Corrective Action Plans

Finding 24120 (2022-009)

Material Weakness 2022

PR

Questioned Costs Procurement, Suspension & Debarment § 200.212 § 200.214 § 200.303 § 200.317 § 200.318

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 ...

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

View Audit 20027 Questioned Costs: $1

Finding 24119 (2022-008)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.334

Compliance requirement ? Earmarking Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because all initiatives and expenditures related to the HEERF funds were precisely and strictly used to monitor, suppress the COVID-19 emergency and...

Compliance requirement ? Earmarking Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because all initiatives and expenditures related to the HEERF funds were precisely and strictly used to monitor, suppress the COVID-19 emergency and additionally to outreach students about the opportunity to receive financial aid, (and they indeed received) due to recent unemployment and financial hardship during the pandemic times. Part of this initiatives were documented in our web page and disseminated through e-mails, phone calls, word of mouth among the community. The institution followed the recommended state and federal government guidelines on maintaining an active program to prevent and respond to the COVID-19 emergency. The institution uses HEERF funds to establish and maintain the following preventive and suppressing measures to fight the COVID-19 emergency, among others: a. Screening temperature b. Purchase covid test kits c. Created and posted many warning banners and instructions d. Purchase prevention and protection supplies for students, faculty, visitor and staff a. Hand sanitizer b. Alcohol auto sprayers c. Face Shields d. Thermometers e. Protective plastic shields for the desks e. Implemented remote education a. Habilitated smart educational rooms for remote education i. Smart TV's ii. High quality microphones iii. Acquired "Zoom" platform licenses iv. Laptops for remote education f. Provided student financial aid to support recent unemployment g. Provided counseling and psychology services to assist students to deal and recover from the emergency. h. Supported a clean and sanitary campus environment with hand sanitizers, handwashing stations, cleaning and disinfection. i. Implemented physical distance j. Keep continued communication with students k. Paid for time off to get vaccinated l. Provided sick leave for COVID treatment and to get vaccinated m. Procured additional space for remote education n. Support costs associated with remote education for students providing laptops and remote communication equipment and hardware Actions Taken or Planned: The institution understands that no further action is necessary or required.

View Audit 20027

Finding 24117 (2022-006)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Equipment & Real Property Management § 200.302 § 200.303 § 200.334 § 200.337 § 200.400

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the...

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

View Audit 20027

Finding 24115 (2022-010)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual rep...

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual reports. Since the institution used the reimbursement method, the drawdown were the actual expenditures/costs incurred and requested for reimbursement. The HEERF reporting requirement does not make any indication nor reference to GAAP. The Institutional aid portion expenditures were supported by the proper invoice or check. The evidence was available to the auditors. 2. The institution concurs with the auditor finding. The institution inadvertently, did not include a line item from one of the quarterly reports. The period to make corrections was closed and we sent an e-mail to the department to amend this annual report. 3. The institution concurs with the auditor finding. The annual report contains detail statistical information that not necessarily is supported by our institutions data base and programs. As the ED expressed, this information was unique and challenging, and accordingly, the institution made some reasonable estimates and derivatives in the information provided. As you may notice in the referenced table by the auditor, the differences were minimal. 4. a. The institution concurs with the auditor finding on the difference in Item #5 of the quarterly report. The institution will accordingly amend the report. b. The institution does not concur with the auditor finding on the timely and accurate reporting in publicly posting the quarterly Student Aid Portion. The four quarterly reports were timely submitted with an e-mail to the HEERF reporting staff and timely posted in the institution web page as required by the HEERF reporting instructions. The reports were further reviewed by an officer of the Department of Education (ED). The ED expressed that this information may be unique and challenging to an audit, and indicated that for these public reporting requirements, the auditors may accept as evidence of compliance, contemporarily produced e-mails, webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements. Copy of the e-mails were available to the auditors as evidence of compliance. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information - All HEERF Grantees). 5. The institution does not concur with the auditor finding because the referenced payment was made in accordance with the Institution's fund distribution and the student financial needs, among other factors, at the time of the evaluation and distribution of the funds. The student financial circumstances may have change after the distribution and payments of the financial aid. Additionally, this is an immaterial amount as compare to the total amount of the funds distributed ant the quantity of students served (1 out of 460). Actions Taken or Planned: The institution understands that no further is needed or required.

View Audit 20027

Finding 24114 (2022-007)

Significant Deficiency 2022

Universidad Teologica Del Caribe, Inc.

