Corrective Action Plans

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Finding 2025-012: Untimely ARP ESSER Reporting Corrective Action: The District will establish a formal federal reporting compliance process to ensure timely, complete, and accurate submission of all required ARP ESSER and other federal reports. Specific Actions: • Develop a centralized federal compl...
Finding 2025-012: Untimely ARP ESSER Reporting Corrective Action: The District will establish a formal federal reporting compliance process to ensure timely, complete, and accurate submission of all required ARP ESSER and other federal reports. Specific Actions: • Develop a centralized federal compliance calendar that includes all required deadlines, including ARP ESSER FS-10F Final Expenditure Reports. • Create written procedures for periodic review and tracking of upcoming federal reporting deadlines. • Assign responsibility to designated staff to monitor reporting requirements and coordinate timely submission. • Conduct supervisory review of all federal reports prior to submission to ensure completeness and accuracy. • Provide training to staff responsible for federal reporting on deadlines, procedures, and compliance requirements. Responsible Party: School Business Manager Anticipated Completion Date: Procedures implemented by March 31, 2026, with ongoing monitoring thereafter.
Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement w...
Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office has put in place steps to ensure that any exception reports from the Clearinghouse are immediately reviewed and any exceptions are addressed and resubmitted. In addition, the Registrar’s Office has put in place steps to ensure that students are submitted to the Clearinghouse early enough so that they will still be submitted by the Clearinghouse to NSLDS timely, even if there are delays by the Clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Kristin Dvorak, University Registrar; Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: January 2026
Finding 2025-001 Required Disclosures Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has participated in educational opportunities provided by the Department of Education and implemented procedures to ensure...
Finding 2025-001 Required Disclosures Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has participated in educational opportunities provided by the Department of Education and implemented procedures to ensure timely disclosure. All subsequent updates have been completed. Implementation Date Immediate Individual(s) Responsible Brandon Goen, Controller
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepare...
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepared by cafeteria staff and (2) the monthly enrollment reports from the accounting software. The reviewer will then sign and date the supporting documentation before the meal claim is submitted. Anticipated date of completion: December 2025. Name of contact person: Jake Flowers, Superintendent. Management response: The corrective action plan was discussed with the employees responsible for filing the claim and the superintendent. After discussion, the plan was approved by the superintendent and will be adopted.
Direct Loan Disbursement Notifications Correction Action Planned: For the 2025-2026 academic year, notifications are scheduled in our FAMS system to be sent immediately after student loans are disbursed to the student account. This action started with the Fall 2025 semester. Policy and Procedures ha...
Direct Loan Disbursement Notifications Correction Action Planned: For the 2025-2026 academic year, notifications are scheduled in our FAMS system to be sent immediately after student loans are disbursed to the student account. This action started with the Fall 2025 semester. Policy and Procedures have been updated to include the Direct Loan notification statement. This is in Section 10.5, Student & Parent Notifications, on Page 48 of the Financial Aid Policies and Procedures manual. This action has already been completed and in progress as of September 2025. Person Responsible for the Corrective Action: Denise Welch, Director of Financial Aid
Name of Contact Person Anna Kinder, Casper Natrona County Department of Health, Executive Director Board of County Commissioners Corrective Action Plan Management agrees with the finding and plans to adhere to compliance with suspension and debarment policies including documentation requirements. Im...
Name of Contact Person Anna Kinder, Casper Natrona County Department of Health, Executive Director Board of County Commissioners Corrective Action Plan Management agrees with the finding and plans to adhere to compliance with suspension and debarment policies including documentation requirements. Implementation is expected to occur during the next fiscal year. Proposed Completion Date June 30, 2026
5. SA-2025-01 a. Deficiency: Employees funded with Title I grant funds should document their time worked for the grant in line with time and effort requirements of the grant. b. Cause: The District did not consistently meet Title I time and effort documentation requirements for certain employees dur...
5. SA-2025-01 a. Deficiency: Employees funded with Title I grant funds should document their time worked for the grant in line with time and effort requirements of the grant. b. Cause: The District did not consistently meet Title I time and effort documentation requirements for certain employees during the audit period. This occurred due to staffing changes and turnover within the federal grant which resulted in retro pay and funding corrections, which resulted in inconsistent time and effort documentation. In addition, there was a lack of centralized oversight to ensure that time and effort records were completed timely and retained in accordance with federal requirements. c. Corrective Action: The District has taken steps to review time and effort allocations, processes and requirements. Training will be provided to applicable employees and supervisors to reinforce federal requirements and expectations.
