Corrective Action Plans

Finding 71647 (2022-001)

Significant Deficiency 2022

South Winneshiek Community School District

IA

Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN March 8, 2023 To: U.S. Department of Education South Winneshiek Community School District respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 123 W. ...

CORRECTIVE ACTION PLAN March 8, 2023 To: U.S. Department of Education South Winneshiek Community School District respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 123 W. Water Street Decorah, IA 52101 Audit period: Year ended June 30, 2022. The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING - FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Education: ? Education Stabilization Fund (ESF): ? Federal Assistance Listing Number 84.425B o Discretionary Grants: Rethink K-12 Education Models (ARP) ? Federal Assistance Listing Number 84.425C o COVID-19 Governor?s Emergency Education Relief Fund (GEER II) ? Federal Assistance Listing Number 84.425D o COVID-19 Elementary and Secondary School Emergency Relief Fund (ESSER II) ? Federal Assistance Listing Number 84.425U o American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER III) Internal control deficiencies: See Finding 2022-001 Recommendation: The District should review the operating procedures of the District offices to obtain the maximum internal control possible under the circumstances utilizing currently available staff. While we do recognize that the District is not large enough to permit a segregation of duties for effective internal controls, we believe it is important the Board be aware that this condition does exist. Action Taken: Management is cognizant of this limitation and will implement additional procedures where possible. Page 2 If the U.S. Department of Education have questions regarding this plan, please call Kris Smith at 563-562-3269. Sincerely yours, Kris Smith South Winneshiek Community School District Business Manager, SBO, Board Secretary/Treasurer cc: Christi L. Meyer, CPA

View Audit 64566

Finding 71643 (2022-001)

Significant Deficiency 2022

Rogers School District #30

AR

Special Tests & Provisions § 200.326

Views of responsible officials and planned corrective actions: The District agrees with the finding and will institute the additional training and review process recommended.

View Audit 64564

Finding 71642 (2022-001)

Significant Deficiency 2022

El Paso County Housing Authority

TX

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. M...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Miguel Hernandez, Executive Director, will be responsible to implement this corrective action by June 30, 2023.

View Audit 63135 Questioned Costs: $1

Finding 71639 (2022-002)

Significant Deficiency 2022

Markesan District Schools

WI

Questioned Costs Procurement, Suspension & Debarment Cash Management

Condition: There were three Education Stabilization Fund construction projects performed by a contractor. Grant expenditures for the projects totaled $770,436. (ESSER II - $401,545 and ESSER III $368,891). There was not a prevailing wage clause in the contracts and certified payrolls were not receiv...

Condition: There were three Education Stabilization Fund construction projects performed by a contractor. Grant expenditures for the projects totaled $770,436. (ESSER II - $401,545 and ESSER III $368,891). There was not a prevailing wage clause in the contracts and certified payrolls were not received. Questioned Costs: $770,436. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement of the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: The District was not aware that the wage requirement applied to these construction projects. Effect: Potential reimbursement for costs that did not follow the wage rate requirements. Context: The PA, HVAC, and water heater construction projects began in May, June, and September 2021, respectively, before the District was aware of wage rate requirements. After becoming aware of the requirement, there were no further construction projects. Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Response: The District became aware of wage rate requirements after finishing the project. Before bidding any future construction projects more than $2,000, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received for any such contracts. Contact Person: Tim Zacharias Anticipated Completion: June 30, 2023

View Audit 63134 Questioned Costs: $1

Finding 71635 (2022-001)

Significant Deficiency 2022

Markesan District Schools

WI

Internal Control / Segregation of Duties

Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstate...

Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstatements on a timely basis. Cause: A small number of individuals within the District?s administration perform substantially all accounting functions and have control over both records and assets. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district?s operations. Response: We agree and will continue to provide supervision and monitor accounting information and operations, obtain explanations for variances from unexpected results and work to increase segregation of duties. The Assistant to the Business Manager will continue to clear checks in Skyward as part of the bank reconciliation process. The District Administrator will review and initial all journal entries. The Assistant to the Business Manager will review payroll on a monthly basis, and the District Administrator will review payroll on a quarterly basis. Contact Person: Tim Zacharias Anticipated Completion: Not Applicable

View Audit 63134

Finding 70898 (2022-001)

Significant Deficiency 2022

Cairo-Durham Central School District

NY

HUD Housing Programs

The district received from RBT, CPA's, LLP the year-end June 30, 2022 Report on Federal Compliance Audit Report for the school district. The district is required to complete a corrective action plan within ninety (90) days of receiving the report or management letter. The corrective action plan is t...

