Corrective Action Plans

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The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both docum...
The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both documents have since been provided to Iowa Workforce Development to demonstrate compliance with WIOA and Uniform Guidance, Part 200.332.
The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provide...
The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provided to Iowa Workforce Development (IWD) and AOS Senior Auditor Tristan Swiggum.
The ECIWDB acknowledges the merit of this recommendation and commits to taking the following action: The establishment of a procedure that incorporates the utilization of an “Orientation Acknowledgement Form’ to demonstrate completion by each individual participant. This procedural change shall be i...
The ECIWDB acknowledges the merit of this recommendation and commits to taking the following action: The establishment of a procedure that incorporates the utilization of an “Orientation Acknowledgement Form’ to demonstrate completion by each individual participant. This procedural change shall be implemented on or about November 1, 2025.
The ECIWDB acknowledges this deficiency and commits to taking the following corrective action: Documented establishment of a procedure that will allow for the Executive Director to approve payments in real time, with subsequent affirmation by the Finance Committee at their monthly meetings. This pro...
The ECIWDB acknowledges this deficiency and commits to taking the following corrective action: Documented establishment of a procedure that will allow for the Executive Director to approve payments in real time, with subsequent affirmation by the Finance Committee at their monthly meetings. This procedural change shall be implemented on or about November 1, 2025.
Coronavirus State & Local Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. Explanation of ...
Coronavirus State & Local Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College verified the status of all vendors utilized in federal grant disbursements during the year ended June 30, 2025. A spreadsheet was maintained during that year which documented this. Since June 30, 2025, a procedure has been added to retain copies of the sam.gov verifications for additional documentation. Name(s) of the contact person(s) responsible for corrective action: Susan Spencer, Vice President for Finance Planned completion date for corrective action plan: Completed March 2026 If the United States Department of Treasury has questions regarding this plan, please call Susan Spencer at 660-263-4100, ext. 11274.
2. 2025-003 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. P...
2. 2025-003 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. Policies must be reviewed regularly for compliance. ii. Actions Taken or Planned: Management will ensure continuous fidelity bond coverage and verify that policies remain compliant with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 09/30/2026  Steps to Implement: Review of existing controls and implementation of new procedures to ensure continuous fidelity bond coverage, including timely renewal and periodic verification that coverage meets HUD requirements.
1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requiremen...
1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requirements consistently throughout the year. ii. Actions Taken or Planned: Insurance coverage will be reviewed and monitored to ensure that an active policy is maintained and that coverage amounts comply with HUD requirements.  Responsible Person: Jill Cromartie  Completion Date: 12/10/2024  Steps to Implement: Review of existing controls and implementation of new procedures to ensure timely premium payments and prevent future lapses in required insurance coverage.
3. 2025-004 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. P...
3. 2025-004 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. Policies must be reviewed regularly for compliance. ii. Actions Taken or Planned: Management will ensure continuous fidelity bond coverage and verify that policies remain compliant with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 9/30/2026  Steps to Implement: Review of existing controls and implementation of new procedures to ensure continuous fidelity bond coverage, including timely renewal and periodic verification that coverage meets HUD requirements.
2. 2025-003 i. Comments on Finding: Payments were made for non-project expenses, resulting in noncompliance with HUD requirements. Management should review vendor payment procedures to ensure only Project expenses are paid. ii. Actions Taken or Planned: Payments to vendors will be reviewed to ensure...
2. 2025-003 i. Comments on Finding: Payments were made for non-project expenses, resulting in noncompliance with HUD requirements. Management should review vendor payment procedures to ensure only Project expenses are paid. ii. Actions Taken or Planned: Payments to vendors will be reviewed to ensure they relate to Project expenses and comply with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 9/30/2026  Steps to Implement: Review of old controls or the implementation of new controls to avoid future noncompliance with HUD
1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requiremen...
1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requirements consistently throughout the year. ii. Actions Taken or Planned: Insurance coverage will be reviewed and monitored to ensure that an active policy is maintained and that coverage amounts comply with HUD requirements.  Responsible Person: Jill Cromartie  Completion Date: 11/12/2025  Steps to Implement: Review of existing controls and implementation of new procedures to ensure timely premium payments and prevent future lapses in required insurance coverage.
