Corrective Action Plans

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Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review ...
Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Period of Performance Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Training will be provided to all relevant staff on cost allowability and period of pe...
Period of Performance Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Training will be provided to all relevant staff on cost allowability and period of performance requirements. This training will reinforce that costs must be incurred within approved project period. ● How compliance and performance will be measured and documented for future audit, management and performance review. Completion of staff training will be tracked and documented. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Subrecipient Monitoring Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document covering ...
Subrecipient Monitoring Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. The internal controls within the annual audit review process will require a response and escalation, as needed, for multiple follow-ups to enhance sub monitoring. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On...
Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Matching, Level of Effort, and Earmarking Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has mandated a required cost share form to be comple...
Matching, Level of Effort, and Earmarking Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has mandated a required cost share form to be completed and will require that the documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with Principal Investigator’s documentation. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Subrecipient Monitoring Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o DRI implemented controls to require the documentation of risk assessment procedur...
Subrecipient Monitoring Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o DRI implemented controls to require the documentation of risk assessment procedures for all subawards issued beginning in November 2024. Depending on the results of the risk assessment, monitoring procedures are designed to ensure compliance. o DRI will review all subawards issued in prior years that are still active. For any that may be missing required information, communication will be sent to the subrecipient by March 31, 2026. o DRI will ensure future monitoring activities are adequately documented. Currently, procedures do require those knowledgeable of subaward activities to review and approve subaward invoices. Procedures will be updated beginning in February 2026 to include an intermittent review of supporting documentation for invoices received based on the subrecipient’s level of risk. o DRI will update procedures to ensure subrecipient audit reports are collected timely beginning in February 2026. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation will be maintained in DRI’s pre-award system or in the accounting system, as appropriate, to ensure compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Nevada State University (NSU) has implemented procedures and staff training to ensure that a risk assessment tool/checklist is completed prior to issuance of a subaward. ● How compliance and performance will be measured and documented for future audit, management and performance review. NSU will conduct a risk assessment using a checklist prior to issuing a subaward. NSU will request and review prospective subrecipients’ annual financial statements and audit reports and will verify suspension and debarment status. Based on the results of this review, NSU will adjust subrecipient monitoring as appropriate. All risk assessments, reviews, and monitoring activities will be documented and maintained in the subrecipient files and in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Grants Award Services will be responsible with additional oversight by the Associate Vice President of Fiscal Services. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document, in place as of July 2025, covering the entire subrecipient lifecycle and includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and Authorized purposes review. Additional reviews of the policy and procedures are conducted throughout the fiscal year to ensure the related practices are relevant and effective, with adjustments made as necessary. ● How compliance and performance will be measured and documented for future audit, management and performance review. Per the UNLV OSP policy, documentation is required throughout the lifecycle and will be used for future audits. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; All required subaward documents will be retained in a centralized database for easy access and compliance tracking. Subaward Specialist will review subrecipient audit reports timely to ensure a management decision letter will be issued within six months of the clearinghouse acceptance date if required. ● How compliance and performance will be measured and documented for future audit, management and performance review. Once subrecipient letters of certification have been issued, management will perform a monthly reconciliation to ensure completeness and timely follow-up. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on al...
Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Supplier Invoice requests will be revie...
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Supplier Invoice requests will be reviewed and approved by a manager independent of the preparer. The manager’s review will include verifying appropriate documentation is received and maintained to support payments processed. ● How compliance and performance will be measured and documented for future audit, management and performance review. The manager’s independent review and approval of each supplier invoice request, including verification of required documentation to support payments, will be tracked and attached within the system’s business process. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu
Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the in...
Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the internal controls in place did not prevent and detect the exceptions. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) University procedures have been updated to ensure verification status updates are properly transmitted to the Common Origination and Disbursement (COD) system upon completion of verification. Relevant staff have been trained on the revised procedures. 2) University has implemented a process to periodically review records and confirm that verification statuses are accurately reflected in COD. All affected student records have been reviewed and corrected. It has been confirmed in the National Student Loan Data System (NSLDS) that none of the mis-reported statuses resulted in an overpayment. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026
Finding 2025-004 Internal Controls Over Procurement Condition: Northern Illinois University (University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not al...
Finding 2025-004 Internal Controls Over Procurement Condition: Northern Illinois University (University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University implemented revised procedures and targeted training beginning in April 2025 to strengthen compliance with 2 CFR 200 procurement requirements. The transactions identified in the condition occurred prior to full implementation of this corrective action. 2. The University will continue to monitor procurement processes to ensure accurate and complete documentation of the procurement method selected. Individual(s) Responsible for Corrective Action: Sponsored Programs & Procurement Services & Contract Management Staff Anticipated Completion Date: June 30, 2026
Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and...
Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. 2. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. 3. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026
Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the...
Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Indirect Cost Rate Review Auditor Description of Condition and Effect. The University does not have a formal review process related to indirect cost rate automated entries. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting,...
Indirect Cost Rate Review Auditor Description of Condition and Effect. The University does not have a formal review process related to indirect cost rate automated entries. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. Corrective Action. The University will establish formal procedures to review the indirect cost rate input and automated entries by additional individual on a monthly or quarterly basis. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Insufficient Supporting Documentation of Disbursements Auditor Description of Condition and Effect. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. As a resul...
Insufficient Supporting Documentation of Disbursements Auditor Description of Condition and Effect. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Corrective Action. The University will establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the r...
Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Auditor Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. Corrective Action. The University will create a formal Banking Services Agreement with the Financial Institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Auditor Description of Condition and Effect. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that ...
Lack of Documentation for Sole-Sourcing Arrangements (Repeat finding) Auditor Description of Condition and Effect. During our testing of procurement, suspension and debarment, we noted there were purchases during the grant period that exceeded the threshold for requiring bids. We further noted that there were no bids acquired by the University due to these items only being available for purchase from a sole vendor. However, we found there were no sole-sourcing arrangements documented and an overall lack of documentation by the University as to why there were no bids acquired for these purchases. We were able to subsequently obtain evidence that these were appropriate sole-source situations. As a result of this condition, the University was not initially maintaining documentation for certain sole-source arrangements to support its compliance with its bid policy and federal guidelines. Auditor Recommendation. We recommend that the University maintain documentation for sole-source arrangements and the approval thereof supporting compliance with its bid policy and federal guidelines. Corrective Action. The University will maintain documentation for sole-source arrangements and approval of supporting documents to remain in compliance with bid policy and federal guidelines. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Lack of Review and Timely Filing of Financial Status Reports (Repeat finding) Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission peri...
Lack of Review and Timely Filing of Financial Status Reports (Repeat finding) Auditor Description of Condition and Effect. During our review of the required reporting for the grant, we noted 1 of the 3 Financial Status Reports tested was submitted to the EGrAMS website outside of the submission period allowed by the grant agreement. As a result of this condition, the University is out of compliance with guidelines established by the grantor. Auditor Recommendation. We recommend that the University implement a process to track the submission of all Financial Status Reports to ensure they are submitted before the due date required by the grant to stay in compliance with grant agreements. Corrective Action. The University will establish and follow an internal controls policy that requires review and approval prior to submitting financial status report timely. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Lack of Review over Financial Status Reports Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitt...
Lack of Review over Financial Status Reports Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Auditor Recommendation. We recommend that the University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. Corrective Action. The University will implement a review process to ensure that all drawdowns are reviewed by a second individual prior to submission. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the Uni...
Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the University is out of compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked and no changes made without proper review and approval. Corrective Action. The University will implement a review process to ensure that all student budgets are reviewed and locked. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester s...
Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. As a result of this condition, the University is not in compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026
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...
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 Context: For the 2 sample items tested, the acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2025. For one of the sample items, the School Corporation expended $333,000 on building renovations which was charged to the ESSER III (84.425U) grant award. For the other sample item, the School Corporation expended $71,000 for locker room upgrades that was charged to the ESSER III grant. Additionally, we noted the School Corporation’s capital asset listing did not contain all the required information, including the source of funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school management will work with the company it hired for asset management to ensure that all items are properly listed on the asset list. The school management will conduct a thorough secondary review of the company’s final asset list.
For A/P - the District Office has the Secretary open all mail and deliver to intended recipients. When delivered to A/R, money is deposited in a timely manner (within 24 hours). A/R then prepares the deposit. The Deposit is then double-checked and initialed by another District Office employee before...
For A/P - the District Office has the Secretary open all mail and deliver to intended recipients. When delivered to A/R, money is deposited in a timely manner (within 24 hours). A/R then prepares the deposit. The Deposit is then double-checked and initialed by another District Office employee before depositing. All accounts are reconciled weekly by A/R and monthly by the SBO. For Investments, there are two signers on the Bank Iowa accounts. All transactions are authorized by the Board, Superintendent, and then transactional is taken care of by the SBO. ACH/Wire Transfers - all ACH and Wire Transfers initiated by payroll are sent to the SBO by the Bank so there are two sets of eyes on them. Financial reporting is reviewed by the Superintendent and Board monthly. Journal entries are not initialed by another District Office Employee. We have made very concerted efforts to distribute duties without compromising accuracy.
March 11, 2026 The University acknowledges the finding and the recommendation from Baker Tilly regarding improving procedures. Finding: 2025-001 – Special Tests and Provisions – Return of Title IV Funding (R2T4) and Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Imp...
