Corrective Action Plans

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Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that supports accurate and timely financial reporting in future periods.
Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that supports accurate and timely financial reporting in future periods.
Finding 1175244 (2025-001)
Material Weakness 2025
FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat findi...
FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat finding from the prior year; however, the finding identified for one student out of the forty students selected was prior to the implementation of the University’s Corrective Action Plan on January 31, 2025. The University previously addressed this issue and implemented a corrective action plan that included updating our reporting frequency and enhancing our data review processes as follows: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. The previous institutional practice did not include reporting program-level data for these terms given that said terms do not involve federal financial aid. This change ensures that all program-level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer reviews a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer summarizes the findings and shares them with the Associate Registrar and Registrar for a secondary review. Any necessary edits are made, followed by a review of an additional 25 students to ensure accuracy. We believe the corrective action steps are critical in ensuring accurate reporting and preventing this issue in the future, and we believe they have been effectively implemented. We believe that the fact that only one of forty students selected was reported incorrectly is an indication that our corrective action plan has been effective. Completion Date: January 31, 2025
This district has implemented a process where meal counts are reviewed and verified by the Business Office. Each month the business office receives a copy of the meal claim along with all backup with meal counts. The business office reviews the meal counts, verifies the totals and then verifies that...
This district has implemented a process where meal counts are reviewed and verified by the Business Office. Each month the business office receives a copy of the meal claim along with all backup with meal counts. The business office reviews the meal counts, verifies the totals and then verifies that the totals match the claim for reimbursement. Any discrepancies found are reported to the Cafeteria Manager for corrections to be made to the claim reimbursement.
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unadjusted Rental Rates Recommendation: Adjust rental rates immediately, and request adjustment on next HAP Voucher to begin repayment. Ensure proper training of employees, prepare the budget worksheet as soon as possib...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unadjusted Rental Rates Recommendation: Adjust rental rates immediately, and request adjustment on next HAP Voucher to begin repayment. Ensure proper training of employees, prepare the budget worksheet as soon as possible and promptly read all correspondence for HUD and forward to management company. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Amounts will be adjusted over the next few HAP voucher to repay HUD and adjust rental rates on the next voucher. Name(s) of the contact person(s) responsible for corrective action: Stacy Lawson, CFO Planned completion date for corrective action plan: June 30, 2026
Management’s Response – Management acknowledges the error and agrees to the amount owed for the overpayment of property management fees and have updated their procedures to ensure future compliance. The Project was reimbursed for the overpayment as of the independent auditor’s report date.
Management’s Response – Management acknowledges the error and agrees to the amount owed for the overpayment of property management fees and have updated their procedures to ensure future compliance. The Project was reimbursed for the overpayment as of the independent auditor’s report date.
Corrective Action Plan Finding No. 2025-002 Unsupported claimed expenditures Condition – The District claimed expenditures in excess of amounts that could be supported by the Accounting records by $77,940. Plan – The District will implement a policy that aligns grant expenditures as closely as possi...
Corrective Action Plan Finding No. 2025-002 Unsupported claimed expenditures Condition – The District claimed expenditures in excess of amounts that could be supported by the Accounting records by $77,940. Plan – The District will implement a policy that aligns grant expenditures as closely as possible with the District’s fiscal year. Reports from the accounting software system that are utilized to prepare expenditure claims will be reviewed, reconciled, and approved by an appropriate member of management prior to final submission. Supporting documentation for each grant expenditure claim submission will be maintained electronically for future reference. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Christopher Whelton, Director of Fiscal Services/CSBO
Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: T...
Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: The corrective action plan will be implemented by June 30, 2026. Corrective Action Plan: We have re-established automated enrollment report generation through our SIS, which is now configured to generate enrollment reports for submission to the National Student Clearinghouse (NSC). Before current reports can be submitted, we are required to submit manually created enrollment reports for each missed reporting period from December 2024 through December 2025. Preparation of these reports is currently underway, and we expect to resume submissions on our established enrollment reporting schedule no later than the end of the Spring 2026 semester.
Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is rep...
Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is reporting information to the National Student Clearinghouse (NSC) servicer but the information is failing to link up to their NSLDS record resulting in her record ultimately not being reported. Corrective Action Plan: Although the University is not able to prevent or resolve rejected records directly when they occur for this reason, we can provide additional information to the Clearinghouse that may allow them to resolve the issue. This sometimes requires requesting that the student provide additional documents and/or submitting information to the Clearinghouse for their review. Rejected records are reviewed by the University after each submission. In addition to this initial review, we have added additional reject tracking in our database. This allows us to better monitor and follow up on records with this issue while we wait for needed information or for the Clearinghouse to review additional information we have submitted. Completion Date: 9/17/2025 Name(s) of Contact Person(s) Responsible for Corrective Action: Jill Austin, CRM Administrator
Finding Identification: 2025 – 001 Federal – Child Nutrition Cluster #50000 Name of contact person: Bricki McNulty Corrective Action: Upon identification of the finding, the Child Nutrition Director immediately contacted the Tri-County Co-op to obtain the formal "Buy American" certification and stat...
Finding Identification: 2025 – 001 Federal – Child Nutrition Cluster #50000 Name of contact person: Bricki McNulty Corrective Action: Upon identification of the finding, the Child Nutrition Director immediately contacted the Tri-County Co-op to obtain the formal "Buy American" certification and statement for the 2024-25 school year. Upon discovery that a formal statement was not currently on file from the vendors for that specific period, the SFA took proactive measures to secure the appropriate certification for the 2025-26 school year to ensure immediate and future compliance. To prevent a recurrence of this finding, the Child Nutrition Director will be responsible for verifying and obtaining the updated "Buy American" certification from the Tri-County Co-op at the start of every school year. The School Food Authority (SFA) remains committed to purchasing domestic commodities and products to the maximum extent practicable. To support this, the Child Nutrition Director will oversee the continued use of the Buy American Exception Log. This log will be used to document any non-domestic items—such as bananas or other seasonal fruits not grown in the U.S. in sufficient quantities—including the specific justification (availability or price) for each exception. By integrating these steps into our annual administrative calendar, the SFA ensures that all food served in the National School Lunch and Breakfast Programs meets the domestic requirements mandated by 7 CFR 210.21(d). Proposed Completion Date: September 2025
The City agrees with the finding and will revise its procurement procedures and train staff to ensure verification is completed and retained for all federally funded procurements.
The City agrees with the finding and will revise its procurement procedures and train staff to ensure verification is completed and retained for all federally funded procurements.
Contact Person Naomi Obrigewitch, Accounting Manager Corrective Action Plan The current process of completing the annual IDEA, Part B budget along with the corresponding time and effort certifications were reviewed by Naomi Obrigewitch and the grant director, Sheri Twist, Director of Student Service...
Contact Person Naomi Obrigewitch, Accounting Manager Corrective Action Plan The current process of completing the annual IDEA, Part B budget along with the corresponding time and effort certifications were reviewed by Naomi Obrigewitch and the grant director, Sheri Twist, Director of Student Services. It was realized that an additional step of communication between the director and the grant specialist who processes the time and effort certifications needs to happen at the beginning of the fiscal year when the budget is created. The director will ensure the IDEA, Part B salary breakdown is forwarded to both the grant specialist and the payroll manager. This will ensure the federal grant guidelines are met. Completion Date On-going
The District is updating the contract templates to include the missing federal provisions identified by the auditors. Additional training will be provided to all staff involved in federal program management and procurement.
The District is updating the contract templates to include the missing federal provisions identified by the auditors. Additional training will be provided to all staff involved in federal program management and procurement.
The District has implemented new procedures to ensure time and effort reporting is completed timely and accurately. In addition, all journal entries will be reviewed prior to posting to ensure the expenditures are allowable to the program.
The District has implemented new procedures to ensure time and effort reporting is completed timely and accurately. In addition, all journal entries will be reviewed prior to posting to ensure the expenditures are allowable to the program.
District is committed to strengthening internal controls and has already begun implementing procedures such as reporting actuals only and retaining the records in a centralized place with back up documents to ensure compliance with the CARES Act and 2 CFR 200.333.
District is committed to strengthening internal controls and has already begun implementing procedures such as reporting actuals only and retaining the records in a centralized place with back up documents to ensure compliance with the CARES Act and 2 CFR 200.333.
The District will implement a new asset management software program and will also conduct a district-wide physical inventory starting in the Spring of 2026 In addition, the Business Office will implement a new review process to ensure compliance with 2 CFR §200.313.
