. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO
Corrective Action Plan: VTSU This was an isolated instance and attributed to human error. Training with all staff has been reinforced. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO
View Audit 3911
Vermont State Colleges
VT
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Corrective Action Plan: CCV Disbursement errors noted are isolated errors due to system issues within COD, testing of processes that resulted in an error, and a scheduling issue related to a holiday break. A new automated COD report in Colleague will be created by CCV and implemented in November 202...
Corrective Action Plan: CCV Disbursement errors noted are isolated errors due to system issues within COD, testing of processes that resulted in an error, and a scheduling issue related to a holiday break. A new automated COD report in Colleague will be created by CCV and implemented in November 2023. VTSU VTSU will continue to monitor and report weekly. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO Finding number: 2023-02 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year: 2023
View Audit 3911
Finding 2251 (2023-001)
Significant Deficiency 2023
Monarch Disabled Housing, Inc.
CA
HUD Housing Programs
The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits will be deposited into the reserve fund subsequent to year-end.
The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits will be deposited into the reserve fund subsequent to year-end.
View Audit 3899
Finding 2250 (2023-001)
Significant Deficiency 2023
Public Broadcasting Service and Subsidiaries
VA
Subrecipient Monitoring Reporting § 200.303
The following action has been implemented to ensure that the required information is collected and reported timely in the FFATA Subaward Reporting System (FSRS). Beginning in the fiscal year 2024, the Company implemented a formal policy and procedure to file a FFATA sub-award report by the end of th...
The following action has been implemented to ensure that the required information is collected and reported timely in the FFATA Subaward Reporting System (FSRS). Beginning in the fiscal year 2024, the Company implemented a formal policy and procedure to file a FFATA sub-award report by the end of the month following the month in which they award any sub-grant or amendment equal to or greater than $30,000 in federal funds. The Company has completed and filed the required FFATA Subaward reporting for those sub-grants equal to or greater than $30,000 in federal funds and is current with the required reporting as of November 2023 and will monitor future sub-grants of federal funds in order to comply with the reporting requirements. Individual(s) Responsible for Corrective Action Plan Name: Meghan Biggs Position: VP & Controller Contact Number: (703) 739 7516 Anticipated Completion Date: November 2, 2023
View Audit 3886
Housing Associates, Inc.
MD
Questioned Costs
$1,096 was deposited to the Replacement Reserve account in September 2023 to replenish the account for the erroneous unauthorized withdrawal from the account in June 2023
$1,096 was deposited to the Replacement Reserve account in September 2023 to replenish the account for the erroneous unauthorized withdrawal from the account in June 2023
View Audit 3879 Questioned Costs: $1
Finding 2247 (2023-002)
Significant Deficiency 2023
Ralls County R-II School District
MO
Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.302
I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditur...
I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the district spreadsheets will include review by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple review and the addition of PO number and date of pay request this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched the grant funds obtained through reimbursement. The new procedure will begin immediately. Tara Lewis Superintendent
View Audit 3876
Finding 2231 (2023-001)
Significant Deficiency 2023
University of Dubuque
IA
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). Summer is an optional term for students ...
Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). Summer is an optional term for students and only students who are enrolled for that semester are submitted to NSC. To ensure withdraw dates during the summer semester are being reported on a timely basis Financial Planning will manually enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/18/2023
View Audit 3808
Wayland Baptist University
TX
Questioned Costs Allowable Costs / Cost Principles Eligibility
Need Analysis and Loan Proration Planned Corrective Action: Executive Director will provide in-house training to all advising staff to ensure proper understanding of awarding, paying special attention to over award resolution. Several selection sets have been created in PowerFAIDS to aid in identif...
Need Analysis and Loan Proration Planned Corrective Action: Executive Director will provide in-house training to all advising staff to ensure proper understanding of awarding, paying special attention to over award resolution. Several selection sets have been created in PowerFAIDS to aid in identifying over awarded students and these will be run and monitored regularly. In June 2023, WBU hired a full-time staff member to serve as a Financial Aid Compliance Specialist in the Office of Financial Aid and this position is devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: October 31, 2023
View Audit 3804 Questioned Costs: $1
Finding 2229 (2023-005)
Significant Deficiency 2023
Wayland Baptist University
TX
Questioned Costs Significant Deficiency
Incorrect Pell Calculations Planned Corrective Action: PowerFAIDS set-up has been adjusted to accommodate individual Period of Enrollment processing for the 2023-24 academic year. Related procedures have also been updated. These adjustments should reduce the amount of manual calculation of Pell eli...