PR

Cash Management § 200.302 § 200.303 § 200.305

Compliance requirement ? Cash Management Institutional Comments on Findings and Recommendations: 1. The institution does concur with the auditor finding. The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time. Actions Taken or Plan...

Compliance requirement ? Cash Management Institutional Comments on Findings and Recommendations: 1. The institution does concur with the auditor finding. The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time. Actions Taken or Planned: The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time.

View Audit 20027

Finding 24113 (2022-002)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.302 § 200.303 § 200.305 § 200.317 § 200.318

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance...

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

View Audit 20027

Finding 24108 (2022-005)

Significant Deficiency 2022

Universidad Teologica Del Caribe, Inc.

PR

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

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specifie...

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specified in a formal written contract, therefore, the consultant does not have a detail for the functions and responsibilities of his designation. (b) The institution agrees with the auditor on this finding. The Institution has yet to comply with, needs to terminate and correct some of the nine elements that are included in the FTC (Federal Trade Commission). Actions Taken or Planned: 1. A contract with the IT Program Coordinator is being finished with a breakdown of the responsibilities expected for the GLBA requirements. We should be starting it in May 2023. 2. There has been progress in the action plan where a set of estimated time of completion is provided. We will keep doing so and monitor every aspect of the risk assessment to cover and safeguard each area found with a document that indicates any advances. 3. The Institution with the IT Coordinator will keep monitoring each step for the progress and any delay with a task report where it will show any advance or delay for the pending findings so that we can track the development closely until finished. 4. Finally, we will continue with the efforts to document and complete the corrections to the risk assessment results.

View Audit 20027

Finding 24107 (2022-004)

Significant Deficiency 2022

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Special Tests & Provisions Eligibility

Compliance requirement - Special tests and provisions ? Enrollment Reporting Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding in that there was one (1) case where the information of enrollment of this student was not available for ex...

Compliance requirement - Special tests and provisions ? Enrollment Reporting Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding in that there was one (1) case where the information of enrollment of this student was not available for examination. After multiples student search, the institution was unable to locate through the NSLDS the reported status update for said student. (b) The institution also agrees with the auditor in that there were (6) six cases where he noted that institution failed to report the student's status before the thirty (30) day deadline for the NSLDS web reporting. (c) The institution also agrees with the auditor in that there was one (1) instance where the institution submitted one (1) of its's enrollment report updates after the 15 days required timeline. Actions Taken or Planned: The institution would continue to submit its Enrollment Reports monthly in order to notify changes of student status to the Department of Education on a timely basis and to maintain the information of student's enrollment status more effectively.

View Audit 20027

Finding 24106 (2022-003)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Subrecipient Monitoring Procurement, Suspension & Debarment

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) ...

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within 14 days after the student's last day of attendance. II. Compliance Requirements ? Applicable for a student who does not begin attendance: b. The Institution agrees with the auditors on this finding in which there was one (1) case were the student did not comply with the Incomplete course requirement and an unofficial withdrawal was not performed. Before the audit process was completed, the institution performed a R2T4 calculation and returned to the US Department of Education, the $439.00 associated with this finding. This process was evidenced to the auditors for their records. c. The Institution agrees with the auditors on this finding in which there was one (1) case were the student had stopped attending the enrolled courses without completing at least 60% of the payment period. Before the audit process was completed, the institution had returned to the US Department of Education, the $581.00 associated with this finding. This process was evidenced to the auditors for their records. d. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to determine that the students withdrew within 14 days after the student's last day of attendance. e. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to return Title IV funds after the 45 days' time frame. Actions Taken or Planned: The institution is aware of the importance to comply with Return of Title IV funds (R2T4) reporting requirements and deadlines. Also, the relation to students last day of attendance (date of withdrawal) vs date of school's determination that the students withdrew and the date of the return of any Title IV funds resulting from an R2T4 calculation. The issues as related to these findings were identified as ones being an oversight and lack in compliance with some of the academic processes as required by R2T4 and has already been discussed with the Academic Dean of the institution who in turn has revisited these matters with Faculty and administrative staff under her supervision including the Registrar. The already instituted task force that meets every Friday of each week to identify and review cases that could affect the R2T4 procedure and requirement has continued to review and evaluate information received from the faculty through the Academic Dean and from information the Registrar's office receives of students that are not attending classes in order to process all applicable withdrawals to assure that the return of Title IV funds procedures and the return of funds if any, are processed timely within the 14 days requirement of the student's last day of attendance and within the 45 days from the date that the institution determined that the student withdrew. Before the audit process was completed, the institution had returned to the US Department of Education, the $439.00 and $581.00 associated with this finding. This process was evidenced to the auditors for their records.

