Corrective Action Plans

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Communications with the Police Jury and Parish Engineers along with all Police Jury Department Head have taken place reinforcing to them the requirements of purchasing, contracting, bidding, and following all Police Jury establised policies and procedures for the proper procurement of goods and serv...
Communications with the Police Jury and Parish Engineers along with all Police Jury Department Head have taken place reinforcing to them the requirements of purchasing, contracting, bidding, and following all Police Jury establised policies and procedures for the proper procurement of goods and services. The reinforcement of the Police Jury Personnel Manual was made advising them all to strictly follow it immediately.
Contact Person(s): Matt Fadich Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable Corrective action planned: Task: Reviewed all nonpayroll transactions charged to federal programs and implemented coding a...
Contact Person(s): Matt Fadich Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable Corrective action planned: Task: Reviewed all nonpayroll transactions charged to federal programs and implemented coding and documentation corrections for 2026. Anticipated completion date: Done Task: Updated procedures addressing the documentation and allowability standards for nonpayroll expenditures directly charged to federal grant programs. Anticipated completion date: Done Task: Train staff with purchasing and coding authority on updated procedures, including documentation requirements and the distinction between allowable program charges and costs that may not be directly charged to federal grants. Anticipated completion date: June 30, 2026 Task: Establish a quarterly review process to identify and address potentially questionable nonpayroll transactions charged to federal programs on an ongoing basis. Anticipated completion date: June 30, 2026 School’s Out Washington considers the above steps sufficient and adequate to close the gaps in the coding of transactions that may have permitted unallowable costs to post to grants for YE2025. These steps will remedy the lapse in effectiveness experienced by School’s Out Washington’s internal controls over allowable costs.
FINDING 2025-004: Audit report deadline Response: Audit information will be completed and delivered to auditor in a timelier manner by Powell County Finance Officer.
FINDING 2025-004: Audit report deadline Response: Audit information will be completed and delivered to auditor in a timelier manner by Powell County Finance Officer.
Significant Deficiency in Internal Control over Compliance and Compliance – Procurement, Suspension and Debarment Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Ye...
Significant Deficiency in Internal Control over Compliance and Compliance – Procurement, Suspension and Debarment Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management reinforce procedures to ensure that verification of procurement, suspension and debarment practices are performed and documented prior to entering into any covered transaction or subaward. This may include retaining screenshots from SAM.gov, signed certifications, contract clauses confirming compliance, and documentation of competitive pricing retained for records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The policies and procedures associated with this process will be improved per the audit recommendations and then training for all staff involved will be completed. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026
Material Weakness in Internal Control over Compliance and Compliance - Reporting Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 ...
Material Weakness in Internal Control over Compliance and Compliance - Reporting Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management implement procedures to ensure that expenditures reported on the Federal Financial Report reflect actual costs incurred during the reporting period and are supported by appropriate documentation. Staff responsible for preparing the Federal Financial Report should be trained in federal reporting requirements to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: There is not currently a clear internal procedure on how to complete the Federal Financial Reports. This will be added to the finance department procedures and will be trained to all staff who will be responsible for this reporting. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026
Material Weakness in Internal Control over Compliance and Compliance - Cash Management Federal Program: Major Program- 93.939- HIV Prevention Activities: Non- Governmental Organization Based. Other Program- 16.889- Grants for Outreach and Services to Underserved Populations Federal Agency: Major Pro...
Material Weakness in Internal Control over Compliance and Compliance - Cash Management Federal Program: Major Program- 93.939- HIV Prevention Activities: Non- Governmental Organization Based. Other Program- 16.889- Grants for Outreach and Services to Underserved Populations Federal Agency: Major Program- U.S. Department of Health and Human Services. Other Program- U.S. Department of Justice Award Number: Major Program- NU65PS923746. Other Program- 15JOVW-22-GG-00404-UNDE Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management ensure drawdowns are strictly aligned with incurred and allowable expenses. This should include: - Pre-drawdown verification of expense documentation. - Monthly reconciliations of drawdown activity to actual expenditures. - Training for staff involved in federal fund management on Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Procedures related to federal drawdowns were not followed in this case. The finance department will review all procedures and ensure that staff are trained on proper drawdown procedures going forward. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026
Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District’s contact person: Renata Sorna, Assistant Director of Business, Finance and Operations North Kitsap School...
Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District’s contact person: Renata Sorna, Assistant Director of Business, Finance and Operations North Kitsap School District 18360 Caldart Ave NW Poulsbo, WA 98370 Tel: (360) 396-3011 Corrective action the auditee plans to take in response to the finding: We have reinstated the semi-annual and annual certification process requiring signatures from both employees and their direct supervisors to verify the work completed after that fact. In addition, we are developing a procedure for policy 6106: Allowable Costs for Federal Programs. Anticipated date to complete the corrective action: Reinstating the semi-annual certifications has already been completed for the 2025-2026 school year. We anticipate finalizing the procedure by the end of school year 2025-2026.
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but n...
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but not yet paid. This includes: • Standardized Weekly Report: A report generated and reviewed weekly by Purchasing and Accounts Payable to identify, prioritize, and resolve outstanding actions for timely payment (Control Owners: AP Manager & Purchasing Manager; Implementation: September 30, 2026) • Weekly Invoice Review: The AP Specialist responsible for subrecipient invoices will review weekly to ensure invoices are prioritized and processed, with delays or exceptions escalated promptly to the AP Manager (Frequency: Weekly; Implementation: September 30, 2026) • Periodic Compliance Monitoring: Management will perform ongoing reviews of subrecipient invoice payment activity to monitor compliance with the 30-day payment requirement and adherence to internal policies (Control Owners: AP Manager & Program Revenue Operations; Frequency: Monthly with quarterly oversight; Implementation: Ongoing, formalized by September 30, 2026) Contact person responsible for corrective action: Naté Hoover, Program Revenue Operations Anticipated Completion Date: 9/30/2026
Finding 1222673 (2025-001)
Material Weakness 2025
Management concurs with the finding and notes that the Organization has hired the appropriate staff and service organizations to complete the audit in a timely manner.
Management concurs with the finding and notes that the Organization has hired the appropriate staff and service organizations to complete the audit in a timely manner.
The organization has since stabilized its operations and restored core financial staffing capacity. As noted by the auditor, management will iniate the audit process earlier in the fiscal year going forward. This earlier start will allow sufficient time to complete all required procedures, proactive...
The organization has since stabilized its operations and restored core financial staffing capacity. As noted by the auditor, management will iniate the audit process earlier in the fiscal year going forward. This earlier start will allow sufficient time to complete all required procedures, proactively address any unforeseen challenges, and ensure timely audit completion in accordance with reporting requirements.
June 12, 2026 Response to Single Audit Finding 2025-001 Finding: Program: ALN 93.788 – State Opioid Response Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include ...
June 12, 2026 Response to Single Audit Finding 2025-001 Finding: Program: ALN 93.788 – State Opioid Response Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Management agrees with this finding and has already implemented measures to ensure that it is not repeated. The additional step of having the Finance Department review contracts with federal dollars to ensure that the ALN in the contract is consistent with the ALN on the contract award. This policy is in place as of June 12, 2026. Matt Berg is responsible for implementing this corrective action.
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditur...
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditures recorded in the accounting system. These procedures should include a reconciliation of reported amounts to the general ledger and supporting documentation prior to submission, as well as an independent review process to ensure reported information is accurate, complete, and compliant with Uniform Guidance requirements. Corrective Action: UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026
2025-007 Auditor’s Recommendation: The entity should strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are identifiable by participant and reconciled to eligibility records. The entity should also establish controls to verify benefit calculations a...
2025-007 Auditor’s Recommendation: The entity should strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are identifiable by participant and reconciled to eligibility records. The entity should also establish controls to verify benefit calculations and ensure assistance is discontinued when eligibility expires, and maintain sufficient documentation to demonstrate compliance with program requirements. Corrective Action: UCM will strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are clearly identifiable by participant and reconciled to approved eligibility records before assistance is provided. Each payment will be supported by participant identification, eligibility approval, assistance type, approved amount, funding source, payment date, and supporting documentation. UCM has established TANF Eligibility Determination Guidelines, a List of Acceptable Documents, and an Assistance Agreement Form to support eligibility determinations and benefit payment documentation. Per VDSS guidance, once eligibility is established at the beginning of the program, a change in status during the participant’s stay does not disqualify the participant from receiving further services. Felony record documentation is not required in the participant file as felony record status is not part of the eligibility requirement per VDSS. Evidence of review and approval will be retained in the participant file. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Case Managers Shruti Jha, Senior Director of Finance Liya Tseye & Carmen Romero, Accountants Laura D’Ambrogi, Grants Manager Anticipated Completion Date: Substantially completed as of April 6, 2026. Ongoing payment review, eligibility monitoring, reconciliation, and supervisory review will continue during the program year.