Item 2025-002 USDA Commodities Distributed Significant Deficiency Recommendation: The Organization should implement IT security measures, including offsite backups and disaster recovery testing, to ensure critical compliance documentation is preserved and accessible in the event of a system failure ...
Item 2025-002 USDA Commodities Distributed Significant Deficiency Recommendation: The Organization should implement IT security measures, including offsite backups and disaster recovery testing, to ensure critical compliance documentation is preserved and accessible in the event of a system failure or cyberattack. Management Views: Management agrees with the finding. Action Planned: In 2026 the Food Bank will begin a regular schedule of testing disaster recovery and backup recovery. Anticipated Completion date: April 30, 2026 Responsible Party: Karla Davis, Chief Financial Officer
A plan was developed by the District to eliminate the excess of net resources in the Food Service Fund. The plan includes a review of the excess of net resources on a monthly basis for determination of areas to improve the foods svc department relating to equipment purchases and staff.
A plan was developed by the District to eliminate the excess of net resources in the Food Service Fund. The plan includes a review of the excess of net resources on a monthly basis for determination of areas to improve the foods svc department relating to equipment purchases and staff.
Department of Education, passed through the State of Montana Office of Public Instruction, Federal Financial Assistance Listing 84.010, federal award numbers S010A240026 and S010240026, grant period 7/1/2024 – 9/30/2026 Title I Grants to Local Education Agencies Special Tests and Provisions Finding ...
Department of Education, passed through the State of Montana Office of Public Instruction, Federal Financial Assistance Listing 84.010, federal award numbers S010A240026 and S010240026, grant period 7/1/2024 – 9/30/2026 Title I Grants to Local Education Agencies Special Tests and Provisions Finding Summary: During the auditor’s federal program testing of Title I, it was noted that several students were removed from the adjusted cohort for unallowable reasons. Corrective Action Plan: The District staff will follow the guidance in ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)), to ensure graduation rate data is reported correctly going forward. Responsible Individual: Laurie Kvamme, Chief Financial Officer Anticipated Completion Date: June 30, 2026
Management’s response/corrective action plan: Management concurs with the audit finding. During fiscal year 2024, the School Unit appropriately recorded the cost of a five-year software agreement as a prepaid expenditure. However, in fiscal year 2025, the entire amount was incorrectly recognized as ...
Management’s response/corrective action plan: Management concurs with the audit finding. During fiscal year 2024, the School Unit appropriately recorded the cost of a five-year software agreement as a prepaid expenditure. However, in fiscal year 2025, the entire amount was incorrectly recognized as a current-year expenditure and included in the calculation of grant reimbursements. To remedy this issue, management will enhance internal controls over prepaid expenditures charged to federal grants. Specifically, finance staff and the business manager, will review all prepaid items at year-end and during grant reimbursement preparation to ensure that expenditures are recognized in the proper fiscal period and in accordance with the underlying contract terms. A reconciliation between prepaid balances, contract terms, and reimbursement requests will be performed prior to federal grant submission. In addition, written procedures will be updated to clearly require verification that only allowable and incurred costs are included in reimbursement claims, and relevant staff will receive additional training on grant compliance requirements related to prepaid expenditures. Management believes these actions will prevent similar issues in the future.
Management’s response/corrective action plan: Management agrees with the finding. The School Unit acknowledges that while suspension and debarment verifications for out-of-district tuition providers were performed through SAM.gov, documentation evidencing those verifications was not formally retaine...
Management’s response/corrective action plan: Management agrees with the finding. The School Unit acknowledges that while suspension and debarment verifications for out-of-district tuition providers were performed through SAM.gov, documentation evidencing those verifications was not formally retained. This occurred because the verification process was conducted as part of normal procurement due diligence; however, procedures did not explicitly require the retention of proof of those checks. RSU 18 will ensure that procedures will require documentation of suspension and debarment checks for all vendors and service providers subject to Uniform Guidance requirements. The school unit will utilize screenshots of vendors search on SAM.gov or signed vendor certifications/attestations as evidence for compliance. The records will be maintained with the Business office and reviewed prior to entering a new contract, renewal, or when required by federal program guidance. Management believes these corrective actions will strengthen internal controls, ensure compliance with Uniform Guidance documentation requirements, and prevent recurrence of this issue in future audit periods.