March 11, 2026 The University acknowledges the finding and the recommendation from Baker Tilly regarding improving procedures. Finding: 2025-001 – Special Tests and Provisions – Return of Title IV Funding (R2T4) and Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Improved Process of Protocol This finding stemmed from 4 (four) departments at the University: College of Science and Health, College of Nursing, Office of the Registrar and Office of Financial Aid. As such, each department’s corrective action plan is listed below. College of Science and Health (COSH) To address this finding, the office of the COSH Dean has implemented a formal attendance-monitoring and escalation process to improve internal controls and ensure timely intervention. The updated process clearly defines responsibilities for faculty, program coordinators, and program leadership. Program Coordinators will review attendance records regularly: before the add/drop deadline, prior to the last day of the withdrawal period, and biweekly afterward to identify students who are not attending or exhibiting patterns of repeated absence. The process also outlines escalation procedures and timelines for student outreach, documentation of communication efforts, and reporting to the Registrar when administrative actions are needed. These procedures help ensure that non-attendance is identified promptly and that appropriate enrollment status adjustments are made in line with institutional policies. The Office of the Dean will oversee compliance with these procedures by conducting regular reviews of attendance records, documenting outreach efforts, and verifying notifications from the Registrar. This corrective measure enhances oversight, promotes prompt intervention for atrisk students, and ensures consistent enforcement of institutional policies on attendance and enrollment status. The action plan will be implemented on March 13th, 2026, and reviewed every semester for quality improvement. *See Corrective Action Plan for included table* Contact Person Responsible for Corrective Action: Dr. Monica G. Ferini, Dean, COSH Anticipated Completion Date: March 13th, 2026 College of Nursing (CON) To address this finding, the office of the CON Dean has implemented the following corrective action plan as follows: • Faculty: consistent check of attendance • Program Coordinator (PC): to run reports before add and drop date to track student activity status, if not active, Program Director (PD) will send notification to Registrar to request to process "drop" from the course • Program Coordinators (PC): Run attendance data tracking every 2 weeks • If student is identified missing >2 classes: PC will notify Faculty then faculty reach out to student (within 2-3d) • If student does not respond to faculty or continues to miss class: Faculty to notify PD (within 3-5d) • If student does not respond to PD or continues to miss class: PD to notify registrar of "withdraw" or dismissal (within 3d) Contact Person Responsible for Corrective Action: Dr. Sheryl Antido, Associate Dean, CON Anticipated Completion Date: March 23rd, 2026 Office of the Registrar Upon receipt of the university administrative or withdrawal form from the college or student, the form is processed in PowerCampus by the Office of the Registrar within five business days. Once the student’s status has been updated from "Enrolled" to "Withdrawn" or "Dismissed," an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program. Upon receipt of the notification from the Office of the Registrar that a student’s status has been updated to “Withdrawn” or “Dismissed,” an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program as confirmation that the student enrollment status has been updated. Contact Person Responsible for Corrective Action: Raquel Munoz, Registrar Anticipated Completion Date: Current Workflow in Place Office of Financial Aid Upon notification from the Office of the Registrar, The Office of Financial Aid will review the student’s record to determine whether a Return of Title IV (R2T4) calculation is required. If applicable, the Office of Financial Aid will complete the R2T4 calculation and process the return of Title IV funds within the required federal timeframe in accordance with 34 CFR 668.22, ensuring that funds are returned no later than 45 days from the date the institution determines the student withdrew. The Office of Financial Aid maintains an internal tracking process to monitor students who withdraw and to ensure timely completion of R2T4 calculations and reporting requirements. We remain committed to this process and will continue to provide ongoing training throughout the year to ensure compliance and to keep academic departments informed of the procedures. Contact Person Responsible for Corrective Action: Henry Espinoza, Director of Financial Aid Anticipated Completion Date: Current Workflow in Place
The University experienced a mid-year leadership transition in the Registrar’s Office when the prior Registrar resigned, requiring a search for a new Registrar. At the time of the transition, the former Registrar was responsible for both routine office operations and oversight of enrollment reportin...
The University experienced a mid-year leadership transition in the Registrar’s Office when the prior Registrar resigned, requiring a search for a new Registrar. At the time of the transition, the former Registrar was responsible for both routine office operations and oversight of enrollment reporting to the National Clearinghouse and NSLDS. During this period, incorrect data entries occurred. Corrective action has been initiated under the leadership of the newly appointed Registrar, who is conducting a comprehensive review of existing processes and internal controls within the office. This review includes evaluating data entry procedures and oversight practices to ensure greater accuracy and consistency. In addition, as part of the integration with Sentara College of Allied Health, the University is adding staff positions in both the Registrar’s Office and Financial Aid. The new staff members will allow for improved systems and process oversight and reduce operational strain on the Registrar’s Office. These corrective actions and staffing enhancements are expected to strengthen internal controls and prevent similar issues in the future.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Ot...
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace HVAC equipment and install windows in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $696,118 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 . Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will comply with Bacon Davis on future projects using federal funds.
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