Corrective Action Plans

Finding 553481 (2024-003)

Significant Deficiency 2024

Paine College

GA

Significant Deficiency Internal Control / Segregation of Duties

"Finding 2024-003 – U. S. Department of Education (USDE), TRIO Programs (significant deficiency): Information on the federal programs – Upward Bound, FAL No. 84.047A, June 30, 2024; Student Support Services, FAL No. 84.042A, June 30, 2024 Criteria – Federal regulations regarding program requirements...

"Finding 2024-003 – U. S. Department of Education (USDE), TRIO Programs (significant deficiency): Information on the federal programs – Upward Bound, FAL No. 84.047A, June 30, 2024; Student Support Services, FAL No. 84.042A, June 30, 2024 Criteria – Federal regulations regarding program requirements. 34-CFR 645.21 Condition – Non-compliances were noted as more fully described in the context below. Context – The College did not meet the two-thirds requirement for the Upward Bound Program. Per federal regulations, not less than two-thirds of the College's program participants will be lowincome individuals who are potential first-generation college students. Cause – Administrative oversight. Effect – The College’s participation in the Title III and TRIO Programs could be subject to USDE sanctions as applicable. Repeat Finding – Yes. Auditor’s Recommendation – We recommend the College monitor participation for the program to assure all requirements are met. View of Responsible Officials – Prior to the start of the Upward Bound FY2024 (September 1, 2024 - August 31, 2025), there was communication between the Program Director and her USDOE Program Officer regarding the current number of participants being served and the number of low-income & first-generation participants (2/3 requirement) as of August 2024. The Program Director explained that recruitment continues to be a challenge stemming from the Covid-19 pandemic, constant changes/turnover in target school personnel, and low student engagement. The monthly plan to increase participant numbers was shared with and approved by the Program Officer. With this, a Continuation Award was granted on September 5, 2024, without any reduction in funds or stipulations to allow the Program to continue to operate and serve students. Program Staff continue to work hard to increase the number of participants, which directly impacts the 2/3 requirement. Please note that decreased student engagement is a nationwide issue in TRIO.

View Audit 352163

Finding 553477 (2024-002)

Significant Deficiency 2024

Paine College

GA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Sup...

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs 1) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.

View Audit 352163

Finding 553476 (2024-001)

None 2024

Ritter Center

CA

Reporting

Views of Responsible Officials and Planned Corrective Actions The FFR report was submitted late due to the Director of Finance being new to the position and balancing vacancies in the Accounting Manager and Accounts Payable Clerk positions. There were many deadlines backlogged and the FFR report is ...

Views of Responsible Officials and Planned Corrective Actions The FFR report was submitted late due to the Director of Finance being new to the position and balancing vacancies in the Accounting Manager and Accounts Payable Clerk positions. There were many deadlines backlogged and the FFR report is one of those items. The Center has been experiencing stability in the key positions as well as expanding the department to include a Grants Administrator who will be responsible for grants reporting. Additionally, the Center is working on a Master Calendar of due dates to monitor and stay ahead of reporting deadlines. Person Responsible: Hector Zapeta Position of Responsible Party: Accounting Manager Anticipated Completion: June 30, 2025

View Audit 352161

Finding 553475 (2024-001)

Significant Deficiency 2024

Miles City Eagles Manor

MT

HUD Housing Programs Matching / Level of Effort / Earmarking

Underpayment of the Flex Subsidy Loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these ...

Underpayment of the Flex Subsidy Loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these suggestions as of the date on this report, November 25, 2024. Karen Burkett, the Managing Agent, will work with the Organization to resolve this matter. The anticipated completion date is June 30, 2025.

View Audit 352155

Finding 553472 (2024-014)

Significant Deficiency 2024

The Howard University

DC

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet t...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements. Anticipated Completion Date: December 31, 2025

View Audit 352153

Finding 553469 (2024-002)

Material Weakness 2024

The Howard University

DC

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the u...

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. 2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel. Anticipated Completion Date: December 31, 2025

View Audit 352153 Questioned Costs: $1

Finding 553086 (2024-013)

Significant Deficiency 2024

The Howard University

DC

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.305

Name of Responsible Individual: Marchon Jackson, Associate Vice President of Research; Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations; Rawle Howard, Assistant Vice President, Procurement Corrective Action: The process to review subrecipient invoices will be improved b...

