Corrective Action Plans

Finding 539094 (2024-001)

Significant Deficiency 2024

DE

Special Tests & Provisions Eligibility Significant Deficiency

View of Responsible Officials: A policy for notifying applicants of changes to Expected Family Contribution (EFC) or financial assistance resulting from the verification process is contained in the Delaware College of Art and Design (DCAD) Approval, Delivery, and Disbursement of Title IV Funds Polic...

View of Responsible Officials: A policy for notifying applicants of changes to Expected Family Contribution (EFC) or financial assistance resulting from the verification process is contained in the Delaware College of Art and Design (DCAD) Approval, Delivery, and Disbursement of Title IV Funds Policies and Procedures in Section III Item d. (previously submitted). Should any of the students’ financial aid change or increase, FAO emails the student Updated Financial Aid Award Letters reflecting the changes. A copy of the student’s Need Analysis/Award Updates is also given to the Bursar. The two other omissions in the finding were correctly noted as not written in DCAD’s policy. No planned corrective action is necessary due to the College’s closure.

View Audit 349799

Finding 539093 (2024-001)

Significant Deficiency 2024

Manhattan School District 114

IL

Reporting

The Finance Director, along with staff, will review and evaluate the reporting requirements of all grants to ensure timely reporting requirements

View Audit 349795

Finding 539092 (2024-001)

None 2024

Town of Brewster, Massachusetts

MA

Reporting Internal Control / Segregation of Duties

February 24, 2025 The Town of Brewster, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Robert E. Brown II, CPA 25 Cemetery Street P.O. Box 230 Mendon, Massachusetts 01756 Audit per...

February 24, 2025 The Town of Brewster, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Robert E. Brown II, CPA 25 Cemetery Street P.O. Box 230 Mendon, Massachusetts 01756 Audit period: The finding from the June 30, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule of expenditures of federal awards. Finding 2024-001 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Town of Brewster’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Brewster was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: The Finance Director reported an incorrect amount of ARPA expenditures on the 2024 Annual ARPA report to the US Department of Treasury. Identification as a Repeat Finding: No Recommendation: The Town of Brewster should complete and submit all required annual reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Responsible for Corrective Plan: The Finance Director will verify amounts are accurate before reporting on the next Annual ARPA report. Estimated Completion Date: Immediately. Action Taken: In reviewing this finding, the Finance Director identified that the Town’s current accounting software automatically updated the date range for a report used to calculate totals for the Recovery Plan Performance Report which resulted in this one-time error. The Finance Director did not notice this mistake at the time, has taken full responsibility, and will only report correct amounts going forward.

View Audit 349789

Finding 539082 (2024-001)

Significant Deficiency 2024

City of Glendale, Arizona

AZ

Procurement, Suspension & Debarment Allowable Costs / Cost Principles HUD Housing Programs

COVID-19 Coronavirus State and Local Fiscal Recovery Fund– Assistance Listing No. 21.027 Recommendation: The City should enhance or modify its internal controls over suspension and debarment, as necessary, to ensure compliance with suspension and debarment provisions. Explanation of disagreement wi...

COVID-19 Coronavirus State and Local Fiscal Recovery Fund– Assistance Listing No. 21.027 Recommendation: The City should enhance or modify its internal controls over suspension and debarment, as necessary, to ensure compliance with suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We provided training to procurement staff about the suspension and debarment requirements of 2 CFR 200.214. Further, we expanded language in the City’s formal soliciation template regarding suspension and debarment and added a specifc step on our solitication timeline checklist to perform SAM checks. Name(s) of the contact person(s) responsible for corrective action Levi Gibson, Budget and Finance Director Planned completion date for corrective action plan: December 2024

View Audit 349783

Finding 539081 (2024-001)

Material Weakness 2024

University of Massachusetts Global-9 Month Audit

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding#2024-001: ...

Finding#2024-001: 40 files were sampled, and 18 files were found to have late reporting. We agree with the findings and have put forward an action plan to ensure this is not a repeat finding in the future. 17 out of 18 students that were part of the findings were reported within the 60 days, however, the program and campus level were not matching in NSLDS. Per the NSLDS Enrollment Reporting Guide, both the campus level enrollment reporting and program-level enrollment reporting should be updated every 60 days. To ensure both program and campus-level enrollments are updated within 60 days, our Registrar will be working closely with the National Student Clearinghouse. We are reviewing each report generated by our system to ensure that the main data elements are found in the report which include: - Student current SSN - OPEID - CIP Code - CIP Year - Credential level - Published Program Length Measurement - Published Program Length - Weeks in Title IV Academic Year - Program Begin Date - Program and Campus Enrollment Status - Special Program Indicator - Program and Campus Enrollment Effective Date - Certification Date In addition, we are carefully reviewing the reports and changing the timing of reporting. One of the 18 students that was part of the findings withdrew and was not reported timely. The university will monitor closely with NSC the timing of files and reporting. Finding #2024-001 Action: Implementation of new control: Registrar to review system generated reports to match NSLDS reporting guides and monitor closely the timing of when files are processed and reported to NSLDS. Name of contact person responsible for corrective action plan: Marilyn Payan, University Registrar Anticipated Completion Date: Currently being implemented, to be completed before 12/31/2024.