The District will implement a new asset management software program and will also conduct a district-wide physical inventory starting in the Spring of 2026 In addition, the Business Office will implement a new review process to ensure compliance with 2 CFR §200.313.
The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and ...
The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and corrected any findings. As a means of maintaining compliance under the Heightened Cash Monitoring 1 Payment Method (HCM1) as described under 34 C.F.R. § 668.162(d)(1), Keystone first makes disbursements to eligible students and parents and pays any remaining credit balances before it requests or receives funds for the amount of those disbursements from the Department. The College’s practices and internal controls for Title IV, HEA program funds received from the Department reflect the compliance criteria as required.
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Per the compliance requirements, transactions should be made only with the vendors who are not suspended or debarred. Condition : Out of 8 vendors tested, we noted that there was no proper documentation maintained...
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Per the compliance requirements, transactions should be made only with the vendors who are not suspended or debarred. Condition : Out of 8 vendors tested, we noted that there was no proper documentation maintained for eight vendors showing that the vendor was not suspended or debarred. Management’s Response : Columbus NCORP acknowledges vendors were not confirmed to have not been suspended or debarred. Columbus NCORP is updating its internal policies to clearly include this requirement so that all future purchases meeting this requirement are properly documented and compliant with grant guidelines. Columbus NCORP staff directly responsible for grant management will also continue to attend training sessions to strengthen their knowledge of grant reporting, grant requirements, and compliance responsibilities. Anticipated Completion Date: January 31, 2026
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : All deposits should be supported by detailed documentation, properly recorded and retained as per the internal controls in place in the organization. Condition : Detailed supporting documentation was not found for...
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : All deposits should be supported by detailed documentation, properly recorded and retained as per the internal controls in place in the organization. Condition : Detailed supporting documentation was not found for three sampled deposits and three other deposits could not be traced to bank statements. Management’s Response : Columbus NCORP will retain all support for cash receipts moving forward. Anticipated Completion Date: January 31, 2026
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Cash disbursements should be approved and reviewed as per the internal controls in place in the organization and the related documentation should be retained. Condition : No supporting documentation could be locat...
Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Cash disbursements should be approved and reviewed as per the internal controls in place in the organization and the related documentation should be retained. Condition : No supporting documentation could be located for three of the expenses selected for testing. Management’s Response : Columbus NCORP will retrain all support for cash disbursements moving forward. Anticipated Completion Date: January 31, 2026
The District will implement procedures to ensure that Davis-Bacon language is included for future projects with contractors or subcontractors to work on projects in excess of $2,000 financed by federal assistance funds.
The District will implement procedures to ensure that Davis-Bacon language is included for future projects with contractors or subcontractors to work on projects in excess of $2,000 financed by federal assistance funds.
The District will implement procedure to ensure that grant activity is charged during the proper period and sufficient documentation is maintained.
The District will implement procedure to ensure that grant activity is charged during the proper period and sufficient documentation is maintained.
FINDING 2025-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awar...
FINDING 2025-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). The Town did not verify that vendors were not suspended or debarred by checking the System for Award Management (SAM). Statement of Concurrence or Nonconcurrence: The Town agrees with the audit finding. Corrective Action: The Town will ensure vendors are not suspended or debarred by checking the System for Award Management (SAM) and maintain documentation showing that verification. Name of Contact Person: Ann Marie Rheault, Director of Finance (860) 738-6961. Projected Completion Date: Policy already implemented.
Finding No. 2025-001: Segregation of Duties and Oversight – Payroll - Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President Actions were taken to correct this finding immediately after the issuance of the FY2024 audit report in March...