View Audit 20027

Finding 24105 (2022-001)

Significant Deficiency 2022

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility § 200.303

Compliance requirement ? Other ? Policies and Procedures requirements. Institutional Comments on Findings and Recommendations: 1 The institution agrees with the auditors on this finding in which the current University Catalog containing the updated general disclosures for enrolled or prospective st...

Compliance requirement ? Other ? Policies and Procedures requirements. Institutional Comments on Findings and Recommendations: 1 The institution agrees with the auditors on this finding in which the current University Catalog containing the updated general disclosures for enrolled or prospective students were not updated on time for the fiscal year. 2 The institution agrees with the auditors on this finding in which the Drug and Alcohol Abuse Prevention Program did not fully comply with the distribution requirement in writing for each student. It also agrees that the institution did not perform a recent biennial review of its Drug and Alcohol Abuse Prevention Program. Actions Taken or Planned: The institution has already updated, published, and distributed its Catalog to accurately represent the vision and goals, our academic offerings and administrative policies and procedures of our operation. As related to the institutions Drug and Alcohol Abuse Prevention Program, the same was also updated, revised, published, and distributed to all active students and staff. The updated Drug and Alcohol Abuse Prevention Program is also available for distribution for all prospective students and any potential employees through the Admissions and Human Resources offices respectively. The same would also be posted on the Web page of the institution. Evidence of both issues were submitted to the auditors.

View Audit 20027

Finding 24104 (2022-001)

Significant Deficiency 2022

San Joaquin Health Centers

CA

Special Tests & Provisions Subrecipient Monitoring Cash Management

The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide on-going training to clinic staff who evaluate the sliding fee application ...

The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide on-going training to clinic staff who evaluate the sliding fee application at its clinic locations. The training consists of reviewing sliding fee program policies and procedures along with all applicable patient forms, sliding fee scale, and patient eligibility. The following quality control measures to ensure compliance will be implemented: 1. Front Desk Peer Review of sliding fee application and verification of patient income and family size. 2. Enhance training materials to support Front Desk Staff with assessing sliding fee applications. 3. Quarterly feedback to Front Desk Staff based on sliding fee applications reviewed. Person Responsible: Kristopher D. Zuniga Position of Responsible Party: Chief Financial Officer Anticipated Completion: April 30, 2023

View Audit 19923

Finding 24103 (2022-001)

None 2022

Alabama Technology Network

AL

Subrecipient Monitoring Reporting

Corrective Action Plan Manufacturing Extension Partnership Year-Ended September 30, 2022 Finding #2022-001: Type of Finding: Noncompliance Responsible Person Joey Massey, Director of MEP Implementation Date January 30, 2023 Views of responsible officials and planned corrective actions: ATN ...

Corrective Action Plan Manufacturing Extension Partnership Year-Ended September 30, 2022 Finding #2022-001: Type of Finding: Noncompliance Responsible Person Joey Massey, Director of MEP Implementation Date January 30, 2023 Views of responsible officials and planned corrective actions: ATN agrees with the finding and recommendation. As a result, ATN immediately submitted the FY22 Federal Funding Accountability and Transparency Act (FFATA) subawards in the FFATA sub-award reporting system (FSRS). Furthermore, ATN will implement procedures to ensure subawards will be reported in the FSRS system on a timely basis as required hereafter.

View Audit 21132

Finding 24100 (2022-002)

Material Weakness 2022

City of Fairburn, Georgia

GA

Procurement, Suspension & Debarment

2022-002 Procurement, Suspension, and Debarment Name of the Contact Person Responsible for the Corrective Action Plan: Bryan Stephens, Finance Director. Corrective Action Plan: The City will ensure all contactors of federal funds are not suspended or debarred in accordance with federal guidelines,...

2022-002 Procurement, Suspension, and Debarment Name of the Contact Person Responsible for the Corrective Action Plan: Bryan Stephens, Finance Director. Corrective Action Plan: The City will ensure all contactors of federal funds are not suspended or debarred in accordance with federal guidelines, including adding a clause to federal contracts. Anticipated Completion Date: September 30, 2023.