Name of Responsible Individual: Marchon Jackson, Associate Vice President of Research; Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations; Rawle Howard, Assistant Vice President, Procurement Corrective Action: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office. Anticipated Completion Date: June 30, 2025

View Audit 352153

Finding 552703 (2024-012)

Significant Deficiency 2024

The Howard University

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.430

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research, Brenda Willis, Senior Executive Director of Financial Grants & Contracts, Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations Corrective Action: A new office is being developed to addres...

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research, Brenda Willis, Senior Executive Director of Financial Grants & Contracts, Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations Corrective Action: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely. Anticipated Completion Date: July 1, 2025

View Audit 352153

Finding 552320 (2024-011)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Period of Performance

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research; Robert Clark, Chief Audit & Compliance Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet...

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research; Robert Clark, Chief Audit & Compliance Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications. Anticipated Completion Date: June 30, 2025

View Audit 352153

Finding 551937 (2024-010)

Significant Deficiency 2024

The Howard University

DC

Equipment & Real Property Management Internal Control / Segregation of Duties

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. Updating the following policies: • Asset Capitalization Policy • Sponsored Progra...

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. Updating the following policies: • Asset Capitalization Policy • Sponsored Program Equipment Management Policy 2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols 3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday 4. Implement an asset management platform to track assets throughout the organization 5. Require intermittent inventory by PIs to confirm assets are available and in use 6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number." 7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel. Anticipated Completion Date: December 31, 2025

View Audit 352153

Finding 551554 (2024-009)

Significant Deficiency 2024

The Howard University

DC

Procurement, Suspension & Debarment

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requis...

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following. 1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed 2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel. 4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly. Anticipated Completion Date: December 31, 2025

View Audit 352153

Finding 551549 (2024-008)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financi...

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.

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Finding 551543 (2024-003)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Co...

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date. Anticipated Completion Date: The correction to the length of each program in Workday was implemented during setup prior to the start of the Fall 2024 semester. There will be a Spring 2025 review performed by the Associate Director for Compliance to ensure the program length is accurately reported and testing shows this issue to be resolved. Each semester, enrollment reporting samples will be selected (approximately) 2 to 3 weeks after the first enrollment file for the semester is sent to NSC. Howard has set up a transmittal calendar with NSC which determines when enrollment files, including the graduate files, are transmitted. Due to work completed regarding the integration of Workday with NSC, Howard worked closely with NSC during Fall 2024 to troubleshoot issues that could delay enrollment files transmission. The schedule for submission of files was setup during this time. Howard currently has a vacancy at the University Registrar position and experienced individuals with Workday user knowledge will be pursued for hire. The hiring date for the University Registrar has not been approximated due to the positional requirement of Workday experience and the newness of the ERP system into the higher education space. The current Interim Registrar has prior University Registrar experience with knowledge of the requirements to be effective in the position.

View Audit 352153

Finding 551540 (2024-005)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Ass...

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Associate Director of Operations & Customer Service; John Hooth, Senior Director of Payroll; Sasha Quinga, Senior Director, Human Resources Information Systems Corrective Action: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services hired a full-time Federal Work Study Coordinator towards the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any FWS students, and the supervisor agreement has been updated as of December 2024 to reflect supervisors signing they understand students are not to have time approved prior to working those hours. The awareness campaign encouraging students to choose the direct deposit option in Workday will begin in late Spring as the Fall 2025 class prepares to enter Howard.

View Audit 352153

Finding 551539 (2024-004)

Significant Deficiency 2024

The Howard University

DC

Cash Management Student Financial Aid

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Robert Muhammad; Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Teshome Metaferiya, Director of Reporting Corrective Action: A st...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Robert Muhammad; Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Teshome Metaferiya, Director of Reporting Corrective Action: A statement of procedure and workflow will be implemented to formally reconcile FWS - Title IV expenses to the general ledger on a monthly basis to ensure timely draws and adjustments. Adjustments and updates to the FISAP including prior year adjustments will be included in the Title IV reconciliation process and communicated immediately. The reconciliations will require two-tier approvals. Anticipated Completion Date: May 30, 2025

View Audit 352153

Finding 551538 (2024-007)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Op...