The district received from RBT, CPA's, LLP the year-end June 30, 2022 Report on Federal Compliance Audit Report for the school district. The district is required to complete a corrective action plan within ninety (90) days of receiving the report or management letter. The corrective action plan is the response to any Management Letter Comments/Findings contained in the annual external audit report or management letter, and will be filed with the State Education Department once approved by the Board of Education. Listed below is the corrective action plan for the Management Letter comments contained in the Financial Statement for the year ended June 30, 2022: Management Letter Comment #1: Federal Program: CFDA Nos.: 84.425D Education Stabilization Fund, ESSER2, 84.425U Education Stabilization Fund, ESSER3 ARP, 84.425W Education Stabilization Fund, ESSER3 Homeless and 84.425U Education Stabilization Fund, UPK ARP Condition: The District does not comply with the required standards of Support of Salaries and Wages because employees whose time was charged to federal grants during fiscal year ending 6/30/2022 did not complete monthly or semiannual time certification forms or personnel activity reports (PAR) for their time distribution. Some employees used timesheet to support their time charges on the grants but the timesheets did not indicate the grant they were working on. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certifications or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h. (5) of the 0MB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee's total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy the specific requirements of this and other appendices under 2 CFR Part 225, and that the total compensation for individual employees: (3) Is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3).) Questioned Costs: There are no questioned costs. Effect: The District did not comply with the required standards of supports of salaries and wages. It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly certifications during the fiscal year and the time sheets did not identify the grant the employee was spending time on. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management require that copies of these payroll certifications be forward to the District Treasurer on a timely basis. Perspective: This is a systematic issue in that controls over the requirement have not been developed to ensure . . issues anse. Repeat: This is not a repeat finding. Management's Response: To address this comment we have revised time sheets to reflect specific grants and have created monthly check sheets for payroll of salaried individuals whose time allocated to each grant is 1 FTE or less. To prevent future occurrences of this deficiency, management has created a checklist of employees who fall in the monthly and semi-annual payroll certification requirement, which is reconciled by the District Treasurer. This will ensure that we receive certifications on a timely basis and can quickly identify missing certifications. Implementation: January 2023

View Audit 63132

Finding 66161 (2022-002)

None 2022

Dallas Theological Seminary

TX

Reporting § 200.329

Inaccurate HEERF Annual Reporting Planned Corrective Action: The financial aid office (FA) will make correction to Year 2 HEERF Annual Reporting when the report opens in early 2023. The FA office will work closely with the business office and the IRE Department to get the reports needed to answer...

Inaccurate HEERF Annual Reporting Planned Corrective Action: The financial aid office (FA) will make correction to Year 2 HEERF Annual Reporting when the report opens in early 2023. The FA office will work closely with the business office and the IRE Department to get the reports needed to answer the questions correctly for the Year 2 corrections and well as Year 3 reporting. Person Responsible for Corrective Action Plan: Jennifer McCormack Anticipated Date of Completion: July 2023

View Audit 62040

Finding 66160 (2022-001)

Significant Deficiency 2022

Dallas Theological Seminary

TX

Student Financial Aid Reporting Significant Deficiency

Enrollment Reporting to NSLDS Planned Corrective Action: The registrar?s office (RO) will begin using the Status Discrepancy report that is available in Anthology to identify conflicting information on a student-by-student basis. This report will help in resolving status discrepancies prior to sub...

Enrollment Reporting to NSLDS Planned Corrective Action: The registrar?s office (RO) will begin using the Status Discrepancy report that is available in Anthology to identify conflicting information on a student-by-student basis. This report will help in resolving status discrepancies prior to submitting the report to NSC. Once the Enrollment Report is submitted, the RO will promptly resolve any Error Resolution Reports received from NSC and submit corrections. The RO will continue to follow up with NSC on the status of data transmissions. Person Responsible for Corrective Action Plan: Sabrina Hopson Anticipated Date of Completion: July 2023

View Audit 62040

Finding 65282 (2022-002)

Significant Deficiency 2022

Maryland Institute College of Art

MD

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Federal Agency: U.S. Department of Education Federal Program: COVID-19 Education Stabilization Fund AL Number: 84.425E/84.425FFinding Number: 2022-002 Department?s Response: Management acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF qua...

