Corrective Action Plans

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2025-003: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency) Corrective Action: The College updated its award notification process, which took effect for the Spring 2025 term. All current and future award notifications...
2025-003: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency) Corrective Action: The College updated its award notification process, which took effect for the Spring 2025 term. All current and future award notifications now comply with 34 CFR 668.165(a)(1). Including the required information regarding when Title IV funds will be disbursed. Referencing the academic calendar, which clearly identifies the official disbursement dates for the term. To prevent recurrence of this finding, the College has implemented the following permanent measures: • Revised Award Notification Templates: All digital and physical award notification templates have been permanently updated to include dedicated fields for the disbursement date or a direct, clear reference to where the student can find the disbursement schedule. • Enhanced Pre-Release Compliance Review: A mandatory two-step review process has been added to the award notification workflow. This step verifies that all notifications meet the “amount, how, and when” Title IV disclosure requirements before they are sent to students. • Mandatory Staff Training: All Financial Aid staff have received and will receive annual training refreshers on the current federal notification requirements, specifically emphasizing the timing of disbursement disclosure, and the use of the updated, compliant templates. • Ongoing Monitoring and Internal Audits: The College will implement a quarterly internal review process where a sample of student award notifications will be checked for accuracy and full compliance with 34 CFR 668.165(a)(1) to ensure sustained adherence. Anticipated Completion Date: 6/30/2026 Contact Person: Joyce Lubeck-Sonenberg
2025-002: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: The College has taken the following actions to implement the required additional control and ensure accurate tuition and fees reporting in the FISAP. • Systemic Data Isolation Control: The College has c...
2025-002: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: The College has taken the following actions to implement the required additional control and ensure accurate tuition and fees reporting in the FISAP. • Systemic Data Isolation Control: The College has collaborated with its Institutional Research and Business Office staff to develop and implement a new report or query within the Student Information System (SIS). – This new control will automatically isolate and extract tuition and fees revenue only for students who meet the Section D criteria (regular students enrolled in credit-bearing classes). – This ensures that non-eligible tuition (e.g., non-credit, high school) is systematically excluded from the FISAP input data. • Segregation of Duties and Dual Review: The process for FISAP preparation has been revised to include a required dual-review step: – The Financial Aid Office will prepare the draft FISAP data using the new controlled data isolation report. – The Controller will perform a mandatory secondary verification of the total tuition and fee revenue reported in Part II, Section E, against the specific data extracted by the new systemic report. • Training and Procedure Documentation: Financial Aid and Business Office staff involved in the reporting process have been trained on the updated FISAP instructions and the mandatory use of the new systemic control to calculate Section E tuition and fees. The new control procedure has been documented in the College’s official FISAP preparation manual. Each different entity has the detailed instructions from the FISAP information. Anticipated Completion Date: 9/30/2025 Contact Person: Joyce Lubeck-Sonenberg
2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guid...
2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guidelines. Key corrective steps include: • Policy Revision: Formally updating institutional policies (Sections 10 and 3.11) to clarify and align the reporting roles of the Registrar and Financial Aid, mandating specific timelines for all status changes, including withdrawals. • Strengthened Internal Controls: Establishing a mandatory dual-verification process for withdrawal effective dates and R2T4 alignment and implementing weekly NSLDS monitoring by Financial Aid and monthly Registrar–Financial Aid reconciliation meetings. • Documentation and Training: Improving documentation standards, including a centralized digital archive, and providing mandatory joint cross-office training on NSLDS rules, SSCR error resolution, and accurate, effective date determination. Anticipated Completion Date: 4/30/2026 Contact Person: Joyce Lubeck-Sonenberg
The Director of Business Services will review bank reconciliations on a monthly basis to ensure everything is accurate and appropriate. On a weekly basis the Director of Business Services holds business office meetings with his staff to review opportunities for continuous improvement within the busi...