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Operations; Keynesha Wilson, Treasury Specialist; Kathleen Harrod, Accounts Payable Disbursement Manager; Rawle Howard, Assistant Vice President, Procurement Corrective Action: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester. Anticipated Completion Date: Howard feels this finding has been mitigated and there will be no further findings where students received a Title IV credit balance check past the 14-day deadline. Semester or bi-semester reviews will be completed by Financial Aid to ensure the University is sufficiently meeting the federal requirements for students and/or parents to receive the Title IV credit balance check within 14 days.

View Audit 352153

Finding 551537 (2024-006)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director o...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Educational Computer Systems, Inc. Corrective Action: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15. Anticipated Completion Date: Summer 2025 is the date the University anticipates having liquidated the Perkins program. Cash on Hand will be reported as of June 30 and updated again on October 31. Completion of the FISAP is due September 30, 2025 and final edits to the FISAP are due December 15, 2025. Howard will update the Cash on Hand and tuition and fees as of December 15, 2025 for final submission. The U.S. Department of Education will then review the submitted FISAP for errors or inconsistencies. Should there be no errors or inconsistencies from ED’s review, they will accept the FISAP and begin basing any Excess Liquid Capital return request on the Cash on Hand reported.

View Audit 352153

Finding 551536 (2024-001)

Significant Deficiency 2024

Bay Area Air Quality Management District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.435 § 200.459

View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will contin...

View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will continue to ensure that all supporting travel documentation agrees with the corresponding invoices to maintain compliance and accuracy. Regarding the overstatement of program expenditures, the Air District will initiate the recovery of the identified overcharges by deducting the amount from future reimbursement requests submitted to the Department of Homeland Security (DHS). Specifically, the Air District plans on recovering the $9,316 in overcharges from the contractor for fiscal year ending June 30, 2024. Additionally, the Air District is in the process of reviewing Fiscal Year 2025 invoices to identify any potential overcharges and will request reimbursement from the contractor, as necessary. To strengthen oversight and compliance, the Air District has begun implementing process changes as of February 2025. These changes ensure that consultant invoices align with the terms of the Air District’s contract prior to approval and payment processing. Name: Daniel Meer Title: Manager, Government Outreach & Special Projects Email: dmeer@baaqmd.gov

View Audit 352146 Questioned Costs: $1

Finding 551531 (2024-001)

Significant Deficiency 2024

Alameda Health Consortium

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.

View Audit 352145

Finding 551530 (2024-002)

Significant Deficiency 2024

Monarch Immigrant Services

MO

Eligibility

Finding 2024-002: Significant Deficiency in Internal Control over Compliance of Major Programs Corrective Action Plan: Program audited annually by grantor (HHS-ACF-ORR) without identifying as an issue. Departmental reorganization already underway to realign supervision and reporting across programs....

Finding 2024-002: Significant Deficiency in Internal Control over Compliance of Major Programs Corrective Action Plan: Program audited annually by grantor (HHS-ACF-ORR) without identifying as an issue. Departmental reorganization already underway to realign supervision and reporting across programs. Monarch Immigrant Services will implement a monthly eligibility and documentation review for screened SOT participants with incoming Mental Health Department Director. Name of Responsible Person: Jason Baker, Executive-Director Anticipated Completion Date: May 1, 2025

View Audit 352142

Finding 551525 (2024-002)

Material Weakness 2024

Pontifical Catholic University of Puerto Rico

PR

Reporting

Management agrees with the noted finding. Re-mediating activities and control will be implemented in the next year.

View Audit 352134

Finding 551524 (2024-001)

Significant Deficiency 2024

Pontifical Catholic University of Puerto Rico

PR

Internal Control / Segregation of Duties

Management has already written the basic Security of information Plan as required by 6 C.F.R. 313.3 and 313.4. This plan was sent to the Federal Student Aid (FSA) Cybersecurity Team (CCT). In July 18, 2024, after closing of the fiscal year, the CCT sent a letter stating they had reviewed the univers...