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant ...
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant files include sufficient documentation supporting financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, compliance with applicable legal eligibility requirements, and work participation when applicable. In addition, the entity should implement a documented supervisory review and approval process to verify eligibility determinations and supporting documentation prior to the provision of assistance. The entity should also provide training to staff responsible for eligibility determinations to ensure they understand federal TANF documentation requirements and maintain complete and accurate participant files. Corrective Action: UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, applicable legal eligibility requirements, and work participation requirements when applicable. UCM reviewed and discussed the findings with the auditor, Senior Director of Finance, and Chief Program Officer. UCM also reviewed the Virginia Department of Social Services post-training materials on TANF Employment Advancement Eligibility Determination Training, and clarified identified areas of the findings with the Virginia Department of Social Services as they relate to the subrecipient signed contract. UCM designed new Screening Guidelines for incoming program participants, including a documented supervisory review and approval process, which were completed on April 16, 2026. The new screening guidelines require participant files to include sufficient documentation supporting eligibility determinations and require supervisory review before assistance is provided. A supervisor or designated reviewer will verify that the participant file contains the required eligibility documentation, that eligibility criteria have been met, and that the assistance is consistent with TANF requirements, VDSS guidance, the subrecipient contract, and program guidelines. UCM reviewed and trained staff on the new eligibility screening guidelines, acceptable documents, and income requirements on April 28, 2026. Staff responsible for TANF eligibility determinations, case management, direct assistance, and grant compliance will continue to receive training as needed to ensure they understand TANF documentation requirements and maintain complete and accurate participant files. UCM will also periodically monitor participant files to confirm continued compliance and identify any additional training or process improvements needed. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Case Managers VDSS Program Consultant Anticipated Completion Date: Substantially completed as of April 28, 2026. Ongoing implementation, supervisory review, staff training, and monitoring will continue during the program year.
2025-005 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing allowability and documentation standards. Controls should ensure only actual costs are charged. Staff responsible for grant accounting should receive Uniform Guidance training...
2025-005 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing allowability and documentation standards. Controls should ensure only actual costs are charged. Staff responsible for grant accounting should receive Uniform Guidance training. Corrective Action: UCM will develop and implement comprehensive written policies and procedures addressing cost eligibility, documentation standards, and the requirement that only actual costs are charged to Federal awards. The procedures will be designed to ensure costs charged to Federal awards are permitted under the award terms, properly supported, accurately recorded, and consistent with Uniform Guidance requirements. UCM will update its grant accounting procedures to require supporting documentation for all costs charged to Federal awards, including invoices, receipts, payroll records, allocation schedules, contracts, purchase approvals, proof of payment, and other relevant source documents. Estimated, unsupported, or budgeted amounts will not be charged to Federal awards unless specifically permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will also implement a documented review process to confirm that Federal award expenditures are based on actual costs incurred. The review will include verification that the expense was incurred during the grant period, relates to the approved program, is supported by adequate documentation, is charged to the correct funding source, and agrees to the general ledger and supporting records. Evidence of review and approval will be retained with the grant files. Staff responsible for grant accounting, Federal award reporting, payroll allocation, accounts payable, and program budget oversight will receive Uniform Guidance training. Training will include cost eligibility, documentation standards, actual cost requirements, cost allocation, and grant expenditure review procedures. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Liya Tseye & Carmen Romero, Accountants Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedu...