Federal Agency: U.S. Department of Education Federal Program: COVID-19 Education Stabilization Fund AL Number: 84.425E/84.425FFinding Number: 2022-002 Department?s Response: Management acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the College?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.Planned Corrective Action: The college has exhausted all HEERF funding, so a corrective action plan is no longer required. Anticipated Completion Date: N/A Name and title of responsible contact: If you have any questions, please contact De Rodrick Jonkins AVP for Financial Aid, Maryland Institute College of Art djonkins@mica.edu or Quaneshia Armstrong Controller, Maryland Institute College of Art qarmstrong@mica.edu

View Audit 67388

Finding 65281 (2022-001)

Significant Deficiency 2022

Maryland Institute College of Art

MD

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster AL Number: 84.063 Finding Number: 2022-001 Department?s Response: Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-...

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster AL Number: 84.063 Finding Number: 2022-001 Department?s Response: Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. Planned Corrective Action: As recommended the financial aid office has implemented additional monitoring controls. Management will develop a process to perform secondary reviews of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports. Anticipated Completion Date: May 31, 2023 Name and title of responsible contact: If you have any questions, please contact De Rodrick Jonkins AVP for Financial Aid, Maryland Institute College of Art djonkins@mica.edu.

View Audit 67388

Finding 65280 (2022-001)

Material Weakness 2022

Mt. Washington Pediatric Hospital, Inc.

MD

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

Mt. Washington Pediatric Hospital, Inc. and Subsidiaries (the Corporation) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS MATERIAL WEAKNESS 2022-001 Inte...

Mt. Washington Pediatric Hospital, Inc. and Subsidiaries (the Corporation) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS MATERIAL WEAKNESS 2022-001 Internal control deficiency over review of expenditures COVID ? 19 ? Provider Relief Fund (Assistance Listing # 93.498) Recommendation: We recommend that management develop and implement effective internal controls, including review and approval of expenditures prior to submission, to ensure that the report submissions are accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In the audit of MWPH?s Provider Relief Fund (PRF), an error was identified in the Period 1 reporting of benefit expenses (repeat finding 2021-001) as an incremental expense in the HRSA portal. As a result, the Period 2 PRF report included an erroneous duplication of expenditures that stemmed from the Period 1 submission in the amount of $25,195. The Corporation attempted to correct the overstatement of fringe benefits by restating and unintentionally duplicated expenditures in the amount of $206,002 within the Period 2 submission. We believe it is relevant to note that the error was committed and subsequently identified by the MWPH CFO, who submitted information in Period 2 to correct the error. The error occurred when the CFO, who produced, reviewed and submitted all data for this small hospital, included benefits with salary costs in its calculations of Covid-related expenses. Both the salary and benefit costs were legitimate uses of the PRF funds. However, the expenses were included in both the Personnel and the Benefits line of the PRF portal, duplicating the reported expense for Period 2 as described above. The duplication was subsequently corrected and identified by the CFO in February 2023. Planned completion date for corrective action plan: For future submissions, the MWPH CFO will continue to stay current on reporting matters in the HRSA portal and continue to collaborate with UMMS Finance staff on guidance. Submission details will be reviewed by UMMS Finance staff. Name(s) of the contact person(s) responsible for corrective action: Mary Miller, Chief Financial Officer of Mt. Washington Pediatric Hospital, 410-578-5163.

View Audit 67387 Questioned Costs: $1

Finding 65279 (2022-003)

Material Weakness 2022

Cable Telecommunications Association of New York, Inc.

NY

CTANY agrees with the recommendation that the net asset starting balance be analyzed for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure the net asset starting...

CTANY agrees with the recommendation that the net asset starting balance be analyzed for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure the net asset starting balance is monitored. In terms of the outside accountant CTANY is considering the option of consulting with an outside firm to help manage the books and accounting records per the recommendations of this audit report.

View Audit 65627

Finding 65278 (2022-002)

Material Weakness 2022

Cable Telecommunications Association of New York, Inc.