View Audit 349782

Finding 539080 (2024-002)

Significant Deficiency 2024

Army West Point Athletic Association, Inc.

NY

Reporting § 200.328

Audit Finding: Pursuant to 2 CFR 200.327 and CFR 200.328 Report Requirements, Army West Point Athletic Association Inc. (“AWPAA”) did not submit its interim performance reports within 30 days after the completion of each reporting period. Root Cause Analysis: During FY2024, AWPAA did not submit it...

Audit Finding: Pursuant to 2 CFR 200.327 and CFR 200.328 Report Requirements, Army West Point Athletic Association Inc. (“AWPAA”) did not submit its interim performance reports within 30 days after the completion of each reporting period. Root Cause Analysis: During FY2024, AWPAA did not submit its quarterly interim performance reports in accordance with the CA requirements. Instead, AWPAA submitted the FY2024 quarterly reports concurrently in October 2024. This was an oversight by the AWPAA & Government Program Management Teams. Corrective Action Plan: To review the interim performance reporting requirements as outline in Section 10B of the Cooperative Agreement and coordinate the timely monitoring and submission of these quarterly reports by the AWPAA Program Management Team. Estimated Completion Date: October 30, 2024 and note: Interim Performance Report for the period ended September 30, 2024 was submitted October 28, 2024 (due by October 30, 2024). Interim Performance Report for the period ended December 31, 2024 was submitted January 29, 2025 (due by January 30, 2025).

View Audit 349781

Finding 539079 (2024-001)

Significant Deficiency 2024

Community Crisis Center

IL

Subrecipient Monitoring Eligibility

Department of Justice 2024-001 Crime Victim Assistance Program Auditor’s Recommendation: We recommend Community Crisis Center, Inc. continue to review its files to ensure that all client files contain the required confidentiality and intake forms. We also recommend Community Crisis Center, Inc. im...

Department of Justice 2024-001 Crime Victim Assistance Program Auditor’s Recommendation: We recommend Community Crisis Center, Inc. continue to review its files to ensure that all client files contain the required confidentiality and intake forms. We also recommend Community Crisis Center, Inc. implement and enforce a policy to obtain the signed forms for all new clients and get any signed forms as soon as possible for any current clients. Additionally, Community Crisis Center, Inc. should conduct regular training and monitoring of employees to ensure confidentiality best practices are followed. Action Taken: Community Crisis center, Inc. will review files to ensure that confidentiality forms and intakes are present on a daily, monthly and quarterly basis for accuracy. In Addtiion, training will be provided to all new staff upon hiring, with quarterly reviews thereafter. If the funding agency has questions regarding this plan, please call me at 847-742-4088.

View Audit 349778

Finding 539078 (2024-003)

Significant Deficiency 2024

Northern Essex Community College

MA

Subrecipient Monitoring

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Corrective Action Plan: The Director of Financial Aid will send an email to all work-study supervisors outlining what has occur...

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Corrective Action Plan: The Director of Financial Aid will send an email to all work-study supervisors outlining what has occurred and reminding them of the consequences of allowing students to work during scheduled class time and approving such time. These consequences include reallocating the funding source for the time worked from work-study to the area’s/department's budget, issuing written warnings to both the student and the supervisor, appointing a new supervisor for the area/department, or revoking the department’s ability to hire work-study students. Going forward, all work-study supervisors will be required to attend an in-person or virtual meeting with the Federal Work-Study Coordinator for an in-depth orientation, rather than completing it online. This meeting will thoroughly cover the program’s guidelines, including how to read a student’s schedule. A second email will be sent to all work-study students from the Director of Financial Aid reminding them of their student obligations, the contract they signed as a student worker, and the requirement that they are not allowed to work during class time. Additionally, going forward, all work-study students will be required to attend an in-person or virtual meeting with the Federal Work-Study Coordinator to review the program's guidelines rather than completing it online. Furthermore, the Director of Financial Aid will coordinate with the Payroll Office to conduct an internal audit of approved 2024-2025 academic year work-study timesheets to ensure compliance with all Federal regulations regarding students working during class time. If any issues are identified during the audit, the appropriate action/s from above will be enforced. Timeline for Implementation of Corrective Action Plan: The emails and in-person/virtual orientations will be implemented by April 2025. The internal audit of approved work-study timesheets will be completed by June 30, 2025. Contact Person Despina Lambropoulos, Director of Financial Aid

View Audit 349777

Finding 539077 (2024-002)

Significant Deficiency 2024

Northern Essex Community College

MA

Questioned Costs Student Financial Aid

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Corrective Action Plan: The Financial Aid Office has a robust policy and procedure for calculating the Return of Title IV (R2T...

