Corrective Action Plans

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Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review an...
Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Registrar Liz Force Planned Corrective Action: The Registrar will update NSLDS reporting processes and controls to include detection controls to ensure all student graduations, including those occurring outside the traditional reporting window, are accurately and timely reported to the NSLDS within the maximum 60-day window. Anticipated Completion Date: December 31, 2025
Malama Honua Public Charter School Foundation (“MHPCS Foundation”) acknowledges the observation noted by the auditors regarding the timing of the advance drawdown received on February 7, 2025 and the subsequent disbursement on April 29, 2025. As described in the audit finding, the funds remained on ...
Malama Honua Public Charter School Foundation (“MHPCS Foundation”) acknowledges the observation noted by the auditors regarding the timing of the advance drawdown received on February 7, 2025 and the subsequent disbursement on April 29, 2025. As described in the audit finding, the funds remained on hand for approximately 81 days prior to disbursement, which exceeds the expectation under 2 CFR §200.305(b) that non-Federal entities minimize the time between the transfer of federal funds and their disbursement. Management notes that the timing of the disbursement occurred during a period of heightened uncertainty related to federal appropriations and funding continuity. During 2024 and early 2025, the federal government operated under a series of short-term Continuing Resolutions due to delays in the passage of full-year appropriations legislation. In early 2025, the federal government faced a potential shutdown while operating under temporary funding authority that extended through March 14, 2025. The uncertainty associated with these circumstances contributed to adjustments in project timelines, vendor invoicing schedules, and payment coordination. While these conditions affected the timing of project-related expenditures, MHPCS Foundation recognizes the importance of ensuring that federal drawdowns are aligned as closely as possible with immediate disbursement needs. MHPCS Foundation maintains internal financial management practices designed to support compliance with federal cash management requirements and has taken steps to strengthen documentation and oversight related to drawdown requests. As part of its corrective action plan, the Foundation has implemented procedures to ensure that advance payment requests are generally limited to anticipated expenditures expected to occur within approximately five to seven days, consistent with the objective of minimizing the time between the receipt and disbursement of federal funds. Prior to requesting a drawdown, the Project or Program Director prepares an itemized expenditure schedule identifying the anticipated immediate cash needs associated with the project or program budget. The itemized expenditure schedule is submitted to the Foundation’s Accountant for review. The Accountant verifies that the projected expenditures are consistent with the approved program budget and prepares a Drawdown Authorization Form documenting the requested advance payment. The Drawdown Authorization Form is then reviewed and approved by the Foundation’s Board President prior to submission of the draw request through the applicable federal payment system (e.g., G5). Following submission, confirmation of the draw request is attached to the authorization documentation and retained for accounting and audit purposes. This process provides documented support for draw requests, establishes multiple levels of review, and ensures that advance payments are supported by near-term disbursement forecasts. Advance payments outside of regular payroll cycles may occur only when supported by documented project or program expenditures and must follow the same authorization and documentation procedures described above. These strengthened procedures are intended to ensure that future drawdowns are aligned with immediate program needs and supported by documented payment schedules, thereby reinforcing compliance with 2 CFR §200.305(b) and related Uniform Guidance requirements. Management believes the procedures outlined above address the circumstances described in the finding and enhance the Foundation’s internal controls over federal cash management. The Foundation remains committed to maintaining strong financial stewardship and ensuring continued compliance with applicable federal regulations governing advance payments and cash management.
The audit finding regarding the ARPA reporting has been reviewed & acknowledged. In the future, the report will be carefully inspected to make sure all figures are correct at the time of the filing. In addition, this reporting for ARPA will be wrapping up shortly since the program is nearing complet...
The audit finding regarding the ARPA reporting has been reviewed & acknowledged. In the future, the report will be carefully inspected to make sure all figures are correct at the time of the filing. In addition, this reporting for ARPA will be wrapping up shortly since the program is nearing completion.