Management has developed a written information security program to comply with the FTC Safeguards Rule. The program documents administrative, technical, and physical safeguards designed to protect customer information and assigns responsibility for oversight and monitoring.
Management has developed a written information security program to comply with the FTC Safeguards Rule. The program documents administrative, technical, and physical safeguards designed to protect customer information and assigns responsibility for oversight and monitoring.
Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions....
Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions. Automation of enrollment reporting is expected upon implementation of the new SIS.
Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented s...
Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented supervisory review and retention of reconciliation evidence.
Management has implemented additional review procedures over Pell Grant calculations, including documented manual recalculations and supervisory approval prior to disbursement. These controls will remain in place until Pell calculations are automated through the planned SIS implementation.
Management has implemented additional review procedures over Pell Grant calculations, including documented manual recalculations and supervisory approval prior to disbursement. These controls will remain in place until Pell calculations are automated through the planned SIS implementation.
A material weakness in internal controls was noted due to the lack of segregaton of duties for revenue. B-Y Water District's General Manager Terry Wootton is the contact person for the corrective action plan for this finding. Due to the population served by B-Y Water District and the limited resourc...
A material weakness in internal controls was noted due to the lack of segregaton of duties for revenue. B-Y Water District's General Manager Terry Wootton is the contact person for the corrective action plan for this finding. Due to the population served by B-Y Water District and the limited resources available to compensate employees and the fiscal responsible nature, B-Y Water District can't justify hiring the additional staff that would be necessary to properly segregate duties. The General Manager, B-Y Water District Board of Directors and B-Y Water District Bookkeeper are aware of the issue. B-Y Water District has put in place policies and is actively working on additional policies that will put controls in place that will safeguard the District's revenue and minimize any future risk. This process will be an ongoing process that will include input from numerous agencies that will ensure B-Y Water District's financial controls are at a very secure level.
The Department acknowledges the recommendation and agrees that maintaining secure and accurate documentation of beneficiary eligibility is important for program integrity and compliance. At this time, the Program is operating in accordance with the guidance provided by the federal grantor and is uti...
The Department acknowledges the recommendation and agrees that maintaining secure and accurate documentation of beneficiary eligibility is important for program integrity and compliance. At this time, the Program is operating in accordance with the guidance provided by the federal grantor and is utilizing the resources and systems currently available to the agency. Action planned/taken in response to finding: The Department has identified resource gaps affecting grant compliance and has engaged with the federal grantor to present these findings and request additional resources, including access to tools for verifying veteran appointments. The Department recognizes the importance of maintaining secure and accurate documentation to confirm eligibility for veteran benefits and will continue to work with the grantor to secure the necessary resources to support auditable appointment verification and ensure full compliance with program requirements. Name(s) of the contact person(s) responsible for corrective action: Danelle Lucero, CFO/ Jamison A. Herrera, Cabinet Secretary, and the HealthCare Director that manages oversight of the program. Planned completion date for corrective action plan: The Chief Financial Officer, ASD staff, and Federal Grant Director will collaborate with the federal grantor to secure additional resources necessary to address the audit recommendations for the next grant period beginning Sept.15, 2026
Finding 2025-003 Name of Responsible Individual: Angelo Chrisomalis, Sr. Director Grants and Contracts Corrective Action: Due to a change that occurred after the reporting period appropriately reallocating one employee’s effort to the federal funding source, the certification was not displayed on th...
Finding 2025-003 Name of Responsible Individual: Angelo Chrisomalis, Sr. Director Grants and Contracts Corrective Action: Due to a change that occurred after the reporting period appropriately reallocating one employee’s effort to the federal funding source, the certification was not displayed on the effort report. The employee has certified that this effort was charged appropriately to this award. We are reviewing our policies and procedures to ensure redistribution of labor is performed within a timely manner. We have moved to an annual effort reporting process aligned to the federal regulations and are implementing the Cayuse Effort Reporting module that will more effectively track and report effort. The system will be implemented during our next effort reporting cycle. Anticipated Completion Date: March 1, 2026
Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this n...
Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution. Anticipated Completion Date: March 1, 2026
Finding 2025-002 Name of Responsible Individual: Demetrius Carmichael, AVP Controller Corrective Action: There was an adjustment to a student’s account resulting in funds required to be returned to the ED. The adjustment amount was drawn down in error. Once the error was identified, the funds were r...
