Corrective Action Plans

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The YWCA has developed written procurement policy to comply with the federal requirements and revised existing procedures to maintain evidence that contractors and vendors are not suspended, debarred, or otherwise excluded from participating in federal programs.
The YWCA has developed written procurement policy to comply with the federal requirements and revised existing procedures to maintain evidence that contractors and vendors are not suspended, debarred, or otherwise excluded from participating in federal programs.
Management’s Views and Corrective Action Plan
Management’s Views and Corrective Action Plan
2024‐001: Student Financial Assistance, JFK Muhlenberg School of Nursing and Medical Imaging (“JFKSON”) Oversight & Monitoring
2024‐001: Student Financial Assistance, JFK Muhlenberg School of Nursing and Medical Imaging (“JFKSON”) Oversight & Monitoring
2024-12-31 00:00:00
2024-12-31 00:00:00
Disbursements to or on behalf of others
Disbursements to or on behalf of others
(1a) Management's view: We acknowledge the auditor’s finding regarding the lack of documented student consent for conducting financial aid transactions and providing required disclosures electronically. While students were receiving required notifications via their secure school email accounts and h...
(1a) Management's view: We acknowledge the auditor’s finding regarding the lack of documented student consent for conducting financial aid transactions and providing required disclosures electronically. While students were receiving required notifications via their secure school email accounts and had uninterrupted access to their financial aid information through the student portal, we recognize that federal guidance requires documented, voluntary consent to participate in electronic transactions.
Corrective action: As of Fall 2025, the Financial Aid Office, in collaboration with IT, has implemented an Electronic Consent Agreement that students must review and accept upon their initial login to the student portal through an automated push notification.
Corrective action: As of Fall 2025, the Financial Aid Office, in collaboration with IT, has implemented an Electronic Consent Agreement that students must review and accept upon their initial login to the student portal through an automated push notification.
This agreement clearly explains students’ rights, the voluntary nature of consent, the option to withdraw consent, and the ability to request paper copies at no cost.
This agreement clearly explains students’ rights, the voluntary nature of consent, the option to withdraw consent, and the ability to request paper copies at no cost.
Student responses are now electronically logged with a date and time stamp, providing auditable records of consent.
Student responses are now electronically logged with a date and time stamp, providing auditable records of consent.
For currently enrolled students, we will initiate a one-time consent collection process by sending the agreement via the student portal and school email, requiring acknowledgement before accessing financial aid–related information.
For currently enrolled students, we will initiate a one-time consent collection process by sending the agreement via the student portal and school email, requiring acknowledgement before accessing financial aid–related information.
The Financial Aid Office will monitor compliance on a term-by-term basis to ensure all active students have provided documented consent.
The Financial Aid Office will monitor compliance on a term-by-term basis to ensure all active students have provided documented consent.
Responsible office: Financial Aid Office
Responsible office: Financial Aid Office
Responsible official: Director of Financial Aid
Responsible official: Director of Financial Aid
Effective date: Fall 2025
Effective date: Fall 2025
(1b) Management's view: We acknowledge the auditor’s finding that, for 4 students in the sample, Title IV credit balances were not released within the federally required 14-day timeframe. While the delays were isolated and not reflective of our standard disbursement process, we recognize that any de...
(1b) Management's view: We acknowledge the auditor’s finding that, for 4 students in the sample, Title IV credit balances were not released within the federally required 14-day timeframe. While the delays were isolated and not reflective of our standard disbursement process, we recognize that any delay is a compliance issue. The impacted students ultimately received their refunds, and no student was financially harmed.
Corrective action:
Corrective action:
Effective Fall 2025, the Financial Aid and Student Accounts Offices have jointly implemented a tracking and escalation process to ensure all Title IV credit balances are identified and refunded within the required 14 days.
Effective Fall 2025, the Financial Aid and Student Accounts Offices have jointly implemented a tracking and escalation process to ensure all Title IV credit balances are identified and refunded within the required 14 days.
A weekly reconciliation report is now generated by Student Accounts and reviewed by the Financial Aid Office to confirm that no credit balances remain unresolved beyond the allowable period.
A weekly reconciliation report is now generated by Student Accounts and reviewed by the Financial Aid Office to confirm that no credit balances remain unresolved beyond the allowable period.
Staff involved in the refund process have received additional training on Title IV requirements, with specific emphasis on the 14-day refund timeline.
Staff involved in the refund process have received additional training on Title IV requirements, with specific emphasis on the 14-day refund timeline.
The Financial Aid Director (or designee) will conduct quarterly spot checks of student account activity to verify compliance.
The Financial Aid Director (or designee) will conduct quarterly spot checks of student account activity to verify compliance.
Responsible offices: Student Accounts and Financial Aid
Responsible offices: Student Accounts and Financial Aid
Responsible officials: Student Billing Coordinator and Director of Financial Aid
Responsible officials: Student Billing Coordinator and Director of Financial Aid
(1c) Management’s view: We acknowledge the auditor’s finding that documentation of anticipated loan amount and disbursement date notifications was not available for the students selected. During the review period, students were notified of their loan eligibility through award letters and had continu...
(1c) Management’s view: We acknowledge the auditor’s finding that documentation of anticipated loan amount and disbursement date notifications was not available for the students selected. During the review period, students were notified of their loan eligibility through award letters and had continuous access to their loan amounts, scheduled disbursements, and account activity through the secure student portal. However, a separate notification specific to anticipated loan amounts and disbursement dates was not consistently generated and retained as documentation. It is important to note that:
All disbursements were made within regulatory timeframes.
All disbursements were made within regulatory timeframes.
The gap was in documented communication, not in the accuracy or timeliness of disbursements.
The gap was in documented communication, not in the accuracy or timeliness of disbursements.
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