Name of Contact Person: Keri Jerrell, DSS Director Corrective Action Plan: 1. PII Policy Monitoring Development – DSS Program Managers will at random, each quarter, complete a walkthrough of their departments offices checking staff computers to ensure they are secured when they are away. Program man...
Name of Contact Person: Keri Jerrell, DSS Director Corrective Action Plan: 1. PII Policy Monitoring Development – DSS Program Managers will at random, each quarter, complete a walkthrough of their departments offices checking staff computers to ensure they are secured when they are away. Program managers will maintain a log of each inspection and document staff members out of compliance. Quarterly Reports will be sent to the DSS Business Officer for record keeping and audit reporting purposes. 2. Program managers will complete write-ups, and re-trainings with focus on the Security Implementations Policy for those found to be out of compliance. Quarterly reports, write-ups and retrainings will be reported to the DSS Director and Administrative Assistance for further review and decisions on whether or not further action needs to take place. Proposed Completion Date: Ongoing Monitoring Procedures
Views of Responsible Officials and Planned Corrective Action In coordination with detailed discussions with the auditors, DPS has determined that its existing quarterly reconciliation process within SHARE remains an appropriate and effective control for the preparation of the Schedule of Expenditure...
Views of Responsible Officials and Planned Corrective Action In coordination with detailed discussions with the auditors, DPS has determined that its existing quarterly reconciliation process within SHARE remains an appropriate and effective control for the preparation of the Schedule of Expenditures of Federal Awards (SEFA). This process is designed to review grant-related transactions for invoicing accuracy, monitoring, and compliance and provides reasonable assurance over grant oversight and expense allowability. In addition, at fiscal year-end, DPS will perform a SEFA-specific review from a revenue perspective to confirm that federal revenue recorded in the general ledger and reimbursement requests are complete, accurate, and consistent with grant-related expenditures. This layered review process is intended to identify and resolve any instances in which expenses may be evaluated or adjusted for reimbursement purposes while remaining appropriately recorded within grant activity in the accounting records. Management concurs that the expenditure amounts reported on DPS’ final SEFA submitted to auditors related to AL 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) were inaccurate. While DPS had carefully and accurately tracked the allowable expenditures of $583,271 for two FEMA events (DR 4795 Roswell South Fork Salt Fire $543,587.72 & DR 4843 NM Roswell Flood $39,683.22) and discussed in detail with the auditors how allowable costs were determined, our submitted SEFA had a formula error which resulted in the two FEMA events not being accurately included in the total. Furthermore, management concurs that the preparation and analysis of a revenue-based SEFA, performed in addition to the expenditure-based SEFA, resulted in net adjustments of $25,998 to the previously submitted FY25 SEFA. Management concurs that DPS did not have a pre-existing formal procedure specific to the receipt and processing of federally donated surplus and usable personal property at the time of this transaction. However, management emphasizes that the donation of three federally provided robots—valued by the donor at $150,000 each for a total of $450,000—was highly unusual in nature and outside the scope of DPS’s routine grant and property transactions. As a result, DPS undertook extensive research and consultation to ensure compliance with all applicable federal requirements, as well as GASB and GAAP standards, prior to final accounting and reporting treatment. Management has created procedures to ensure the donated assets are correctly valued and included in DPS’s capital asset listing. DPS will record the donated capital assets in the government wide financial statements as capital assets and record as a revenue and expense transaction in the fund financial statements. Management further notes that DPS will follow GASB 33 and GASB 72 for non-exchange transactions when this type of transaction reoccurs. Corrective Action Plan Timeline: Process for federally donated useable personal property/assets has been implemented as of December 1, 2025. Updated SEFA process to be completed no later than October 9, 2026. Designation Of Employee Position Responsible For Meeting Deadline: CFO Deputy ASD Director ASD Director
Views of Responsible Officials and Planned Corrective Actions Management concurs with the finding. The Department will fully implement the proposed entitywide reporting controls. The Grant Management Bureau will lead the implementation of the following measures to strengthen reporting compliance: • ...
