Corrective Action Plans

Finding 42660 (2022-007)

Material Weakness 2022

Virginia Union University

VA

Questioned Costs

See corrective action plan for chart/table.

View Audit 53516 Questioned Costs: $1

Finding 42659 (2022-006)

Material Weakness 2022

Virginia Union University

VA

Reporting

See corrective action plan for chart/table.

View Audit 53516

Finding 42658 (2022-005)

Material Weakness 2022

Virginia Union University

VA

Student Financial Aid

See corrective action plan for chart/table.

View Audit 53516

Finding 42657 (2022-007)

Material Weakness 2022

Columbia Gorge Community College

OR

Cash Management Material Weakness

Finding 2022-007 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where t...

Finding 2022-007 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Responsible Individuals: Lorelle Davies, Chief Financial Office Corrective Action Plan: As the deadline neared for the end of the award period, The College initially drew the funds with a plan to make an expedited disbursement of the funds. Other Oregon Community Colleges shared with the College success in receiving extensions for the grants. The HEERF team then determined it would be more impactful to our community if we altered course and requested an extension to implement a more strategic plan. Upon the guidance of the Department of Education Grant Administrator, we promptly returned the funds to G5. Columbia Gorge Community College experience turnover in a large number of key positions and was not aware of the 15-day requirement. The grant agreement was on record, but was missing the terms of the withdrawal document. The Chief Financial Officer contacted the Department of Education by email to acknowledge error and provided an action plan with confirmation that funds were returned. We reviewed and assured that no interest was earned on the funds. Updated our G5 award to remove the previous CFO and reissue all grant terms. The grant team reviewed and assured that no interest was earned on the funds and continued compliance going forward. Since the return of the funds we have continued to communicate, implement, and rectify any and all grant issues. We will continue to seek out grant administrator guidance to prevent these issues in the future. Confirmation of account flag removed and resolution received March 28, 2022 Anticipated Completion Date: March 28, 2022

View Audit 52798

Finding 42656 (2022-001)

Material Weakness 2022

Corn Hill Housing Development Fund Corporation

NY

HUD Housing Programs Eligibility Reporting

2022-001: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing. However, this tenant file could not be located. As a result, the following documentation could not be located to determine eligibility, as required by the HUD regulations: ? Form HUD-50059, Owner?s Ce...

2022-001: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing. However, this tenant file could not be located. As a result, the following documentation could not be located to determine eligibility, as required by the HUD regulations: ? Form HUD-50059, Owner?s Certification of Compliance ? A completed and signed application ? The signed lease agreement ? The move-in and move-out inspection forms Recommendation: We recommend the Corporation establish procedures for maintaining tenant files to comply with HUD requirements for verification of tenant information, as required. Action Taken: Management agrees with the recommendation and will establish procedures with the managing agent to ensure all tenant files are maintained in accordance with HUD regulations.

View Audit 53271

Finding 42655 (2022-003)

Significant Deficiency 2022

City of Marysville, California

CA

Reporting

Finding 2022-003 ? Schedule of Expenditures of Federal Award (SEFA) ? Significant Deficiency All grants will be reviewed and each individual grant tracking summary will indicate source of grant, whether federal, state, or other, all assistance listing numbers will be added as needed and our master ...

Finding 2022-003 ? Schedule of Expenditures of Federal Award (SEFA) ? Significant Deficiency All grants will be reviewed and each individual grant tracking summary will indicate source of grant, whether federal, state, or other, all assistance listing numbers will be added as needed and our master grant tracking summary will be updated to include the source. When completing the SEFA, it will be prepared at the same time of the master grant tracking summary for comparison. We are also working on a grant policy and checklist that will allow for the collection of needed information and materials.

View Audit 52521

Finding 42654 (2022-002)

Material Weakness 2022

City of Marysville, California

CA

Equipment & Real Property Management

Finding 2022-002 ? Tracking of Equipment ? Material Weakness As the City works on conducting a full inventory, the equipment and real property on hand will be evaluated to assess if it was purchased or improved using federal funds. An additional section has been added to the master capital asset ...

Finding 2022-002 ? Tracking of Equipment ? Material Weakness As the City works on conducting a full inventory, the equipment and real property on hand will be evaluated to assess if it was purchased or improved using federal funds. An additional section has been added to the master capital asset workbook to indicate if acquired by federal funds. All assets will be reviewed during the preparation of the FY 22-23 audit and noted accordingly. These will also be compared to all grant tracking summaries to ensure that all assets are assessed and noted.

View Audit 52521

Finding 42653 (2022-001)

Significant Deficiency 2022

Beloit Assisted Living, Inc. Hud #075-Ee099-Wah

WI

HUD Housing Programs

Beloit Assisted Living, Inc. will review their policies and procedures surrounding required replacement for reserve deposits when the requirement is adjusted by HUD.