The Director of Business Services will review bank reconciliations on a monthly basis to ensure everything is accurate and appropriate. On a weekly basis the Director of Business Services holds business office meetings with his staff to review opportunities for continuous improvement within the business office. The Director of Business Services also reviews financial activity on a monthly basis for any material discrepancies in the accounts. After the checks are approved, they are mailed out. In prior years, the Board Finance Committee randomly pulled checks for review. Current practice is that all Board members get a copy of the check register for the period between board meetings and ask questions about any expenditures they want additional information for. All expense reports are currently being countersigned. The budget to actual comparisons are reviewed by the Board at least annually, but it is not on based on a set schedule. The Director of Business Services provides financial updates to the Board of Education on a monthly basis. The Director of Business Services reviews employee contracts (professional staff) and rates of pay (non-professional staff) to ensure the correct rate is being paid to each employee. District is willing to accept the risk.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.
As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.
As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.
As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.
As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.
Planned Corrective Action: Lake Erie College continues to review its operations and explore new partnerships to improve its financial performance. Some examples include: • Expanding marketing efforts to include high school Sophomores and Juniors creating a three-year enrollment funnel for the first ...
Planned Corrective Action: Lake Erie College continues to review its operations and explore new partnerships to improve its financial performance. Some examples include: • Expanding marketing efforts to include high school Sophomores and Juniors creating a three-year enrollment funnel for the first time in college history. • Increase net tuition revenue by re-modeling financial aid strategies. • Eliminate academic programs and related faculty personnel for majors with declining enrollment. • Maximize enrollment in the new, market-savvy majors added for fiscal year 2026. • Make a comprehensive 9% cut to the fiscal year 2026 unrestricted operating budget. • Enforcing our residency requirement and meal plan enrollment to meet our budgeted revenue from auxiliaries. • Solicit grants from state, county, and local government agencies for facility projects and scholarship awards. • Continue to increase fundraising projections by engaging new donors and board members. Anticipated Completion Date: The elimination of academic programs and related faculty personnel took place at the end of the Spring 2025 term. The other items will be ongoing throughout the fiscal year. Responsible Contact Person: Jacalyn Kovach, Vice President of Finance
U.S. Department of Health and Human Services Maternal, Infant and Early Childhood Home Visiting Grant Program – Assistance Listing No. 93.870 Congressional Directives Grant Program – Assistance Listing No. 93.493 Recommendation: Develop and implement an internal control framework that ensures retent...
U.S. Department of Health and Human Services Maternal, Infant and Early Childhood Home Visiting Grant Program – Assistance Listing No. 93.870 Congressional Directives Grant Program – Assistance Listing No. 93.493 Recommendation: Develop and implement an internal control framework that ensures retention of evidence documenting the procedures performed to verify that vendors are not suspended, debarred, or otherwise excluded from conducting business before The Village for Families & Children, Inc. and Subsidiaries procuring their services. Program management should either obtain certifications from applicable vendors or maintain sufficient documentation of their review of the System for Award Management (SAM) website. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Village will establish a standardized process to retain proof of its suspension and debarment review. Compliance with the debarment regulations will be achieved by one of the following methods: 1.) Capturing a screenshot of the verification performed on the System of Award Management (SAM) Exclusions database at SAM.gov, 2.) Obtaining a certification from the entity, or 3.) Including a clause or condition in the agreement related to the covered transaction. The compliance requirements and procedures will be communicated to both Leadership and Finance teams. All supporting documentation will be retained either within the Finance Department or in the respective program records. Name(s) of the contact person(s) responsible for corrective action: Marjorie Loring Planned completion date for corrective action plan: January 31, 2026
Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account
Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account
In response, the District agrees and intends to continue to provide supervision and monitor accounting information and operations including obtaining explanations for variances from unexpected results and work to increase segregation of duties. In addition to monthly review and Board approval of the...
In response, the District agrees and intends to continue to provide supervision and monitor accounting information and operations including obtaining explanations for variances from unexpected results and work to increase segregation of duties. In addition to monthly review and Board approval of the voucher list, detailed check register, and itemized revenue and expenditure statements relative to the yearly approved district budget, the Administrator will also review the monthly bank reconciliations, payroll records, and accounting information to determine if expectations are being met, as well as to obtain explanations for any variances.
Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will verify vendors are not suspended or debarred prior to entering into covered transactions.
Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will verify vendors are not suspended or debarred prior to entering into covered transactions.
Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will conduct a documented review of monthly claim reports.
Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will conduct a documented review of monthly claim reports.
Management should insure the required monthly deposits into the reserve for replacement account are made in a timely manner.
Management should insure the required monthly deposits into the reserve for replacement account are made in a timely manner.