Views of Responsible Officials and Planned Corrective Actions Management concurs with the finding. The Department will fully implement the proposed entitywide reporting controls. The Grant Management Bureau will lead the implementation of the following measures to strengthen reporting compliance: • Federal Grant Tracker/Checklist: An existing grant tracking spreadsheet will be utilized to monitor all federal grants and milestone dates, including SF-425 financial reports and progress-report due dates by award. The tracker will be maintained in a shared file accessible to grant managers and analysts. • Automated Reminders: Automated email alerts will be reviewed against the Federal Grant Tracker to ensure all awards are captured and deadlines are met. • Preparer Verification and Supervisory Review: Additional information fields will be incorporated into the Federal Grant Tracker to verify completeness and accuracy of each submission, along with documented supervisory review and approval. • Monthly Compliance Updates: A monthly summary will be presented to executive management, highlighting upcoming deadlines, submission status, and any exceptions. This information will be documented within the Federal Grant Tracker. • Evidence Retention: Supporting documentation, including SF-425 due dates and analyst/manager approval dates, will be recorded in the Federal Grant Tracker and retained for audit and verification purposes. The effectiveness of these measures will be assessed by achieving 100% on-time submissions for two consecutive quarters. We are committed to meeting this objective and ensuring consistent, timely, and accurate grant reporting across the organization. The Department expects to fully implement these measures by December 31, 2025, with implementation oversight assigned to the Chief Financial Officer and Grants Management Bureau Manager.
The KCS Special Education Department will undertake a new physical inventory of all IDEA equipment, updating any inaccurate asset numbers, serial numbers, and locations in the Incident IQ asset management system. Additionally, effective for FY 2027, the District will restructure the department by mo...
The KCS Special Education Department will undertake a new physical inventory of all IDEA equipment, updating any inaccurate asset numbers, serial numbers, and locations in the Incident IQ asset management system. Additionally, effective for FY 2027, the District will restructure the department by moving a Special Education IT Asset Management position under the supervision of the District Property Manager to ensure IDEA asset management is consistent with all district property management.
February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applica...
February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Controller General. The Corrective Action Plan, submitted by the City of Richardson more specifically, responds to the Report and outlines the City’s corrective action plans to address the finding. We again thank Crowe LLP for their hard work in this matter. This single audit has and will continue to serve as a roadmap for future financial operations. Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency In two out of seven selections tested for required certified payrolls for contactor or subcontractor work performed during the fiscal year end September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Response: The City acknowledges that the required supporting documentation was not available at the time compliance testwork was completed by Crowe LLP. The City recognizes its responsibility to obtain and review certified payroll records from contractors and subcontractors for all laborers working on City grant funded projects to ensure wages and fringe benefits are paid in compliance with the Davis-Bacon Act. Corrective Action Plan: The City has an established Grants Management Policy and quarterly reporting from departments stating compliance with grant requirements. To strengthen compliance and address the documentation deficiency identified in the audit finding, the City will conduct mandatory training sessions with designated grant personnel in each department to reinforce policy requirements, required documentation standards, and applicable federal and state regulations, including certified payroll monitoring requirements where applicable. Training will be completed by June 30, 2026, and will be provided annually thereafter.The City will implement a grant review process that includes a master checklist to assist departments in verifying compliance prior to processing payments. The checklist will include verification that required supporting documentation, including certified payroll records when applicable, has been received, reviewed, and approved. Implementation of this checklist will occur by March 31, 2026. A centralized electronic repository will be established to allow Finance access to grant agreements, supporting documentation and relate records maintained by City departments. This control will be implemented by March 31, 2026. Additional internal controls will be incorporated into the financial software system to ensure that all required supporting documentation is attached and reviewed prior to payment approval. This control will be implemented by March 31, 2026. The City will conduct periodic internal compliance review testing of grants, including verification of required labor compliance documentation where applicable, to confirm ongoing adherence to federal and state regulations. Pre-award and post-award meetings will be held between Finance and the respective grant departments to establish reporting parameters, documentation requirements, monitoring responsibilities and compliance expectations prior to project implementation. When bids are solicited that include grant funding, the City will continue to communicate to all prospective bidders that compliance with all applicable federal and state laws and regulations, including labor standard requirements when applicable, is a condition of award. Bid documents will include a sample copy of the U.S. Department of Labor Davis-Bacon and Related Acts Weekly Certified Payroll form. Contact Person Responsible/Anticipated Completion Date: The Finance Director is responsible for oversight of this corrective action plan, with day-to-day management and implementation delegated to the Assistant Director of Finance. Implementation of these corrective actions is scheduled to begin immediately, with full completion anticipated by June 30, 2026. Once implemented, the procedures will be monitored on an ongoing basis to ensure continued compliance and to prevent recurrence of the finding.
