Corrective Action Plans

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Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit find...
Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any cr...
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.
All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.
All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be...
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases a...
Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases attendance without providing official notice. Based on the University’s review of institutional records and applicable regulatory guidance in effect during the audit period, management believes the withdrawal processing methodology applied was reasonable and consistent with institutional procedures and Title IV requirements. For three of the four students identified, the data reported to NSLDS reflected the institution’s determination date rather than the withdrawal date. Management maintains that this approach was the result of interpretation applied to specific withdrawal circumstances and did not materially misrepresent the students’ enrollment status or Title IV outcomes. For the remaining student, management agrees that a clerical data-entry error resulted in an incorrect withdrawal date being reported to NSLDS; however, this instance was isolated and does not represent a systemic control deficiency. While the University does not agree that the instances cited constitute noncompliance, management acknowledges the auditor’s concern regarding consistency in distinguishing withdrawal dates from determination dates for NSLDS reporting purposes. In response, and without conceding noncompliance, the University will enhance its policies, procedures, and internal controls to promote consistent application of regulatory definitions and reduce the risk of future discrepancies.
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment ...
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment with existing practices. The finalized policies will be presented for Board approval and implemented by March 18, 2026, and responsibility for ongoing monitoring and periodic review has been assigned to the Chief Financial Officer and Director of Administration to ensure continued compliance. Training will be provided to applicable staff, and compliance with the updated policies will be incorporated into management’s periodic internal reviews.
Finding - Eligibility - Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063: June 30, 2025 Award Year: U.S. Department of Education Criteria or Specific Requirement The amount of a student’s Pell Grant for an academic...
Finding - Eligibility - Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063: June 30, 2025 Award Year: U.S. Department of Education Criteria or Specific Requirement The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (34 CFR 690.62 through 690.66). Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Condition Of the 40 students selected for eligibility testing, two students within the sample were incorrectly awarded aid based upon their specific circumstances. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will strengthen quality control through improved reporting and staffing to ensure accurate and compliant student aid awards. Names of Contact Persons Responsible for Corrective Action: Anne-Marie Caruso, Associate Vice President, Student Financial Services; Beck Gusler, Director Financial Aid Compliance. Anticipated Completion Date: December, 2025 Summary Schedule of Prior Audit Findings None.
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the sch...
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the scheduled disbursement date according to updated procedures when disbursement occurs earlier than the scheduled date to ensure accuracy of reporting data to COD. These are updates to the current Disbursement Policy and Procedures.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure deposits are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure deposits are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure withdrawals are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure withdrawals are made as required by the regulatory agreement.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:...
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office updated procedures when citizenship documentation is received for a student previously classified as a noncitizen. The Financial Aid Office will notify the Office of Records and Registration of the student’s status change. Prior to disbursing Title IV aid, the Financial Aid Office will verify with the Office of Records and Registration that the student has been added to required NSLDS reporting. Name(s) of the contact person(s) responsible for corrective action: Tasha Marwitz Planned completion date for corrective action plan: Effective immediately.
The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthe...
The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: 5/31/2026. Responsible Contact Person: Anthony Daniels-Halisi, CEO.
Finding 2025-002: MAINTENANCE OF EFFORT – SIGNIFICANT DEFICIENCY Federal Program: Title I, Part A (84.010) Auditee Contact Person: James Ragsdale, CFO Expected Completion Date: July 31, 2026 Condition: The School’s Form 9 report, used by the IDOE to calculate Maintenance of Effort, was found to be u...
Finding 2025-002: MAINTENANCE OF EFFORT – SIGNIFICANT DEFICIENCY Federal Program: Title I, Part A (84.010) Auditee Contact Person: James Ragsdale, CFO Expected Completion Date: July 31, 2026 Condition: The School’s Form 9 report, used by the IDOE to calculate Maintenance of Effort, was found to be unreliable. Reported expenditures on the Form 9 did not reconcile with the Network’s cash-basis financial records for the period of July 1, 2024, to June 30, 2025. Corrective Action Plan: To ensure accurate reporting and compliance with Federal MOE standards, Purdue Polytechnic High School of Indianapolis, Inc. will implement the following: Form 9 Reconciliation Protocol: The School will implement a mandatory reconciliation between the general ledger cash-basis reports and the Form 9 Biannual Financial Report prior to each submission (January and July). Standardized Chart of Accounts: The CFO will review all account mappings to ensure they strictly follow the SBOA Uniform Compliance Guidelines for Indiana Charter Schools. This will ensure expenses are categorized correctly by fund, object, and function as required for IDOE reporting. Quarterly Internal Audits: The Finance Team will perform a Form 9 reconciliation quarterly to identify and correct any discrepancies in cash-basis recording before the official reporting window opens. Staff Training: The CFO will attend IDOE Office of School Finance training sessions specifically focused on Form 9 submission and Maintenance of Effort compliance. Audit Trail Documentation: For every Form 9 submission, the CFO will maintain a "reconciliation folder" containing the original trial balance and the crosswalk used to generate the Form 9.
Finding No. 2025-002 – Documented Review and Approval of Grant Expenditures Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to e...