Finding No. 2025-001: Segregation of Duties and Oversight – Payroll - Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President Actions were taken to correct this finding immediately after the issuance of the FY2024 audit report in March 2025. As indicated in the FY2025 audit report, this weakness was noted for the period from July 2024 through March 2025. The weakness was corrected after March 2025 with the following actions: Preparation of timesheets and allocation of time prepared by the finance department with respect to federal grant awards are reviewed and approved by the department leaders where the federal grant dollars are being spent.Additionally, for better segregation of duties for financial reporting and grant reporting the following controls were added: The finance department instituted a monthly financial reporting package to be sent to the President of the organization which includes the monthly financial statements and any significant adjustments in the previous period. President will review and approve the packet monthly. The head of the finance department reviews all general ledger detail, a listing of all journal entries made, and significant accounts reconciliations, done by finance department staff. Aged payables and receivables are reviewed by the team internally and reported periodically to the President. Finally, reporting also includes an update to the Schedule of Federal Awards and other significant grant reporting done in conjunction with the advancement team. An executive member of management, reviews the federal grant reports prepared by the finance team prior to submission. In addition, UCD hired a full-time CPA Controller in April 2025 to manage and oversee compliance for the organization and ensure the timeliness of reporting. Expected Completion Date: 7/1/2025 Finding No. 2025-002: Reporting – Material Weakness in Internal Control over Compliance Contact for Corrective Action: Matt Bergheiser, President See Plan for Finding No. 2025-001, same plan applies here. Expected Completion Date: 7/1/2025
Housing Authority of the County of Howard respectfully submits the following corrective action plan for the year ended June 30, 2025. Responsible Official: Mr. Ross Allen, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Aud...
Housing Authority of the County of Howard respectfully submits the following corrective action plan for the year ended June 30, 2025. Responsible Official: Mr. Ross Allen, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended June 30, 2025 Oversight Agency: U.S. Department of Housing and Urban Development The finding from June 30, 2025, audit is discussed below. The finding is numbered to correspond to the auditing findings disclosed in Sections B and C of the Schedule of Findings and Questioned Costs. C. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT 2025-01 Family file Deficiencies 14.850 Public and Indian Housing Program Criteria and Criteria: The Authority’s purpose for existence is to provide decent, safe, and affordable housing to low-income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent to be charged to eligible families. HUD regulations prescribe the content of these family files. These requirements consist of the following: Criteria: Our review of 23 family files revealed the following: a. As a condition of admission or continued occupancy, the tenant and other family members provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. Context: Our review of 23 family files revealed the following: a. One file with a delinquent annual reexamination. b. One file lacked verification of childcare deduction. c. Two files contained rent calculation errors. Effect: Delays in performing annual reexaminations may result in under charging the tenant rent and thus understating dwelling rental income. Deduction for medical expenses and childcare could be overstated without proper verification and could result in an incorrect rental charge to the tenant. Rental calculation errors may result in an incorrect rent charge to the tenant, Recommendation: The Authority should ensure all tenant reexaminations are performed timely. Verification of medical and childcare deductions should be documented with appropriate documentation. The Authority should ensure the proper verified income is used in calculation of rent charges to the tenant. Response: We have modified policies and procedures to ensure all re-examinations are performed timely, appropriate deductions are documented and rental charges are calculated correctly. Views of Responsible Officials and Planned Corrective Actions: We will review tenant’s files for the deficiencies identified above and implement new internal control procedures to correct these conditions. We anticipate a complete resolution of this type of error by February 29, 2026.
Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Karen Miller, Controller, 609-771-2203, Jeanette Vega, Director of Grant Financial Administration, 609-77...
Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Karen Miller, Controller, 609-771-2203, Jeanette Vega, Director of Grant Financial Administration, 609-771-2847 Amy Cuhel-Shuckers, Director, Grants and Sponsored Research, 609-771-3120 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College was unable to provide evidence that certain quarterly and annual performance reports required under the ALN 84.126A grant agreements were submitted timely and with the required approvals. These delays resulted from staffing vacancies, turnover, and insufficient tracking mechanisms for reporting deadlines across the supporting units. The College acknowledges the importance of ensuring accurate and timely performance reporting as required under 2 CFR 200.329 and the underlying award documents. To strengthen compliance, the College will look to implement a centralized reporting and tracking system with automated deadline reminders, incorporate performance reporting reviews into enhanced month-end monitoring procedures, strengthen cross-functional communication and coordination, and expand annual training requirements for all principal investigators and administrative support staff. Additionally, the College added performance-reporting oversight to its monthly Research Administration meetings. The College is also expanding support staff to assist with fiscal and performance monitoring. The College implemented portions of the corrective action beginning in FY25, with remaining actions implemented through December 31, 2026. These improvements are designed to ensure full compliance with sponsor-required reporting timelines going forward. Anticipated Completion Date: December 31, 2026
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