Develop a Strategic Plan of Action ensuring data accuracy and timely transmission of Enrollment Status Reports & Degree Verification Reports to the National Student Clearinghouse for further submission to NSLDS. The plan will establish a structured, repeatable process to:  Validate the accuracy of ...
Develop a Strategic Plan of Action ensuring data accuracy and timely transmission of Enrollment Status Reports & Degree Verification Reports to the National Student Clearinghouse for further submission to NSLDS. The plan will establish a structured, repeatable process to:  Validate the accuracy of student enrollment and degree data prior to NSCH submission.  Ensure timely transmission of Enrollment Status Reports (ESRs) and Degree Verification Reports (DVRs).  Strengthen internal controls, documentation, and audit readiness with system-generated audit reports and dual review.  Improve communication among Registrar, IT, Institutional Research, and Financial Aid. Susan W. Gibson, University Registrar James Stotts, Associate VP Financial Aid Tansha Gillins, Principal Analyst June 30, 2026 Due to BANNER SaaS system upgrade in progress, this action will be completed by June 30, 2026, to allow for report writing in the new reporting tool postimplementation Immediate action: To ensure timely reporting to National Student Clearinghouse and NSLDS, reports will be generated bi-weekly. ISE scheduler will be used to extract baseline data from BANNER for uploading the Enrollment Status Report to National Student Clearing biweekly with off-cycle adjustments as needed. Initial errors will be identified and corrected using a dual-review process before uploading the report to NSCH. Martha Henderson, Associate Registrar Tansha Gillins, Principal Analyst On-going activity Beginning March 30, 2026 The Degree Verification Report will be generated monthly to ensure that graduation status is reported within the timeframe required by NSLDS. Graduation lists will be forwarded to the Office of Financial Aid for dual review and validation to confirm the accuracy of the data and the timeliness of certification to NSLDS. Martha Henderson, Associate Registrar Palmira Wakhisi, Financial Aid On-going activity Beginning May 20, 2026
To prevent future errors in reporting, the School District will establish a simple monthly reconciliation procedure in which reported meal counts are compared to daily meal service records to identify and correct discrepancies before submission.
To prevent future errors in reporting, the School District will establish a simple monthly reconciliation procedure in which reported meal counts are compared to daily meal service records to identify and correct discrepancies before submission.
To prevent future errors in eligibility determinations, the School District will implement a secondary review process. All eligibility applications will be reviewed by a second qualified staff member to verify household size, income calculations, and comparison to the National Income Eligibility Gui...
To prevent future errors in eligibility determinations, the School District will implement a secondary review process. All eligibility applications will be reviewed by a second qualified staff member to verify household size, income calculations, and comparison to the National Income Eligibility Guidelines before final approval.
Finding 2025-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: I...
Finding 2025-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation expended $2,354,885 during the previous audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building. Equipment acquisitions were charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards in the prior audit period. During the testing of equipment acquisitions, it was noted the School Corporation had not updated the capital asset ledger as of June 30, 2025 for federal equipment acquisitions made in the current and prior period and had not fully implemented the corrective action plan from the previous audit related to this finding. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When the capital asset inventory is completed, the Corporation Treasurer and the Building/Maintenance Director will verify the inventory is up to date and accurate. Responsible Party and Timeline for Completion: Treasurer and Building/Maintenance Director will work together after the school year to ensure the capital asset inventory is current.