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedures over Federal award expenditures to ensure costs charged to Federal awards are allowable, allocable, reasonable, properly approved, and adequately supported in accordance with Uniform Guidance. Written procedures will be developed for expenditure review and approval, including documentation of business purpose, budget availability, cost eligibility under the award terms, proper account coding, funding source, supporting documentation, and evidence of approval. UCM will also strengthen controls over direct assistance to client expenditures by requiring documentation of client eligibility, assistance type, amount approved, funding source, program approval, finance review, and evidence of payment. Direct assistance expenditures will be reviewed to ensure they are allowable under the Federal award, consistent with program requirements, properly coded, and adequately supported before payment or reimbursement is processed. UCM will also implement a Federal award expenditure checklist or similar review tool to document review before expenditures are paid, posted, or reported. The checklist will include review of allowability, allocability, reasonableness, budget availability, funding source, supporting documentation, approval, and compliance with applicable Federal award requirements. For direct assistance to clients, the checklist will also confirm client eligibility, approved assistance type, required case documentation, and evidence of payment. Staff responsible for Federal award expenditures, direct client assistance, grant accounting, accounts payable, and program budget management will receive training on the updated procedures and Uniform Guidance requirements. Supporting documentation and evidence of review and approval will be retained with the expenditure records. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026
2025-003 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing time and effort, employee benefits, payroll allocations, and documentation standards. Staff responsible for grant accounting should receive Uniform Guidance training. Correcti...
2025-003 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing time and effort, employee benefits, payroll allocations, and documentation standards. Staff responsible for grant accounting should receive Uniform Guidance training. Corrective Action: UCM is implementing Insperity, a new Human Resource and Payroll software system, to improve the accuracy and documentation of time allocation, payroll processing, and benefit allocation across programs and funding sources, including the Family Achievement Program federal award. UCM will configure Insperity and related procedures to support time allocation by program, grant, or cost objective, supervisor approval, payroll allocation reporting, and retention of supporting documentation. In addition, UCM will develop and implement written policies and procedures addressing time and effort reporting, employee benefit allocations, payroll allocation methodology, review and approval requirements, and documentation retention standards. These procedures will require that employee benefits charged to the federal award are based on actual benefit costs incurred, rather than budgeted or estimated amounts, unless otherwise permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will establish a review process to ensure payroll and benefit costs charged to the federal award are accurate, allowable, based on actual costs incurred, properly supported, and consistent with Uniform Guidance requirements. Staff responsible for grant accounting, payroll processing, and federal award compliance will receive Uniform Guidance training. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Deborah Ewell, Director of Human Resources Laura D’Ambrogi, Grants Manager Anticipated Completion Date: September 30, 2026
Department of Treasury, Passed through the Department of Agriculture and Natural Resources Federal Financial Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: During the engagement, Eide Bailly LLP noted the annual project and expenditure repor...
Department of Treasury, Passed through the Department of Agriculture and Natural Resources Federal Financial Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: During the engagement, Eide Bailly LLP noted the annual project and expenditure report submitted during the year ended December 31, 2025, was not reviewed prior to submission and had amounts reported that did not agree to the general ledger system of the City. Responsible Individuals: Kristen Bobzien, Chief Financial Officer Corrective Action Plan: The City will put procedures in place to ensure the annual project and expenditure report is reviewed for accuracy prior to submission. Anticipated Completion Date: December 31, 2026
The Town has been duly aware of it responsibilities pertaining to this program and will comply with the program requirements for suspension and debarment including evaluation and documentation for program expenditures.
The Town has been duly aware of it responsibilities pertaining to this program and will comply with the program requirements for suspension and debarment including evaluation and documentation for program expenditures.
Required Monthly Deposits Not Made Timely. Criteria: Monthly deposits are required to be made to the replacement reserve account. Condition: Monthly deposits were not made. Deposits were made every few months and total amount deposited ties to the required total deposits for the year. Context: Requi...
Required Monthly Deposits Not Made Timely. Criteria: Monthly deposits are required to be made to the replacement reserve account. Condition: Monthly deposits were not made. Deposits were made every few months and total amount deposited ties to the required total deposits for the year. Context: Required deposits were made but they were not made monthly due to cash flow restraint. Response: The Organization will make the required deposits monthly if cash flow allows. Management expects these corrective actions to ensure future compliance with applicable federal and HUD reporting requirements.
SCORE believes that this finding stems from exceptional circumstances that occurred during fiscal year 2025 related to the interruption of federal funding. SCORE expensed the last of the authorized fiscal year 2025 federal award funds in March 2025 and is still awaiting authorization for the remaind...