OCCIDENTAL COLLEGE CORRECTIVE ACTION PLAN FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Explanation of Deficiency: A sample of 20 federal aid recipient students was selected fromsystem generated reports of students ...
OCCIDENTAL COLLEGE CORRECTIVE ACTION PLAN FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Explanation of Deficiency: A sample of 20 federal aid recipient students was selected fromsystem generated reports of students who graduated, withdrew, or dropped during the 2024-2025 academic year. The enrollment information per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. All 20 of the students selected as samples were not reported to the NSLDS within the required timeframe. Corrective Action Plan: With the hiring of our Associate Registrar for Systems and Reporting we once again have a staff member specifically responsible for reporting enrollment and degrees to the NSC. That position is backed up by three other staff members who also have access to submit and correct files. This past summer, we adjusted our reporting schedule in a further effort to comply with our reporting requirements. Despite any delays caused by us or by the National Student Clearinghouse, I understand that we are responsible for making sure our data is received and posted according to our obligations. The division of labor that comes with a full staff will allow for data transfers as soon as degrees are posted after the end of a semester. The adjusted timing for enrollment file submissions will also prevent any bottlenecks that might delay our data from being posted. These steps have already been implemented as evidenced by the fact that our degree file for the fall semester just ended was sent before our holiday break. As noted last year, staff have been instructed that the resolution of error files is to be given a high priority. One staff member has priority responsibility for resolving those files backed up by our primary submitter of data to the Clearinghouse. Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: August 1, 2025
Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking...
Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking software. Timesheets are only allowed to be turned in to the Payroll Clerk by the approving supervisor, and after timesheets are entered by the Payroll Clerk they are scanned to the supervisor to review and make sure they agree to what was turned in. The Chief Operations and Financial Officer, Director of Child Nutrition, and Payroll Clerk have all completed internal control training, and The District is evaluating the Child Nutrition Department’s staffing and job descriptions and looking into adding a clerical position to help with reporting and add to segregation of duties/checks and balances.
Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding struc...
Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026
Finding 2025-002: Allowable cost-Significant deficiency in internal controls over compliance. Management Response The District purchased supplies on the District credit card. There was no purchasing requisition entered or approval prior to making the purchase. The District conducted procurement trai...
Finding 2025-002: Allowable cost-Significant deficiency in internal controls over compliance. Management Response The District purchased supplies on the District credit card. There was no purchasing requisition entered or approval prior to making the purchase. The District conducted procurement training in August 2025. The District will conduct another training in October 2025 to discuss procurement requirements regarding credit card purchases. If a credit card purchase is made without a requisition, the accounts payable staff will notify the management prior to the credit card payment.
Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Assistant Director (AD) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted ...
Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Assistant Director (AD) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The AD will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the AD receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The AD will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.
Finding: 2025-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A242416, P033A242416, R063P242851, P268K252851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed to ide...
Finding: 2025-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A242416, P033A242416, R063P242851, P268K252851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed to identify populations whose enrollment status changed and accurately report changes to National Student Clearinghouse and the National Student Loan Data System (NSLDS). This issue was discovered during the annual audit of student financial aid files. Of the565 Title-IV recipients for the affected terms, 37 students (6.5%) have been identified as affected by this issue. Corrective Action: The process has been reviewed and updated to correct this issue. • The Information Technology department has developed an internal script to actively identify and update student enrollment status records whose enrollment statuses have not already changed in the College’s School Information System, which then allows the student files to be identified in National Student Clearinghouse reporting procedures. • A report was created and is checked monthly to screen student accounts for manual review in case script developed does not update student records with new enrollment statuses. This report includes the date of status change for manual auditing of reason for status change in manual review. Responsible Individual: Cameron Brown, Director, Financial Aid Completion Date: August 2025
Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure str...
Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and compliance with federal grant requirements. c. Anticipated Completion Date: Immediately.
Views of Responsible Officials and Corrective Action Plan The Campus Business and Financial Aid Offices reviewed the untimely return of Title IV (R2T4) funds and implemented a revised process to ensure compliance. Weekly R2T4 reviews: Financial Aid specialists now review all accounts requiring R2T4 ...
Views of Responsible Officials and Corrective Action Plan The Campus Business and Financial Aid Offices reviewed the untimely return of Title IV (R2T4) funds and implemented a revised process to ensure compliance. Weekly R2T4 reviews: Financial Aid specialists now review all accounts requiring R2T4 calculations each week. Mid-month reconciliation: Added to the existing end-of-month process to expedite fund returns. Weekly coordination meetings: Financial Aid and Business Services staff review pending cases to ensure all returns meet the 45-day federal deadline. Quarterly compliance checks: Other Financial Aid staff monitor adherence and make recommendations for process improvement. The District will review this process each term and adjust procedures as needed to sustain compliance and efficiency.
This segregation of duties weakness is impratical to totally correct due to the limited resources and staff available to the district. The District will continue to use other controls, where practical, to compensate for this limitation.
This segregation of duties weakness is impratical to totally correct due to the limited resources and staff available to the district. The District will continue to use other controls, where practical, to compensate for this limitation.
As a 501c3 non-profit organization with a large portfolio of federally funded cost-reimbursement awards, management of cash is of fundamental importance due to the nature of the business and floating of cash involved in base operations and maintaining our valued vendor partnerships. Parallax has mad...
As a 501c3 non-profit organization with a large portfolio of federally funded cost-reimbursement awards, management of cash is of fundamental importance due to the nature of the business and floating of cash involved in base operations and maintaining our valued vendor partnerships. Parallax has made significant improvements from prior years, including but not limited to, establishment of a formal Billing Policy and substantially fewer selections where vendor payment wasn’t made within 30 days of Parallax’s request for reimbursement from the government. Unfortunately, Parallax encountered some cumulative timing challenges on cash collections because of provisional vs. anticipated final billing rates in fiscal year 2025. Parallax is also in the process of renegotiating the terms of the line of credit that would avoid fluctuations based on receivables. We believe a combination of internal controls through the policy put in place, collection of backlog rate variances and a static line of credit availability will collectively assist with ensuring future compliance. The anticipated completion date of May 1, 2026 was derived from the requirement to submit our Incurred Cost Submission to the government by December 31, 2025. The anticipated completion date assumes established final rates within a 60-calendar day window of that date to allow time to process billings, communicate with clients and allow time for payment processing to Parallax.
Subject: Management response to Fiscal Year 2025 Audit Findings The management of Village Tech Schools acknowledges receipt of the following findings for the FY25 audit and has developed a corrective action plan response to address the findings. Finding 2025-001: Reporting – Significant deficiency i...
Subject: Management response to Fiscal Year 2025 Audit Findings The management of Village Tech Schools acknowledges receipt of the following findings for the FY25 audit and has developed a corrective action plan response to address the findings. Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Supervisor (CNS) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The CNS will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the CNS receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The CNS will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.
Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted...
Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted, communications must be generated to youth program staff to take corrective actions before the elapse of the funding period. Action Taken The Executive Director has begun meetings with staff to establish a short-term plan to discuss strategies to increase the number of youth participants in the Program. In addition, at these meetings, the Executive Director has instructed the Program Executive and Program Manager to maintain control over the budget allocated and the activities to be carried out and to coordinate the planning of future activities. With regard to the Finance Area, the Chief Financial Officer is instructed that at least every two months or at the request of the Assistance Manager submit the “Encumbrance Budget Report” to see the changes in budget and be able to make decisions related to changes in the approved budget by the Labor Department Program. In the meetings to be held, the results obtained and the status of the activities carried out in order to be accountable for the actions carried out must be reported. This to maintain continuous monitoring of the program, before the end of the validity of the funds.
The District will develop and implement procurement policies and procedure to ensure compliance with 2 CFR section 200.318 to 200.326.
The District will develop and implement procurement policies and procedure to ensure compliance with 2 CFR section 200.318 to 200.326.
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