Finding 2025-002 Name of Responsible Individual: Demetrius Carmichael, AVP Controller Corrective Action: There was an adjustment to a student’s account resulting in funds required to be returned to the ED. The adjustment amount was drawn down in error. Once the error was identified, the funds were returned to the ED prior to the end of the award year/fiscal year. We are implementing a second review of awards that result in adjustments, cancellation, or recovery requiring return to the DOE to ensure funds are returned within a timely manner. In addition to this review, we are instituting a weekly report that will identify timing of funds drawn and returned to ensure adherence to this requirement within 7 calendar days. Anticipated Completion Date: March 1, 2026
Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the ...
Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the Office of the Dean will provide joint oversight with the Office of Student Affairs on matters impacting regulatory requirements. Specifically, there will be a monthly review of the NSLDS database on the second Monday of each month with a regular tracking system. The Registrar, Associate Dean of Students and Dean’s Office representative will provide quarterly “audits” to the Dean on accuracy of data and reporting compliance. Annual NSLDS training, appropriate to the role, will be provided for all team members in the Registrar's Office and others as appropriate. Anticipated Completion Date: March 31, 2026
In Finding 2025-001, a condition was noted that a majority of the board members or their immediate family are not users of the health center services. Compliance conditions state that more than fifty percent of board members should “utilize the health center as their principal source of primary heal...
In Finding 2025-001, a condition was noted that a majority of the board members or their immediate family are not users of the health center services. Compliance conditions state that more than fifty percent of board members should “utilize the health center as their principal source of primary health care” in order for them to give substantive input into the Organization’s strategic direction and policy. Management recognizes the importance of complying with board member compliance guidelines. In response to Finding 2025-001, procedures will be established to ensure that more than 50 percent of the board members are users of the health center.
The University acknowledges the finding and affirms its commitment to full compliance with federal enrollment reporting requirements.Following the prior-year finding, management implemented enhanced internal controls, including:Peer review of enrollment status reports prior to submission.Reconciliat...
The University acknowledges the finding and affirms its commitment to full compliance with federal enrollment reporting requirements.Following the prior-year finding, management implemented enhanced internal controls, including:Peer review of enrollment status reports prior to submission.Reconciliation of student status lists between the Registrar's Office and Financial Aid Office.Monitoring of submission confirmations to ensure successful transmission to NSLDS.Despite these controls, a programming error within the Student Information System (SIS) caused enrollment status change dates to become corrupted during the electronic transmission process from the SIS to the National Student Clearinghouse and subsequently to NSLDS. As a result, certain reported dates did not accurately reflect the actual effective date of the student's enrollment change. The issue was technical in nature and not the result of failure to perform the reporting process.
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prev...
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prevent recurrence, management will monitor all parties, issue email reminders with clear deadlines, and enforce timely processing to ensure compliance with the 30-day requirement. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026
Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200. Additionally, controls were not sufficient to ensure checks for suspension and debarment were documented before entering into covered transactions with third-parties....
Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200. Additionally, controls were not sufficient to ensure checks for suspension and debarment were documented before entering into covered transactions with third-parties. Planned Corrective Action: Management will continue to strengthen internal controls through the revised Procurement Policy, enhanced documentation requirements, and clarified approval procedures. A centralized tracking database has been implemented to document sanctions, suspension, and debarment checks, as well as other required verifications based on the nature of each purchase or service. These procedures are required prior to entering into covered transactions and are monitored through dual staff reviews. Management believes that ongoing monitoring and consistent enforcement of these procedures will ensure compliance and prevent recurrence. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026
2025-004 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Take...
2025-004 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board will evaluate existing review and approval processes for federal program charges and implement appropriate controls to ensure all expenditures are thoroughly reviewed, properly authorized, and fully supported before payment is made. As part of the review of charges, a daily review of invoices will be implemented to ensure that all invoices coded to WIOA are allowable costs. The Board’s allowable costs are reviewed by three members: Fiscal Coordinator, Fiscal Manager and Executive Director. These are reviewed and approved by each before the costs are paid. Evidence of these allowable costs will have reviewer’s initials and date reviewed on the bills/invoices themselves and a checklist with signatures that they have reviewed these.
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