Finding 2025-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10...
Finding 2025-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. The lack of review was isolated to fiscal year 2024 as the School Corporation qualified under the Community Eligibility Provision for fiscal year 2025. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the event the School Corporation is not eligible for the Community Eligibility provision in future periods, the Treasurer and Food Service Director will develop controls to ensure system income thresholds are reviewed annually to ensure they are in agreement with USDA income thresholds. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for ensuring system income thresholds are met.
Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Awar...
Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Questioned Costs: $164,866 (known questioned costs) Context: During the testing of meal claim reimbursements, we noted 3 monthly reimbursements in a sample of 6 claims selected where the School Corporation was unable to produce auditable support of meals served and claimed via underlying meal system reports. The claim reimbursements for these 3 months unsupported by meal claim data totaled $157,708. Additionally, we noted one month in which there were variances when comparing the reimbursement in our to sample to underlying meal system reports, resulting in $7,158 over claimed. Additionally, we noted that management has no formal, documented review control in place for monthly meal claims prior to submission to the Indiana Department of Education (IDOE). Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer and Food Service Director will enhance internal controls surrounding the Child Nutrition claim reporting process. The Treasurer and Food Service Director will ensure the preparation and review of claims is documented and correct prior to submission. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for the claim reporting process.
Finding #2025-003 – Reporting – Significant Deficiency. Condition and context: Same as finding #2025-002. Recommendation: Same as finding #2025-002. Planned corrective action: Management acknowledges that documented evidence of supervisory review for certain federal grant billings was not consistent...
Finding #2025-003 – Reporting – Significant Deficiency. Condition and context: Same as finding #2025-002. Recommendation: Same as finding #2025-002. Planned corrective action: Management acknowledges that documented evidence of supervisory review for certain federal grant billings was not consistently maintained, although billings were supported by underlying documentation. Effective immediately, the Academy has implemented a formal review and approval process requiring independent supervisory sign-off prior to submission of all federal grant billings. Standardized documentation procedures have been established to retain evidence of review, including a billing checklist and dated approval, to ensure proper segregation of duties and compliance with federal requirements. Responsible officer: Matthew Sherman, Business and Operations Officer. Estimated completion date: February 26, 2026.
Finding Summary During the recent Federal and State Single Audit report, completed by WIPFLI, it was identified that the institution did not accurately report Last Date of Attendance (LDA) information to the National Student Loan Data System (NSLDS) for the unofficial withdrawal population. Specific...
Finding Summary During the recent Federal and State Single Audit report, completed by WIPFLI, it was identified that the institution did not accurately report Last Date of Attendance (LDA) information to the National Student Loan Data System (NSLDS) for the unofficial withdrawal population. Specifically, adjusted end dates were not being properly communicated to the National Student Clearinghouse (NSC), which is responsible for enrollment reporting to NSLDS. As a result, students’ withdrawal dates were not accurately reflected. Issue Identified Upon notification of the finding, the Financial Aid and Registration & Records offices met to review existing procedures. It was determined that when grades of “F” were assigned, the LDA was updated in our ERP. Since internal systems had the updated last day of attendance, R2T4 calculations were done correctly. However, an enrollment file was not resubmitted to NSC to reflect the revised LDA for enrollment reporting to NSLDS. Corrective Action Taken The institution has implemented the following corrective measures to assure updated Reporting to NSC: o Once the correct LDA is confirmed by the Financial Aid Office the Registrar’s Office updates the student record in the student information system. o The updated LDA is reported to the National Student Clearinghouse (NSC), which in turn updates NSLDS. Internal Controls Implemented To prevent recurrence, the following controls are now in place:  Written procedures have been updated to clearly define: o Roles and responsibilities of Financial Aid and Registrar staff o Timeline for reporting updates to NSC  Staff training was conducted with both departments to ensure understanding of federal reporting requirements. Implementation Date The revised process was implemented immediately upon identification of the issue and is fully operational. Fall 2025 unofficial withdrawals were accurately updated to NSC on 1/15/26. Persons Responsible: Jennifer Anderegg, Dean of Strategic Enrollment Kim Yoder, Director of Financial Aid Jess Schwartz, Registrar
Response and Corrective Action Plan: The District will review its procedures and look into possible additional controls to be implemented.