View Audit 21080

Finding 24099 (2022-002)

Significant Deficiency 2022

Embry-Riddle Aeronautical University

FL

Procurement, Suspension & Debarment § 200.303

Finding: 2022-002 Federal Program: Education Stabilization Fund (ALN 84.425F) Name(s) of the contact person(s) responsible for the corrective action: Jare Allocco Allen, Controller David Drews, Associate Controller Misty Clark, Director of Accounting View of Responsible Officials: The Controller...

Finding: 2022-002 Federal Program: Education Stabilization Fund (ALN 84.425F) Name(s) of the contact person(s) responsible for the corrective action: Jare Allocco Allen, Controller David Drews, Associate Controller Misty Clark, Director of Accounting View of Responsible Officials: The Controller?s Office will implement an additional internal control for this compliance requirement. In addition to Procurement?s verification and documentation, Accounting will also perform a verification of the written evidence of the suspension and debarment review.

View Audit 20951

Finding 24098 (2022-001)

Significant Deficiency 2022

Embry-Riddle Aeronautical University

FL

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

Finding: 2022-001 Federal Program: Disbursements to or on Behalf of Students Name(s) of the contact person(s) responsible for the corrective action: Vandeen McKenzie, Executive Director Financial Aid John Hanson, Director of Financial Aid, Prescott Karen Williams, Director of Financial Aid Opera...

Finding: 2022-001 Federal Program: Disbursements to or on Behalf of Students Name(s) of the contact person(s) responsible for the corrective action: Vandeen McKenzie, Executive Director Financial Aid John Hanson, Director of Financial Aid, Prescott Karen Williams, Director of Financial Aid Operations Santonio McPhee, Associate Director of Financial Aid Operations View of Responsible Officials: Financial Aid management will establish a control check to monitor that student disbursement notices are being sent within the required timeframe. The control check is comprised of a report generated directly from the University?s student information system and a manual review of the output to confirm notices are being sent. This review will be completed at the start of the new aid year and monthly thereafter.

View Audit 20951

Finding 24094 (2022-001)

Significant Deficiency 2022

Easter Seals Rio Grande Valley

TX

Procurement, Suspension & Debarment

Recommendation: We recommend the Organization implement policies and procedures to ensure a search for Suspension and Debarment is completed before entering into contracts in order to follow compliance requirements. Corrective Action Plan ? In response to the finding listed above, Easter Seals Rio ...

Recommendation: We recommend the Organization implement policies and procedures to ensure a search for Suspension and Debarment is completed before entering into contracts in order to follow compliance requirements. Corrective Action Plan ? In response to the finding listed above, Easter Seals Rio Grande Valley has written a policy #400 "Debarment and Suspension". The policy expands the parameters from the current practice of completing the search for all direct service providers, to completing the search for any contracted service in the amount of $25,000 or greater, in order to comply with federal grant requirements. Easter Seals RGV will conduct a search prior to entering into a contract to ensure that the contracting organization or entity is not debarred or suspended from doing business with the government. Proposed Completion Date ? March 21, 2023 Contact Person - David H. Elizondo, CFO

View Audit 20913

Finding 24093 (2022-001)

None 2022

International Social Service United States of America Branch, Inc.

MD

Reporting

Federal Award Findings and Questioned Costs Finding 2022-001: Reporting Federal Program: Repatriation Program Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.579 Vi...

Federal Award Findings and Questioned Costs Finding 2022-001: Reporting Federal Program: Repatriation Program Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.579 Views of Responsible Officials and Planned Corrective Actions: ISS-USA agrees with the recommendations and will enhance procedures to ensure all amounts reported reconcile with the financial accounting information.

View Audit 20785

Finding 24089 (2022-004)

Material Weakness 2022

Easter Seals Serving Dc/md/va

MD

Matching / Level of Effort / Earmarking

Based on our grant agreement with Head Start, Easter Seals DC MD VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to mee...