Management has already written the basic Security of information Plan as required by 6 C.F.R. 313.3 and 313.4. This plan was sent to the Federal Student Aid (FSA) Cybersecurity Team (CCT). In July 18, 2024, after closing of the fiscal year, the CCT sent a letter stating they had reviewed the university submission and has determined that the CAP acceptably addresses the auditor finding for audit year 2023. Contracting of an independent third party to carry out a NIST CS IT Risk Assessment and Penetration Testing & vulnerability Assessment for PUCPR was completed. GM Security Technologies, is a qualified Security Assessor Company (QSAC) certified by the PCI Security Council. The initial report for a Pen Test & Vulnerability Assessments report by April 21st,2025. When evaluation is completed, GM Sectec will perform a retest to high/critical remediated vulnerabilities and a guide roadmap mapped to NIST Cyber Security Framework. These assessments are planned to be completed by June 2025

View Audit 352134

Finding 551523 (2024-001)

Significant Deficiency 2024

Suffolk Redevelopment and Housing Authority

VA

HUD Housing Programs Eligibility Significant Deficiency

Finding No. 2024-001 Housing Choice Voucher: Tenant Eligibility – Significant Deficiency Contact Person: Patricia Tyus Executive Director/CEO The Authority's Housing Choice Voucher program was not pulling Earned Income Verifications (EIVs) within 90 days of move-in, as required by HUD regulations....

Finding No. 2024-001 Housing Choice Voucher: Tenant Eligibility – Significant Deficiency Contact Person: Patricia Tyus Executive Director/CEO The Authority's Housing Choice Voucher program was not pulling Earned Income Verifications (EIVs) within 90 days of move-in, as required by HUD regulations. Additionally, the Authority was missing one recertification for a tenant during the audit period and was missing criminal background checks for tenants. These issues were all for tenants at Whitemarsh Point Eagle Landing. CORRECTIVE ACTION: EIV compliance The Nelrod Company was solicited to provide a Compliance Monitor Plan for SRHA. They did not completely prepare what was required for; but focused on SEMAP, and they were delayed with the deliveries in the contract. We discontinue the contractual relationship and implemented the following items in 2024. We have completed the following items: 1. SRHA placed a priority on getting the staff EIV access so that all the staff can pull and print the EIVs 2. HCV added additional EIV procedures to the HCV SOPs 3. Worked with Vista Management (PBV) to ensure the EIV are printed and in the files 4. Management staff completed training for the staff on the following dates: Quality Control file training—02/08/2024; Compliance Training on all processes--09/06/2024; Adjustment Payment Training--10/4/2024; File Compliance Procedures—1/17/2025. TARGET DATE: On-going

View Audit 352125

Finding 551522 (2024-101)

Material Weakness 2024

Gila County

AZ

Procurement, Suspension & Debarment § 200.303

The County will maintain physical documentation that it has verified vendors are not suspended or debarred from doing business with the federal government prior to making purchases and ensure that all employees are trained to verify suspension and debarment and maintain documentation.

View Audit 352123

Finding 551518 (2024-002)

Significant Deficiency 2024

Lemoyne-Owen College

TN

Questioned Costs Student Financial Aid Significant Deficiency

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 68...

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 685.300(b)(5), the College provided reconciliations for the following programs, however the reconciliations were not correct and therefore the programs were not properly reconciled, monthly or annually. a. Federal Pell Grant Program b. Federal Direct Loan Program c. Federal FSEOG Program d. Federal Work Study Program 2. The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the Federal Pell Grant Program. 3. The College distributed the Annual Security and Fire Report (ASR) on October 10th, 2024. PER 34 CFR 668.41, By October 1 of each year, an institution must distribute the ASR to all enrolled students and current employees as described in § 668.46(b). 4. Per HEA, Section 484B and 34 CFR 668.22, one (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement that the college determined the student withdrew. 5. Per HEA, Section 484B & 34 CFR 668.22, three (3) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program post-withdrawal disbursement funds disbursed within the 45-day requirement that the college determined the student withdrew. 6. Per HEA, Section 484B & 34 CFR 668.22, five (5) out of 6 students tested for withdrawals and the return of Title IV funds (R2T4) and the school did not complete the R2T4 calculations correctly. As a result of these inaccuracies, two (2) students were overpaid Pell and Direct Loan (DL) funds in the amount of $612 and one (1) student was underpaid $866 in Pell funds. The following errors occurred: a. Incorrect withdrawal dates were used b. Incorrect dates of determination were used c. Funds that could have been disbursed were incorrectly recorded as funds disbursed The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Title IV reconciliations were prepared. They have been provided to WPG. The College hired an experienced Director of Financial Aid on February 18, 2025. She will ensure the proper reconciliation and management of all financial aid programs and the accurate and timely submission of program reports. The Director of Campus Security has been advised of the deadline for distribution of the Annual Security and Fire Report (ASR).

View Audit 352118 Questioned Costs: $1

Corrective Action Plans

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