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Corrective Action Plan: The Financial Aid Office has a robust policy and procedure for calculating the Return of Title IV (R2T4) Funds. In this particular case, the Financial Aid Counselor who completed the R2T4 calculation inadvertently transposed numbers when adjusting the subsidized student loan that needed to be returned to the U.S. Department of Education. While human error can never be fully eliminated, we take proactive measures in an attempt to avoid mistakes, such as testing the R2T4 process within Banner, our Student Information System (SIS), updating policies and procedures as needed, and providing ongoing staff training. In light of this error, an internal audit will be conducted to review all R2T4 calculations completed to date for the 2024-2025 academic year. Furthermore, staff will be provided additional training on the R2T4 process, reinforcing the importance of attention to detail. The staff member who made the error has been spoken to, and the necessary correction has been made to the student’s account. Timeline for Implementation of Corrective Action Plan: The corrective action plan will be implemented by April 2025. Contact Person Despina Lambropoulos, Director of Financial Aid

View Audit 349777 Questioned Costs: $1

Finding 539074 (2024-001)

Significant Deficiency 2024

Northern Essex Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was...

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was promoted to replace her. During the transition, the new Registrar got behind in submitting Enrollment Reports for Spring 2024. The result of the first report being behind schedule caused a backlog of Enrollment and Error reports which resulted in a delay for the enrollment reports to be sent to NSLDS. The Registrar has made it a priority to submit enrollment reports and error reports in a timely manner (within 24-48 hours) so that they can be submitted to NSLDS within the 60-day timeframe. Timeline for Implementation of Corrective Action Plan: Corrective action plan began immediately when the next semester began. The action plan appears to be successful as there was no backlog of Enrollment/Error reports for Summer 2024, Fall 2024, and into Spring 2025 semester. Contact Person: Registrar – Shawna Lind

View Audit 349777

Finding 539073 (2024-012)

Significant Deficiency 2024

City of Boston

MA

Reporting Internal Control / Segregation of Duties § 200.303

Boston Fire Department has incorporated and implemented proper control procedures around all grant related matter; including but not limited to financial reporting and oversight. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Moni...

Boston Fire Department has incorporated and implemented proper control procedures around all grant related matter; including but not limited to financial reporting and oversight. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539072 (2024-011)

Material Weakness 2024

City of Boston

MA

Questioned Costs Period of Performance Procurement, Suspension & Debarment § 200.303 § 200.308 § 200.309 § 200.403

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776 Questioned Costs: $1

Finding 539070 (2024-010)

Significant Deficiency 2024

City of Boston

MA

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

Boston Public Schools has updated its’ training and guidance for timekeepers. Timekeepers participate in enhanced trainings annually in August in preparation of the new school year. Anticipated Completion Date: August 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants...

Boston Public Schools has updated its’ training and guidance for timekeepers. Timekeepers participate in enhanced trainings annually in August in preparation of the new school year. Anticipated Completion Date: August 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776 Questioned Costs: $1

Finding 539067 (2024-009)

Significant Deficiency 2024

City of Boston

MA

Procurement, Suspension & Debarment Student Financial Aid Allowable Costs / Cost Principles § 200.303 § 200.64 § 200.67

Boston Public Schools has revised its’ eligibility record keeping process to ensure that records are accurate and complete. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle. Anticipated Completion Date: June 30, 2025 Responsible Contact...

Boston Public Schools has revised its’ eligibility record keeping process to ensure that records are accurate and complete. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539066 (2024-008)

Significant Deficiency 2024

City of Boston

MA

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Boston Public Schools has begun to conduct announced and unannounced visits to schools during MCAS testing. These visits include observations of testing locations and test material storage, as well as support when questions arise. Observation notes are stored centrally. Anticipated Completion Date:...