View Audit 52524

Finding 42652 (2022-001)

Significant Deficiency 2022

Halls Ferry Manor, INC

MO

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

Recommendation: We recommend the Project review controls to include timely review of year-end financials and surplus cash calculation so surplus cash is deposited timely.

View Audit 51388

Finding 42651 (2022-001)

Significant Deficiency 2022

Cabot Performing Arts Center, INC

MA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management has been making updates to its policies and procedures throughout 2022 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 51333

Finding 42649 (2022-002)

Material Weakness 2022

Centerburg Local School District

OH

Procurement, Suspension & Debarment § 200.320

Corrected during FY2022. In April 2022, ?approval for a noncompetitive proposal when procuring personnel-based services from a high-performing Educational Service Center? was received from ODE. Prior to this, cost comparisons from the KCESC were accepted as procurement documentation for audits, and ...

Corrected during FY2022. In April 2022, ?approval for a noncompetitive proposal when procuring personnel-based services from a high-performing Educational Service Center? was received from ODE. Prior to this, cost comparisons from the KCESC were accepted as procurement documentation for audits, and a cost comparison was provided for FY2022. A SAM search also has been completed for the KCESC for FY23. No quotes from competing vendors were available for the Bloom Pediatric Therapy contract as no other vendor could be found to provide the service. If this occurs again in the future, a log will be kept in this situation as documentation that no other vendors are available.

View Audit 51331

Finding 42648 (2022-004)

Significant Deficiency 2022

Isothermal Planning and Development Commission

NC

HUD Housing Programs Reporting Significant Deficiency

Finding: 22-04 Name of Contact Person: Charlotte Sullivan, Finance Director Corrective Action Plan: FRC has contracted with an independent CPA to complete the electronic filing of the 2021 and 2022 audited financial information to HUD. Proposed Completion Date: Immediately.

View Audit 50848

Finding 42647 (2022-002)

Material Weakness 2022

D H, Incorporated

OR

HUD Housing Programs Eligibility Material Weakness

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Finance Director/ShelterCare 2. The corrective action planned: a. Pinehurst Management is the management agent overseeing property through 4/30/202...

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Finance Director/ShelterCare 2. The corrective action planned: a. Pinehurst Management is the management agent overseeing property through 4/30/2023. A new management agent will be identified to take over the property after 4/30/2023. b. Ensure that the new managing agent employs an onsite manager with HUD compliance experience. c. Currently prioritizing recertifications by oldest first. d. Monthly review of TRACS reports to ensure recertifications are being completed in a timely manner. 3. The anticipated completion date: a. New processes will be implemented by 5/1/2023.

View Audit 50186

Finding 42646 (2022-001)

Material Weakness 2022

St. Mary's Residence, Inc.

MN

Internal Control / Segregation of Duties

2022-001 Audit adjustments Auditor Recommendation Recommendation: We recommend that the Organization verifies all necessary adjustments are made to the financial statements prior to the audit process. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disa...

2022-001 Audit adjustments Auditor Recommendation Recommendation: We recommend that the Organization verifies all necessary adjustments are made to the financial statements prior to the audit process. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Sara Wohlers (management agent) will establish a review process to ensure that all necessary adjustments are made to the financial statements prior to the audit process. 3. Official Responsible for Insuring CAP Sara Wohlers is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented for the September 30, 2023 audit. 5. Plan to Monitor Completion of CAP Julie Baruch (board chair) and Sara Wohlers will be monitoring this plan.

View Audit 49389

Finding 42642 (2022-003)

Material Weakness 2022

New Mexico Early Childhood Education and Care Department

NM

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.318

2022-003 Procurement, Suspension, and Debarment Recommendation: We recommend the program staff and ASD staff responsible for procuring contracts review federal compliance requirements to ensure appropriate language is included in all agreements. Explanation of disagreement with audit finding: The...

2022-003 Procurement, Suspension, and Debarment Recommendation: We recommend the program staff and ASD staff responsible for procuring contracts review federal compliance requirements to ensure appropriate language is included in all agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Agency?s Certified Procurement Officer (CPO) later verified that all agreements did contain the required ?Suspension and Debarment? language, it was too late to test in time to submit the audit on time. The various departments of ECECD will use this finding to ensure that designated ASD and Program staff fully understand the importance of providing complete and accurate information to the auditors. In addition, ECECD ASD will work toward improving communication regarding potential audit findings to the appropriate program staff, allowing for enough time to address the potential finding and possibly avoid a finding altogether. Name(s) of the contact person(s) responsible for corrective action: Michelle Montoya, Chief Procurement Officer; ECECD Program Managers; Ron Lucero, ASD Director; Thomas Montoya, Deputy ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer. Planned completion date for corrective action plan: June 30, 2023

View Audit 49019

Finding 42640 (2022-002)

Material Weakness 2022

New Mexico Early Childhood Education and Care Department

NM

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.331

2022-002 (Previously 2021-001) Subrecipient Monitoring U.S. Department of Health and Human Services Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.575/596 and 93.870 Recommendation: We recommend the Department implement ...