Management is in process with the insurance company to obtain a fidelity bond or employee dishonesty coverage policy in order to meet the requirements of the Regulatory Agreement.
Management is in process with the insurance company to obtain a fidelity bond or employee dishonesty coverage policy in order to meet the requirements of the Regulatory Agreement.
2025-005 - Material Weakness and Material Noncompliance - Allowable Costs Condition: Federal revenues and expenses reported on the Schedule of Expenditures of Federal Awards should only include eligible expenses that occurred within the current fiscal year. Corrective Action Plan: The Village experi...
2025-005 - Material Weakness and Material Noncompliance - Allowable Costs Condition: Federal revenues and expenses reported on the Schedule of Expenditures of Federal Awards should only include eligible expenses that occurred within the current fiscal year. Corrective Action Plan: The Village experienced some staff turnover in the prior fiscal year. In addition, the Village has not historically been subject to single audits, which created some challenges with the preparation of the Schedule of Expenditures of Federal Awards. Going forward, the Village has a better understanding of the requirements for completing the Schedule.
2025-004 - Significant Deficiency and Noncompliance - Written Federal Policies and Procedures Condition: The Village is required to have in place written federal policies and procedures in compliance with Uniform Guidance 2 CFR 200, which include procurement and suspension/debarment and equipment an...
2025-004 - Significant Deficiency and Noncompliance - Written Federal Policies and Procedures Condition: The Village is required to have in place written federal policies and procedures in compliance with Uniform Guidance 2 CFR 200, which include procurement and suspension/debarment and equipment and real property management. Corrective Action Plan: The Village has drafted a Federal Policy/Procedure document which will be approved by the Village Council in early 2026.
FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Number...
FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal, documented review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis Contact Person Responsible for Corrective Action: Amber Swinehart, Food Services Director Contact Phone Number: 765-759-2592 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Services Director will provide evidence of review for the eligibility parameters from Titan at least once a year prior to the start of the school year Anticipated Completion Date: 6/30/2026
Recommendation: Management should review and update internal controls over reporting requirements to prevent untimely submissions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management reviews reporting deadli...
Recommendation: Management should review and update internal controls over reporting requirements to prevent untimely submissions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management reviews reporting deadlines to ensure timely submissions. Name(s) of the contact person(s) responsible for corrective action: Judy Thomas, CFO Planned completion date for corrective action plan: June 2025
Recommendation: Management should reinforce the requirement for supervisor approval of all timecards prior to payroll processing. This should include training for supervisors and payroll staff on federal timekeeping requirements and implementation of system controls or checklists to ensure approvals...
Recommendation: Management should reinforce the requirement for supervisor approval of all timecards prior to payroll processing. This should include training for supervisors and payroll staff on federal timekeeping requirements and implementation of system controls or checklists to ensure approvals are documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reinforce supervisor approval of all timecards prior to payroll processing. Name(s) of the contact person(s) responsible for corrective action: Judy Thomas, CFO Planned completion date for corrective action plan: June 2026
District has performed audit/adjustments/journal entries as directed. Additionally, accounting procedures/resources have been updated to avoid need for adjustments on further audits. In particular, the district's annual grant tracking spreadsheets have been updated to summarize the specific amount o...
District has performed audit/adjustments/journal entries as directed. Additionally, accounting procedures/resources have been updated to avoid need for adjustments on further audits. In particular, the district's annual grant tracking spreadsheets have been updated to summarize the specific amount of reimbursement that should be desposited to each accounting fund which will allow the bookkeeper to more easily verify total grant throughout the year and at year end.
Finding 1168633 (2025-001)
Material Weakness 2025
Department of Education Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the thir...
Department of Education Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in business process review and implement redesigns as necessary. Management is committed to ensuring consistent application of policies and procedures so that enrollment reporting and oversight of third-party service providers result in accurate and timely reporting by the third-party service provider. Although the third-party service provider holds a national monopoly on enrollment reporting and other institutions of higher education face similar reporting issues by the third-party service provider, Management believes that review of internal processes over enrollment reporting will mitigate accuracy and timeliness errors made by the third-party service provider. These measures will help ensure compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: February 28, 2026
The District will review the general ledger and compare to expenditure reports to ensure agreement before the reports are submitted.
The District will review the general ledger and compare to expenditure reports to ensure agreement before the reports are submitted.
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