NY

CTANY agrees with the recommendation that accounts payable and related expenses should be monitored for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure account...

CTANY agrees with the recommendation that accounts payable and related expenses should be monitored for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure accounts payable and related expenses are constantly monitored. In terms of the outside accountant CTANY is considering the option of consulting with an outside firm to help manage the books and accounting records per the recommendations of this audit report.

View Audit 65627

Finding 65277 (2022-001)

Material Weakness 2022

Cable Telecommunications Association of New York, Inc.

NY

HUD Housing Programs

CTANY agrees with the recommendation that accounts receivable and related revenue should be monitored for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure accou...

CTANY agrees with the recommendation that accounts receivable and related revenue should be monitored for accuracy. Due to management transition over the past year, the CTANY board and administrative consultants are working to ensure that best practices are put in place going forward to ensure accounts receivable and related revenue are constantly monitored. In terms of the outside accountant CTANY is considering the option of consulting with an outside firm to help manage the books and accounting records per the recommendations of this audit report.

View Audit 65627

Finding 65276 (2022-005)

Material Weakness 2022

Solano Community College District

CA

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.407

U.S. Department of Education 2022-005: Unallowable Costs ? COVID-19 Higher Education Emergency Relief Funds (HEERF)/Coronavirus Aid, Relief and Economic Security (CARES) Act ? Institutional Portion Assistance Listing Number: 84.425F Recommendation: Implement procedures to ensure all grant expenditur...

U.S. Department of Education 2022-005: Unallowable Costs ? COVID-19 Higher Education Emergency Relief Funds (HEERF)/Coronavirus Aid, Relief and Economic Security (CARES) Act ? Institutional Portion Assistance Listing Number: 84.425F Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The unallowable expenses in the HEERF grant will be transferred out of the grant expenses in the 2022-23 fiscal year. Name(s) of the contact person(s) responsible for corrective action: Susan Wheet, VP of Finance and Administration Planned completion date for corrective action plan: The corrective action plan will be implemented by August of 2022.

View Audit 62600 Questioned Costs: $1

Finding 65274 (2022-002)

Significant Deficiency 2022

Solano Community College District

CA

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

U.S. Department of Education 2022-002: Student Financial Assistance Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: 84.268 Recommendation: We recommend the College to evaluate its procedures related to the manual input of information from the student loan request. Explanation...

U.S. Department of Education 2022-002: Student Financial Assistance Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: 84.268 Recommendation: We recommend the College to evaluate its procedures related to the manual input of information from the student loan request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This issue was discovered during the audit process, and we performed the following activities in response: ? We consulted with the auditing team?s national resource about the proper way to correct this award. Implemented by August 2022. ? Following their guidance, we corrected the student?s awards so that the appropriate amount of sub and unsub were in place and then re-ran her R2T4 calculation to make sure everything was correct in our system and on COD. Implemented by September 2022 ? We conducted a review of our other Direct Loan awards, and found that this incident was an isolated manual mistake, not a systemic one. Implemented by August 2022 ? Although the person responsible for this error is no longer employed in the financial aid department, we have done training with the current Direct Loan coordinator to reduce the likelihood of this mistake in the future. Implemented by August 2022 ? We modified the Direct Loan procedure log to include a reminder about this regulation. Implemented by August 2022 Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by September 2022.

View Audit 62600 Questioned Costs: $1

Finding 64889 (2022-001)

None 2022

Sharon Ridge Expansion Corporation

CT

Reporting § 200.512

We agree with the finding. The current year audit will be certified and submitted within the required timeframe.

View Audit 61020

Finding 64657 (2022-003)

Material Weakness 2022

Belcourt Public School District #7

ND

Special Tests & Provisions § 200.326

2022-003 MATERIAL WEAKNESS ? SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevai...

2022-003 MATERIAL WEAKNESS ? SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Corrective Action Plan: The contractor indicated that he would not be using payroll in this particular contract, but rather work would be performed by independent contractors. It was not understood by the District that the contractor would be required to provide weekly certified payroll reports indicating that no payroll occurred during the weekly payroll reporting period. Contractors awarded future construction project contracts applicable to payroll reporting will be required to provide weekly certified payroll reports to the Belcourt School District. Duane Poitra, Business Manager is responsible for this corrective action plan. Anticipated Completion Date: Fiscal Year 2022-23

View Audit 74660

Finding 64502 (2022-001)

Significant Deficiency 2022

Northwest Nazarene University

ID

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.326

2022-001 Higher Education Emergency Relief Funds ? ALN 84.425F Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Explanation of disagreemen...