2022-002 (Previously 2021-001) Subrecipient Monitoring U.S. Department of Health and Human Services Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.575/596 and 93.870 Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure this does not occur again, the Family Support and Early Intervention Division (FSEI) Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FSEI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FSEI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. Name(s) of the contact person(s) responsible for corrective action: Mayra Gutierrez, FSEI Director; Johanna Kehoe, FSEI Deputy Director; Ron Lucero, ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer. Planned completion date for corrective action plan: June 30, 2023

View Audit 49019

Finding 42639 (2022-004)

Significant Deficiency 2022

New Mexico Early Childhood Education and Care Department

NM

Questioned Costs Allowable Costs / Cost Principles § 200.403 § 200.405

Significant Deficiency in Internal Control over Compliance and Other Matters 2022-004 Unallowable Costs U.S. Department of Health and Human Services Child Care and Development Fund Block Grant (CCDF) ? CRSSA (Coronavirus Response and Relieve Supplemental Act) Assistance Listing Numbers: 93.575 R...

Significant Deficiency in Internal Control over Compliance and Other Matters 2022-004 Unallowable Costs U.S. Department of Health and Human Services Child Care and Development Fund Block Grant (CCDF) ? CRSSA (Coronavirus Response and Relieve Supplemental Act) Assistance Listing Numbers: 93.575 Recommendation: We recommend the program work closely with ASD to ensure expenditures are tracked and mapped to the appropriate federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ECECD ASD Director, CFO and Grants Manager will work with the Federal Program Team to develop formal policies and procedures for grant management to ensure compliance with programmatic grant requirements and track expenditures to ensure costs charged to grants are allowable, necessary, and reasonable. Name(s) of the contact person(s) responsible for corrective action: Ron Lucero, ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer; Grants Manager (TBA); ECECD Program Managers. Planned completion date for corrective action plan: June 30, 2023

View Audit 49019 Questioned Costs: $1

Finding 42638 (2022-001)

Material Weakness 2022

Mighty Fortress Manor

MN

Internal Control / Segregation of Duties

2022-001 Audit adjustments Auditor Recommendation Recommendation: We recommend that the Organization verifies all necessary adjustments are made to the financial statements prior to the audit process. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disa...

2022-001 Audit adjustments Auditor Recommendation Recommendation: We recommend that the Organization verifies all necessary adjustments are made to the financial statements prior to the audit process. Corrective Action Plan (CAP) 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Sara Wohlers (management agent) will establish a review process to ensure that all necessary adjustments are made to the financial statements prior to the audit process. 3. Official Responsible for Insuring CAP Sara Wohlers is the official responsible for insuring corrective action of the deficiency. 4. Planned Completion Date for CAP This plan will be implemented for the September 30, 2023 audit. 5. Plan to Monitor Completion of CAP John Frank (board chair) and Sara Wohlers will be monitoring this plan.

View Audit 49018

Finding 42637 (2022-004)

Significant Deficiency 2022

Morrow County School District No. 1

OR

Reporting Subrecipient Monitoring Significant Deficiency

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below...

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below. US DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF)- Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Significant Deficiency #2022-004 Auditor Discussion and Recommendation: Condition and criteria: The District should have control processes in place to ensure that monitoring procedures are in place for large contracts. The District contracted work for the engineering and design of HVAC improvements. For 2 of 3 invoices, payments were made from summary invoices rather than from application and certification of payment. We also did not locate a specific contract for the project, just a proposal. When the application and certification of payments were received, there were errors and changes requiring final reconciliation and accruals. Cause: There were changes in personnel at the District during the year and the ESSER grant is fairly new to the District. In addition, the invoices from the contractor did not initially contain all of the required information. Context and effect: We reviewed 100% of the invoices for the project and $38,324 was accrued as a year end liability and additional expense when the final contractor billing was received. This affected both grant revenue and expenses and led to adjustments on the Schedule of Expenditures of Federal Awards (SEFA). Auditor?s recommendation: We recommend enhanced monitoring procedures for large contracts and that application and certification for payment be reviewed and approved by an official with knowledge of the project and status before payment is issued. We also recommend contracts containing language applicable to Federal programs be prepared for all large projects. Management?s Plan of Action: Individuals Involved: Matt Combe, Superintendent/Management Gabriel Hansen, Chief Financial Officer/Business Manager Brandi Sweeney, Maintenance Coordinator Plan: Management has assigned the Business manager review of contract request for payment prior to payment and also for the cutoff date for reporting. The Business manager will request from contractors any information needed to properly allocate payment to proper periods prior to payments being issued. Team meeting will be held to discuss the progress of projects for the district to keep all responsible properly informed. Time Frame: Re-establish payment procedures on contracts completed by January 3, 2023. Process of team meetings to discuss projects progress completed by January 3, 2023.