Based on our grant agreement with Head Start, Easter Seals DC MD VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to meet the matching requirement. As noted in the audit report, our organization did not meet the 20% non-federal match requirement for the latest program year. Our inability to meet the 20% threshold in fiscal year 2022 was, in part, due to a lack of volunteering activity associated with limited operations/required closures of our Head Start locations throughout the COVID pandemic. The mandatory annual waivers associated with our organization?s 20% non-federal share matching contribution requirement for the first four years (ended July 31, 2019, 2020, 2021, and 2022) of our Prince George?s County Head Start Program grant agreement were submitted by the end of the organization?s Fiscal Year 2022. Likewise, the annual waver for the first year (ended June 2022) for our Washington, DC Head Start Program grant agreement was also submitted by the end of Fiscal Year 2022. The outstanding waiver requests are currently under review by representatives of The Administration of Families and Children, the agency that oversees the Office of Head Start program. While we have maintained a constant dialogue with the Office of Head Start over the last several months, which administers grant funding and oversight, we have yet to receive a formal approval for any of the individual submissions. We are hopeful that response to all five waiver requests submitted will be obtained no later than the end of the current grant year for our Prince George?s County Program (July 31, 2023).

View Audit 20775

Finding 24087 (2022-006)

Significant Deficiency 2022

Pacific Islands Bible College

GU

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Anticipated Completion Date: Ma...

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750

Finding 24086 (2022-005)

Significant Deficiency 2022

Pacific Islands Bible College

GU

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

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement procedures to improve its knowledge of special test and provisions required for the federal programs under the SFA cluster. PIU will coordinate with its vendor, FA So...

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement procedures to improve its knowledge of special test and provisions required for the federal programs under the SFA cluster. PIU will coordinate with its vendor, FA Solutions, to improve on its knowledge on this item since they are the vendor that processes all financial aid for PIU. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750

Finding 24077 (2022-007)

Significant Deficiency 2022

Pacific Islands Bible College

GU

Special Tests & Provisions Student Financial Aid

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Anticipated Completion Date:...

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750

Finding 24076 (2022-004)

Significant Deficiency 2022

Pacific Islands Bible College

GU

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Area: Reporting Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement review controls over reports required to be submitted for the programs under the SFA cluster. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue,...

Area: Reporting Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement review controls over reports required to be submitted for the programs under the SFA cluster. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750

Finding 24075 (2022-003)

Material Weakness 2022

Pacific Islands Bible College

GU

Questioned Costs Cash Management Student Financial Aid

Area: Cash Management Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will review the requirements of the Uniform Guidance and understand the cash management principal requirements. Once this is done, PIU will implement procedures and update the Business Office Ma...

Area: Cash Management Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will review the requirements of the Uniform Guidance and understand the cash management principal requirements. Once this is done, PIU will implement procedures and update the Business Office Manual. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750 Questioned Costs: $1

Finding 24073 (2022-002)

Significant Deficiency 2022

West Contra Costa Unified School District

CA

Allowable Costs / Cost Principles

Below is the corrective action plan for the federal compliance audit finding from our 21-22 financial audit report. FINDING #2022-002: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CORRECTIVE ACTION Staff were trained on timekeeping policies and procedures in the summer of 2022. The Director of State ...

Below is the corrective action plan for the federal compliance audit finding from our 21-22 financial audit report. FINDING #2022-002: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CORRECTIVE ACTION Staff were trained on timekeeping policies and procedures in the summer of 2022. The Director of State and Federal programs created the PowerPoint Presentation and presented it to staff. Additionally, the district?s website was updated to include the training presentation, training video, sample semi-annual and monthly forms, duty statements, work assignments, and frequently asked questions. The district expects to be in compliance with federal timekeeping requirements for the next audit cycle.

View Audit 20634

Finding 24072 (2022-001)

Significant Deficiency 2022

Paragon Management, Inc., D.b.a. Paradise Schools

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2022-001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: David Friedman Anticipated Completion Date: November 15, 2022 Planned Corrective Action: Paradise Schools? finance director will update its ?Purchasing Pro...

Finding Number: 2022-001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: David Friedman Anticipated Completion Date: November 15, 2022 Planned Corrective Action: Paradise Schools? finance director will update its ?Purchasing Procedures? manual, to ensure that the School will be in conformance with the Davis-Bacon Act. These procedures will include how to determine whether all laborers and mechanics employed by contractors or subcontractors, who work on construction contracts in excess of $2,000 financed by federal assistance funds, are paid wages not less than those established for the locality of the project (prevailing wage rates), as established by the United States Department of Labor. These updated procedures will be communicated by November 15, 2022, and annually by July 15, to the School?s federal grants coordinator and district business office employees. In addition, these updated procedures will be included annually in the School's Employee Handbook. In addition, Paradise Schools is considering participation in a governmental purchasing cooperative. One of the determining factors will be whether or not approved vendors in the cooperative are in compliance with the Davis-Bacon Act.

View Audit 20466

Corrective Action Plans

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