2022-001 Higher Education Emergency Relief Funds ? ALN 84.425F Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For previously incurred expenses that later fall under the reimbursement guidelines of a Federal or State Grant, the University will review and insure any expenses we submit for reimbursement are verified through our grant procurement policy controls and if the vendor is suspended or disbarred. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022

View Audit 75144

Finding 64497 (2022-002)

Significant Deficiency 2022

Northwest Nazarene University

ID

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation...

2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the fall of 2021, the University changed banking relationships. Outstanding checks from the former bank were cancelled and a check was issued from the new bank. The reissuance of checks showed a flaw in our 240-day reconciliation tool which focused on the check date rather than the original disbursement date. This was an isolated issue and we have adjusted our 240-day review tool to calculate based on the original disbursement date. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022

View Audit 75144

Finding 64492 (2022-003)

Material Weakness 2022

Eastern University

PA

Material Weakness Reporting § 200.329

Higher Education Stabilization Fund Reporting Planned Corrective Action: I have worked with our IT department, specifically the individual that works closely with Financial Aid reports and data, to ensure I have received accurate data in order to correct this report. The IT person who initially prov...

Higher Education Stabilization Fund Reporting Planned Corrective Action: I have worked with our IT department, specifically the individual that works closely with Financial Aid reports and data, to ensure I have received accurate data in order to correct this report. The IT person who initially provided me with the information for the report is no longer in that department. Additionally, I am working with our former CFO who still works for Eastern on Special Projects to submit the Year 3 report. We are sharing our data with our new CFO and our Director of Accounting and Finance to help close the information gap. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 3/24/2023

View Audit 73872

Finding 64477 (2022-004)

Significant Deficiency 2022

Eastern University

PA

Significant Deficiency

Incorrect Pell Calculations Planned Corrective Action: The Financial Aid Counselor that missed making these adjustments is no longer working in our office. Additionally, effective with the 23-24 school year, we as a University have chosen to align our enrollment requirements among undergraduate prog...

Incorrect Pell Calculations Planned Corrective Action: The Financial Aid Counselor that missed making these adjustments is no longer working in our office. Additionally, effective with the 23-24 school year, we as a University have chosen to align our enrollment requirements among undergraduate programs so as not to cause any further confusion or mistakes when a student switches from one program to another. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 1/1/2023

View Audit 73872

Finding 64474 (2022-006)

None 2022

Eastern University

PA

Verification Planned Corrective Action: We have reviewed our Verification report and made the necessary adjustments to ensure that all of the correct information is included on each and every report. This will allow us to confirm that only those students who have completed all necessary paperwork fo...

Verification Planned Corrective Action: We have reviewed our Verification report and made the necessary adjustments to ensure that all of the correct information is included on each and every report. This will allow us to confirm that only those students who have completed all necessary paperwork for their particular Verification flag have been cleared to have Financial Aid disbursed to their account. The affected students had their Federal Aid removed and replaced with Eastern University aid. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 3/1/2023

View Audit 73872

Finding 64473 (2022-005)

None 2022

Eastern University

PA

Eligibility

Satisfactory Academic Progress Appeals Planned Corrective Action: This particular student mistakenly received a record that indicated that they had passed Satisfactory Academic Progress as well as failed passing Satisfactory Academic Progress. This issue has been fixed and the affected student had t...

Satisfactory Academic Progress Appeals Planned Corrective Action: This particular student mistakenly received a record that indicated that they had passed Satisfactory Academic Progress as well as failed passing Satisfactory Academic Progress. This issue has been fixed and the affected student had their Federal Aid removed and replaced with Eastern University aid. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 2/1/2023

View Audit 73872

Finding 64472 (2022-002)

Material Weakness 2022

Eastern University

PA

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and...

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and activity. We have already crafted a report that captures this information and we will continue to add to this report and utilize it for the current year to determine any adjustments that need to be made to Federal Student Aid. We are meeting again this week to discuss and finalize this report and test it out repeatedly to ensure it captures the right information every time. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023

View Audit 73872

Corrective Action Plans

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