Finding No. 2025-002 – Documented Review and Approval of Grant Expenditures Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to ensure management documents the review and approval of grant expenditures. Anticipated Completion Date – Completed for fiscal year end June 30, 2026
Finding 2025-001 – Timely Preparation of Monthly Grant Expenditure Reports Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to en...
Finding 2025-001 – Timely Preparation of Monthly Grant Expenditure Reports Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to ensure monthly grant expenditure reports were submitted on a timely basis. Anticipated Completion Date – Completed for fiscal year end June 30, 2026
The district has updated procedures to include review of the Quarterly Financial Summary reports by someone other than the preparer of the reports prior to submission. Review will be documented. This finding was corrected in time for the 2nd Quarterly Financial Summary reporting (Oct-Dec 2024). Due ...
The district has updated procedures to include review of the Quarterly Financial Summary reports by someone other than the preparer of the reports prior to submission. Review will be documented. This finding was corrected in time for the 2nd Quarterly Financial Summary reporting (Oct-Dec 2024). Due to the timing of the 2024-25 Single Audit, the 1st Quarterly Financial Summary had already been submitted under the old process, which resulted in this finding to be a repeat of a prior year finding.
Finding # 2025 -001- Lack of Segregation of Duties Over Payroll (Prior Year Finding # 2024 -001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. ...
Finding # 2025 -001- Lack of Segregation of Duties Over Payroll (Prior Year Finding # 2024 -001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The limited size of the District's office staff prevents the ideal segregation of functions over payroll. The Payroll and Human Resources Administrative Assistant is the only employee responsible for entering employee salaries and hourly pay rates and has access to process payroll. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties over payroll. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: We recommend employee salary and hourly pay rates be reviewed and approved by someone independent of the payroll process. We also recommend an independent review and approval of payroll registers prior to distribution or direct deposit processing. Response: We agree with this finding. Due to staffing limitations, full segregation of payroll duties is not currently feasible, however, the District will implement additional compensating controls, including independent review and approval of employee salaries and hourly rates and payroll registers prior to processing. Contact Person Ryan Bohnsack Anticipated Completion: Not Applicable
Betsy Rohde, CEO/Business Manager for the Colome School District, is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the district's business office. The size of the school district and the monetary resourc...
Betsy Rohde, CEO/Business Manager for the Colome School District, is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the district's business office. The size of the school district and the monetary resources available prevent the hiring of additional staffing to the business office at the proper levels for internal controls. Planned Corrective Action Plan: The Colome School District has an internal controls policy to identify areas of risk and implements that policy to reduce the risk of any mistakes and inappropriate or illegal activity within the school district. The school board takes an active role in monitoring financials, including reviewing the bank statements, claims, and financial sofware reports each month. They may request any supporting documentation that is not already provided at school board meetings by meeting one on one with the CEO/Business Manager. The principal was added to email alerts of all bank transfers including payroll and ACH payments. This ensures an additional staff member is notified when the CEO/Business Manager makes financial transactions within the school district's bank accounts. The school board will review the policy to identify any areas that still leave a significant risk to ensure all financial activities are monitored by more than one individual. This is an ongoing process.
Management agrees with the finding. Management at the System Office will work with KVCC and YCCC to implement a process in which all Direct Loan disbursements receive notification within the 30-day window. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Fin...
Management agrees with the finding. Management at the System Office will work with KVCC and YCCC to implement a process in which all Direct Loan disbursements receive notification within the 30-day window. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.
Management agrees with the finding. Management at the System Office will work with CMCC, YCCC, MCCS IT Shared services and specialists with the Student Information System vendor to implement a process in which all disbursement calculations are checked by the software platform for accuracy. The timin...
Management agrees with the finding. Management at the System Office will work with CMCC, YCCC, MCCS IT Shared services and specialists with the Student Information System vendor to implement a process in which all disbursement calculations are checked by the software platform for accuracy. The timing of this resolution is anticipated to occur in 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.
Management agrees with the finding. Management at the System Office will work with EMCC and CMCC management to implement a process which verifies all refund calculations of Title IV funds (R2T4) are reviewed by the appropriate level of management to ensure timely filing to the COD system is occurrin...
Management agrees with the finding. Management at the System Office will work with EMCC and CMCC management to implement a process which verifies all refund calculations of Title IV funds (R2T4) are reviewed by the appropriate level of management to ensure timely filing to the COD system is occurring. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cros...
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar
Views of Responsible Officials and Planned Corrective Actions – Total Health Care will conduct regular testing of its application process for the sliding fee discount. This will include reviews of the documents and support provided by applicants for the sliding fee. These reviews will be conducted r...
Views of Responsible Officials and Planned Corrective Actions – Total Health Care will conduct regular testing of its application process for the sliding fee discount. This will include reviews of the documents and support provided by applicants for the sliding fee. These reviews will be conducted randomly throughout the year and will be based on sample selections. Total Health Care is committed to insuring that every applicant who is eligible for its sliding fee discount is accurately identified, and the sliding fee benefit is correctly awarded. These steps will also include random and unannounced observation and inspection of the sliding fee process. Organization Contact Person Responsible for Corrective Action – Richard Greene, CFO Anticipated completion date: 6/30/26
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