Boston Public Schools has begun to conduct announced and unannounced visits to schools during MCAS testing. These visits include observations of testing locations and test material storage, as well as support when questions arise. Observation notes are stored centrally. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539065 (2024-007)

Significant Deficiency 2024

City of Boston

MA

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Boston Public Schools has updated training for school leaders to review school leader certification of withdrawals. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539064 (2024-006)

Significant Deficiency 2024

City of Boston

MA

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

Boston Public Schools has updated its’ training and guidance for timekeepers. Timekeepers participate in enhanced trainings annually in August in preparation of the new school year. Anticipated Completion Date: August 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants...

Boston Public Schools has updated its’ training and guidance for timekeepers. Timekeepers participate in enhanced trainings annually in August in preparation of the new school year. Anticipated Completion Date: August 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776 Questioned Costs: $1

Finding 539063 (2024-005)

Significant Deficiency 2024

City of Boston

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

The City will implement procedures so that there is documentation of review, approval and submission of FFATA reports. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539062 (2024-004)

Significant Deficiency 2024

City of Boston

MA

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Boston Public Schools Food and Nutrition Services has begun implementing various procedures in order to accurately report meal counts and claims. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.g...

Boston Public Schools Food and Nutrition Services has begun implementing various procedures in order to accurately report meal counts and claims. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539061 (2024-003)

Significant Deficiency 2024

City of Boston

MA

Questioned Costs School Nutrition Programs Cash Management § 200.303

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Co...

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776 Questioned Costs: $1

Finding 539059 (2024-004)

Significant Deficiency 2024

Matchbook Learning Schools of Indiana, Inc.

IN

Reporting Significant Deficiency Internal Control / Segregation of Duties

Response to Finding 2024-004 – Maintenance of Effort 1. Improving Accuracy of the Form 9 Report (Completion: Within 6 months) o Implementing monthly reconciliations to ensure Form 9 expenditures match financial records. o Assigning a dedicated financial officer to oversee and verify Form 9 complianc...

Response to Finding 2024-004 – Maintenance of Effort 1. Improving Accuracy of the Form 9 Report (Completion: Within 6 months) o Implementing monthly reconciliations to ensure Form 9 expenditures match financial records. o Assigning a dedicated financial officer to oversee and verify Form 9 compliance. 2. Strengthening Reporting and Internal Controls (Completion: Within 9 months) o Conducting regular audits of Form 9 data before submission to the Indiana Department of Education. o Developing a standardized reporting checklist to ensure compliance with state and federal MOE requirements.

View Audit 349775

Finding 539058 (2024-001)

None 2024

Kennebec Montessori School

ME

Reporting Matching / Level of Effort / Earmarking

Management will establish more oversight on the submission of data collection form.

View Audit 349774

Finding 539053 (2024-001)

Significant Deficiency 2024

City of Fairhope, Alabama

AL

The City hired grant consultants to manage the compliance and execution of the Airport Improvement grants. The City will review all compliance requirements and grant agreements for applicable requirements. The City has established a review process for grants managed by third parties to ensure fede...

The City hired grant consultants to manage the compliance and execution of the Airport Improvement grants. The City will review all compliance requirements and grant agreements for applicable requirements. The City has established a review process for grants managed by third parties to ensure federal reports are completed accurately and timely. This was implemented March 2025.

View Audit 349771

Finding 539049 (2024-002)

Significant Deficiency 2024

Santa Clara University

CA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-002: Criteria The institution shall require each applicant whose application is selected by the Department of Education to verify the information ...

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-002: Criteria The institution shall require each applicant whose application is selected by the Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. If verification reveals that the student information does not match, the institution must submit corrections to the FAFSA. Corrections and updates can be submitted by the student on the web or by the institution using the FSA Access to Central Processing System Online or the Electronic Data Exchange. Statement of Condition During testwork, KPMG selected 40 students that were selected for verification. Of the 40 students selected for verification test work, one student’s information required for the appropriate Verification Tracking Group was not completed and 6 students had inconsistencies for which corrections were not submitted. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure verifications will now have a second approver who will ensure verifications are completed correctly. Additionally, we also have added additional training to ensure that appropriate second and third checks are implemented. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

View Audit 349756 Questioned Costs: $1

Finding 539047 (2024-001)

Significant Deficiency 2024

Santa Clara University

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the ins...

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that disbursements are reported in a timely manner. Statement of Condition During testwork, KPMG selected 40 students that had Pell Grant or Direct Loan disbursements where the University was required to report student disbursement date to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes award of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. KPMG identified 5 of the 40 students were not reported to COD in a timely manner. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure Direct Loan and Pell Grant disbursements will now be reviewed after each disbursement (Monday, Wednesday, and Friday) and are reported within the Department of Education's requirements. Additionally, we will ensure that the COD Workday outbound and inbound integrations are monitored daily. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

View Audit 349756

Corrective Action Plans

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