SCORE believes that this finding stems from exceptional circumstances that occurred during fiscal year 2025 related to the interruption of federal funding. SCORE expensed the last of the authorized fiscal year 2025 federal award funds in March 2025 and is still awaiting authorization for the remainder of the appropriated funds under the fiscal year 2025 award. As a result, SCORE was not able to continue submitting monthly draw requests that included the corresponding Detailed Expenditure Worksheets (DEWs). However, in accordance with the Notice of Award requirements, SCORE continued to prepare and submit quarterly financial reports reflecting expenditures that had been earmarked for federal reimbursement. Because the corresponding DEWs and draw requests could not be submitted while federal funding authorization remained pending, these reports could not be fully reconciled to the DEWs that have not yet been filed. Management acknowledges the auditors’ recommendation and will strengthen internal controls around the reconciliation of monthly and quarterly reporting. SCORE will implement enhanced reconciliation procedures to ensure that future reimbursement requests are fully reconciled prior to submission and will establish a documented contingency procedure for reporting periods in which federal funding authorization or reimbursement processing is delayed.
SCORE acknowledges the auditors’ recommendation and confirms that procedures are already in place to verify new vendors against the SAM.gov suspension and debarment database prior to engagement. Management agrees that this procedure should be extended to include periodic verification for contract re...
SCORE acknowledges the auditors’ recommendation and confirms that procedures are already in place to verify new vendors against the SAM.gov suspension and debarment database prior to engagement. Management agrees that this procedure should be extended to include periodic verification for contract renewals and multi-year vendor relationships. SCORE will also update its vendor compliance procedures to require documented SAM.gov verification at the time of vendor onboarding and periodically thereafter for continuing vendors and will implement a centralized tracking mechanism to document verification dates.
The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the p...
The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the process of implementing enhanced controls over student notification procedures. Formal policies and procedures will be established to ensure that notifications are generated and delivered prior to disbursement, including defined timing, content, and documentation requirements. The College will engage third-party consultants and implement system enhancements to improve the timing and sequencing of notifications and disbursements. In addition, the College will implement monitoring procedures, including tracking of notification and disbursement dates and documented supervisory review, to ensure compliance with timing requirements and timely identification and resolution of exceptions. Accounting, independent of the Office of Financial Aid, will perform a final review to verify that notifications are issued prior to disbursement and that established procedures are consistently followed. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that required notifications are provided timely and in accordance with federal requirements, and to prevent recurrence
The College acknowledges the finding and agrees that verification procedures must include documented evidence of completion and supervisory review. The condition resulted from the absence of formal procedures and lack of retained documentation evidencing completion and review of verification activit...
The College acknowledges the finding and agrees that verification procedures must include documented evidence of completion and supervisory review. The condition resulted from the absence of formal procedures and lack of retained documentation evidencing completion and review of verification activities. The College is in the process of implementing enhanced controls over verification procedures. Formal policies and procedures will be established to define responsibilities, documentation requirements, and supervisory review expectations. Each verification file will require documented evidence of completion and review, including electronic sign-off or system-based approval. In addition, the College will implement quality control measures, including systematic validations and periodic supervisory reviews, with documentation retained to evidence the scope and results of such reviews. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that verification procedures are consistently applied, properly documented, and subject to appropriate review, and to prevent recurrence.
The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, ...
The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, and insufficient documentation and reconciliation of student-level return activity. The College is in the process of implementing enhanced controls over the R2T4 process. A monthly structured workflow has been established whereby the Office of Financial Aid prepares and provides a detailed listing of students subject to R2T4 calculations, including institutional return amounts. Accounting independently reviews and verifies the calculated return amounts and processes the return through the federal system, with documented review and approval. The College has eliminated undocumented manual netting adjustments and requires that all R2T4 returns be recorded as distinct transactions supported by a standardized documentation package, including studentlevel calculations, withdrawal determination dates, and institutional return amounts. All activity is maintained in a centralized electronic repository to ensure a complete audit trail. In addition, the College is formalizing written procedures to define roles and responsibilities, establish documentation standards, and require documented supervisory review and approval. Periodic reconciliations will be performed to ensure that student-level return amounts agree to system activity and federal cash activity. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that R2T4 calculations and returns are accurate, properly documented, fully traceable, and compliant with federal requirements, and to prevent recurrence.
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