View Audit 49017

Finding 42636 (2022-003)

Material Weakness 2022

Morrow County School District No. 1

OR

Subrecipient Monitoring Material Weakness Equipment & Real Property Management

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below...

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below. US DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF)- Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Material Weakness #2022-003 Auditor Discussion and Recommendation: Condition and criteria: The District should have control processes in place to ensure that allowable projects subject to prevailing wage requirements are performed under those requirements. There was one project that was subject to Federal prevailing wage requirements but did not get performed or documented for those requirements. Cause: The District did not have policies and procedures set up to monitor the prevailing wage requirements. Context and effect: The District has few capital projects funded by grant dollars, but there was one project for security improvements that fell under Federal prevailing wage guidelines. The proposal from the contractor said it included prevailing wage rates, but there was not an official contract found that would detail the prevailing wage requirements and we were unable to locate copies of certified payrolls indicating the District was not monitoring this requirement. The total cost of the project was $133,878 and included costs for the equipment and installation of the security enhancements. Auditor?s recommendation: We recommend the District update their policies and procedures to identify and monitor projects with Federal prevailing wage requirements. We also recommend contracts containing language applicable to Federal programs be prepared for all large projects. Management?s Plan of Action: Individuals Involved: Matt Combe, Superintendent/Management Gabriel Hansen, Chief Financial Officer/Business Manager Brandi Sweeney, Maintenance Coordinator Plan: The district will include in contracts language requesting the proper documentation of compliance with prevailing wage on contract using Federal programs. To monitor this requirement the district will request from contractors prevailing wage certifications if they are not received timely. Time Frame: Implement in contracts language stating request for documentation of compliance with prevailing wage laws completed by January 3, 2023 Implement review of certified payroll documents and request from contractors when not received completed by January 3, 2023.

View Audit 49017

Finding 42635 (2022-006)

Material Weakness 2022

Chicot Memorial Medical Center

AR

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Finding 2022-06 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible expenses internally within a spreadsheet. The spreadsheet incl...

Finding 2022-06 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible expenses internally within a spreadsheet. The spreadsheet included errors in the calculation of allowable expenditures, which were included on the Period 1 report to the Health Resources and Services Administration (HRSA). Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track expenses are free of errors. Anticipated Completion Date: 3/31/2023

View Audit 47261

Finding 42634 (2022-005)

Material Weakness 2022

Chicot Memorial Medical Center

AR

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Finding 2022-05 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible patient care revenues internally within a spreadsheet. The rev...

Finding 2022-05 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible patient care revenues internally within a spreadsheet. The revenues included in the spreadsheet and on the Period 1 report to HRSA, which were utilized to calculate lost revenues, contained an error. Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track revenue are free of errors. Anticipated Completion Date: 3/31/2023

View Audit 47261

Finding 42633 (2022-001)

Significant Deficiency 2022

Quinnipiac University

CT

Student Financial Aid Matching / Level of Effort / Earmarking

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance pu...

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance purposes. The assignment process is currently underway and is required to be completed by June 30, 2023. The University is on track to meet that federal imposed deadline. Quinnipiac University agrees with the finding. A small percentage of the remaining loans to be assigned originated over 10 years ago. As it relates to this finding, we were unable to locate promissory notes for six students with loans originated 10 to 30 years ago. Due to their age, we believe the finding may be related to office moves and departmental reorganizations over the years. As a result of this finding and the federal assignment process in general, Management and Financial Aid have performed a comprehensive review of the remaining student records waiting to be assigned for completeness. As a result of this review Management and Financial Aid have identified all loans that are missing original promissory notes. As part of the assignment process, in lieu of original promissory notes alternative documents supporting the existence of these loans have been provided to the Perkins loan assignment processor. Any loans that are not accepted during this appeals process will be purchased by the University at the conclusion of the assignment process, which is planned to be completed by June 30, 2023. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 47260

Finding 42632 (2022-001)

Significant Deficiency 2022

Village Cooperative of Alexandria

MN

Internal Control / Segregation of Duties Significant Deficiency

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

View Audit 47257

Finding 42629 (2022-001)

Material Weakness 2022

Ivy Tech Community College of Indiana

IN

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements relate...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

View Audit 43389

Corrective Action Plans

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