Response and Corrective Action Plan: The District will review its procedures and look into possible additional controls to be implemented.
Finding Number: 2025-002, Grant Closeouts Condition: The University did not complete full grant closeout procedures in a timely manner for 8 out of 40 grants that were tested with a period of performance that ended in the year ended June 30, 2025. Corrective Actions: Penn State will raise awareness ...
Finding Number: 2025-002, Grant Closeouts Condition: The University did not complete full grant closeout procedures in a timely manner for 8 out of 40 grants that were tested with a period of performance that ended in the year ended June 30, 2025. Corrective Actions: Penn State will raise awareness of the late closeout issue at various committee, workgroup, and council meetings during Spring 2026, and enforce compliance with our existing policy. These meetings involve research leadership at all colleges, such as Associate Deans for Research, College Research Administration Officers, and College Strategic Financial Partners. Penn State will provide additional trainings throughout the year to educate colleges on the closeout process through the Financial Analysis and Compliance Office. Contact person responsible for corrective action: Jason Guilbeault, Assistant Vice President for Research – Post Award Contractual Compliance Anticipated Completion Date: March 31, 2026
Finding Number: 2025-001, Subrecipient Payments Condition: The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Planned Corrective Action: Penn State created a new Subaward Administration and Compliance Of...
Finding Number: 2025-001, Subrecipient Payments Condition: The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Planned Corrective Action: Penn State created a new Subaward Administration and Compliance Office (SACO), which is part of the new Post Award Contractual Compliance Office. The SACO is led by its own director and provides central oversight over key subaward compliance processes, such as subrecipient payments, and provide training to campus on subrecipient processes. This function has already implemented new changes and workflows in the financial system to allow for better tracking and reporting of subaward compliance activities, and continues to refine subaward processes. The creation of this office demonstrates Penn State’s commitment to compliance for subaward activities. Contact person responsible for corrective action: Jason Guilbeault, Assistant Vice President for Research – Post Award Contractual Compliance Anticipated Completion Date: February 27, 2026
Views of Responsible Officials and Corrective Action Plan We concur. Foundation management has implemented new procedures to ensure all required reporting is performed timely and accurately. We will continue outreach to the Small Business Administration to verify and correct the invalid FAIN number.
Views of Responsible Officials and Corrective Action Plan We concur. Foundation management has implemented new procedures to ensure all required reporting is performed timely and accurately. We will continue outreach to the Small Business Administration to verify and correct the invalid FAIN number.
Compliance Requirement Procurement Criteria Under 2 CFR 180.995, the School District must not enter into covered transactions with parties that are suspended or debarred. For covered transactions (generally at or above the simplified acquisition threshold), the School District must verify that vendo...