Incorrect Pell Calculations Planned Corrective Action: PowerFAIDS set-up has been adjusted to accommodate individual Period of Enrollment processing for the 2023-24 academic year. Related procedures have also been updated. These adjustments should reduce the amount of manual calculation of Pell eligibility needed for modular enrollment, which will reduce the chance of similar over and under awarding in the future by reducing the risk of human error. Executive Director has provided in-house training to all advising staff to ensure proper understanding of calculating Pell. In June 2023, WBU hired a full-time staff member to serve as a Financial Aid Compliance Specialist in the Office of Financial Aid and this position is devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: October 31, 2023
View Audit 3804 Questioned Costs: $1
Finding 2223 (2023-004)
Significant Deficiency 2023
Wayland Baptist University
TX
Subrecipient Monitoring Significant Deficiency
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Wayland Baptist University will implement multi-factor authentication (MFA) in alignment with Center for Internet Security (CIS) Control 6 for all externally exposed applications. We will mitigate risk for internal-only applicatio...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Wayland Baptist University will implement multi-factor authentication (MFA) in alignment with Center for Internet Security (CIS) Control 6 for all externally exposed applications. We will mitigate risk for internal-only applications by enabling MFA where available and authorizing access to vulnerable applications only from our Single Sign On (SSO) and MFA portals when available. We will evaluate and implement a third-party solution to assist in automated vulnerability scanning of internal and externally exposed assets in alignment with CIS Control Safeguards 7.5 and 7.6. We will evaluate and implement a third-party solution to align with CIS Control 18 to conduct penetration testing annually. Establishing a vendor management policy and review standard will be completed with an emphasis on following CIS Control 15, focusing on maintaining an inventory of service providers, including classification of the service providers, and ensuring that service-provider contracts include security requirements. The Chief Information Officer will write and provide annually a report to the Board of Trustees detailing Wayland Baptist University's information security program. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO Anticipated Date of Completion: June 30, 2024
View Audit 3804
Finding 2221 (2023-003)
Material Weakness 2023
Wayland Baptist University
TX
Reporting Student Financial Aid Eligibility
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: 100% of example students (16 which overlap with the 12 mentioned) were accurately reported with a “W” withdrawn status to National Student Clearinghouse (NSC) in a timely (monthly) manner, but thi...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: 100% of example students (16 which overlap with the 12 mentioned) were accurately reported with a “W” withdrawn status to National Student Clearinghouse (NSC) in a timely (monthly) manner, but this correct status did not get transferred to NSLDS. An internal SSRS report for official and unofficial withdrawals, which also accurately reflects these withdrawn students, will remain available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. Several related WBU questions to our primary NSC support employee are awaiting a response from NSC. The NSC reporting tool(s) will be updated to make sure the correct combination of fields and corresponding data sources are used for dates. One of multiple date fields may have been misunderstood by the tool’s historical authors. A field-by-field analysis plus any needed corrections to the queries are part of the planned corrective action. Post-submission error corrections by registrar staff via NSC will be spot-checked by Information Technology for date-related warnings. If this cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. Data improvements needed for the PowerCampus baseline product’s NSC reporting tool will also be included in testing this further. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO and Andrew Shamblin, Programmer Analyst Anticipated Date of Completion: June 30, 2024
View Audit 3804
Finding 2219 (2023-002)
Material Weakness 2023
Wayland Baptist University
TX
Student Financial Aid Material Weakness
Return of Title IV (R2T4) Calculations Planned Corrective Action: Executive Director of Financial Aid will continue to provide regular in-house R2T4 training specific to WBU for all staff and will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased t...
Return of Title IV (R2T4) Calculations Planned Corrective Action: Executive Director of Financial Aid will continue to provide regular in-house R2T4 training specific to WBU for all staff and will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. The staff member responsible for disbursements, being new to her role in fall of 2022, did not realize that fall disbursements needed to be processed even after the end of the fall term. Once discovered, this was immediately addressed. In June 2023, WBU hired a full-time staff member to serve as a Financial Aid Compliance Specialist in the Office of Financial Aid and this position is devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: October 31, 2023
View Audit 3804
Finding 2218 (2023-002)
Material Weakness 2023
School District of Pickens County
SC
Equipment & Real Property Management Procurement, Suspension & Debarment Subrecipient Monitoring
CONTACT PERSON: Matt Owens, Chief Financial Officer, mattowens@pickens.k12.sc.us CORRECTIVE ACTION: The District will ensure that inventory records are maintained for federally funded equipment and services as required. PROPOSED COMPLETION DATE: Prior to June 30, 2024
CONTACT PERSON: Matt Owens, Chief Financial Officer, mattowens@pickens.k12.sc.us CORRECTIVE ACTION: The District will ensure that inventory records are maintained for federally funded equipment and services as required. PROPOSED COMPLETION DATE: Prior to June 30, 2024
View Audit 3800
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