Compliance Requirement Procurement Criteria Under 2 CFR 180.995, the School District must not enter into covered transactions with parties that are suspended or debarred. For covered transactions (generally at or above the simplified acquisition threshold), the School District must verify that vendors are not suspended or debarred by (1) checking SAM.gov, (2) collecting a vendor certification, or (3) adding a contractual clause that the vendor is not suspended or debarred and maintaining documentation of the verification. Additionally, under 2 CFR 200.318(h), the School District must maintain effective internal controls over procurement to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition During testing and confirmed with management at the School District, it was determined that the School District does not verify that vendors were not debarred or suspended. Cause The School District’s procurement procedures do not require or are not consistently followed to perform and retain documentation of suspension and debarment checks for covered transactions. Effect Without controls to verify and document vendor eligibility, the School District is at risk of expending federal funds with vendors that are suspended or debarred, resulting in noncompliance with federal requirements. This could lead to questioned costs, repayment obligations, and reputational risk. Recommendation The Bonadio Group recommended that the School District strengthen its internal controls over the procurement requirement regarding suspension and debarment requirement by implementing the following actions: (a) Update written procurement procedures to clearly require documented verification before entering any covered transactions. (b) Require procurement staff to document verification at the time of award and to retain the documentation in the procurement file. (c) Integrate a system of controls, where feasible, that prevents a purchase order or contract from being finalized unless proof of suspension/debarment verification has been uploaded. (d) Provide reoccurring training to procurement, finance and grant management staff regarding federal suspension and debarment requirements and proper documentation practices. (e) Implement periodic monitoring or internal reviews to ensure that the verification process is consistently followed and address any deviations promptly. View of Responsible Officials The School District will institute additional procedures to ensure that vendors are not debarred or suspended. Response We are in agreement with the recommendation and will be creating a federal funds procedural manual to address the issues above. Anticipated Completion Date This will be corrected by 6/30/26. Person Responsible Stephanie Fanning, Assistant Superintendent for Business
2025-004-Procurcmcnt Suspension and Debarment We have developed an internal form that each employee knows they must fill out when obtaining any kind of service or supply. We have educated staff on the dollar limits and thresholds required as well as any backup documentation needed to be obtained for...
2025-004-Procurcmcnt Suspension and Debarment We have developed an internal form that each employee knows they must fill out when obtaining any kind of service or supply. We have educated staff on the dollar limits and thresholds required as well as any backup documentation needed to be obtained for each purchase of goods or services. Moving forward the finance department will be responsible for running sam.gov checks to make sure all vendors that the district does business with are clear of suspension and debarment at either the start of the fiscal year or whenever procuring new services and goods throughout the year.
2025-003-Cash Management MVRTD recognizes this material weakness. Several factors lead to the inaccurate billing noted in the audit. Firstly, it must be noted the during FY25 the MVRTD did not have a financial director on staff and the billing work was being performed by a staff accountant with no p...
2025-003-Cash Management MVRTD recognizes this material weakness. Several factors lead to the inaccurate billing noted in the audit. Firstly, it must be noted the during FY25 the MVRTD did not have a financial director on staff and the billing work was being performed by a staff accountant with no previous training in the billing of MVRTD specific grants and no written manuals or instructions were left behind to reference. Due to the fact allocations were set up to be calculated as an automatic entry inside of Passport ( our previous accounting system) and completed outside the system, there were no oversite measures that would have provided a way to prevent or identify duplicate transactions such as the overbilling that occurred. Since July 1, 2025, we have hired a full-time Finance Director and established a new accounting system. We have started using Quick Books Online (QBO), which is a much more detailed and comprehensive accounting system that allows us to be able to identify errors in the billing process and we established an entirely new cost allocation system that is outside of QBO. This ensures an internal and external check and balance system. All invoices and back-up are now being reviewed and approved by the Executive Director. Both the Finance Director and Executive Director will sign off on the invoices before submitting them to the state.
Finding 2025-006 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental E...
Finding 2025-006 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - During review of enrollment reporting procedures, we noted that one (1) student record requested for testing was not provided, and two (2) sampled student records were not updated to reflect current enrollment status changes in NSLDS. As a result, the College could not demonstrate that enrollment reporting was complete, accurate, or timely for the students tested. Views of Responsible Officials –The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plans to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.
Finding 2025-005 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental E...
Finding 2025-005 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - Testing of student withdrawals revealed that for three (3) students, Title IV funds identified as unearned through the Return of Title IV (R2T4) process were not returned to the U.S. Department of Education within the required timeframe. The returns were made between 209 and 349 days after the College’s date of determination (DOD), which is well beyond the 45-day requirement established by federal regulations. Views of Responsible Officials – The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plan to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.
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