Corrective Action Plans

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Finding 2025-001 – Significant Deficiency over Internal Controls related to Debarment Compliance – ARA – 21.027 Recommendation: Habitat should have the required certifications completed annually to ensure compliance with regulations and adherence to internal policies. Corrective Action: We have alre...
Finding 2025-001 – Significant Deficiency over Internal Controls related to Debarment Compliance – ARA – 21.027 Recommendation: Habitat should have the required certifications completed annually to ensure compliance with regulations and adherence to internal policies. Corrective Action: We have already implemented procedures to ensure the certifications are signed. Commencing in October 2024 we began taking steps to implement our corrective action plan. In 2025 we performed internal audits to ensure compliance and significant effort has been made to ensure the proper documentation is obtained and retained. Going forward we will continue to educate and train those involved with these processes and perform internal audits to ensure processes are functioning as designed. Personnel Responsible for Corrective Action: Shelly Dillow, SVP of Accounting and Finance and Paul Harvey, SVP of Construction Anticipated Completion Date for Corrective Action: The Corrective Action has already been implemented as of the date of this report. If there are questions regarding this corrective action plan, please call Shelly Dillow, SVP of Accounting and Finance, at (615) 942-1264. Sincerely, Habitat for Humanity of Greater Nashville Shelly Dillow, SVP of Accounting and Finance Paul Harvey, SVP of Construction
Management agrees with the finding. The weakness occurred due to the implementation of a change in the accrual process not initially being fully documented as an additional task in the billing workflow. Our corrective action plan is as follows: • Rectify the financial impact of the identified duplic...
Management agrees with the finding. The weakness occurred due to the implementation of a change in the accrual process not initially being fully documented as an additional task in the billing workflow. Our corrective action plan is as follows: • Rectify the financial impact of the identified duplicated cost (which is isolated to a single billing period) via a billing adjustment to ensure the net reimbursement of program expenses by the relevant funder is accurate. • Document the rationale for the payroll accrual and its subsequent reversal, and the individual steps required at each stage of the billing and review processes. The CFO, Controller and Grant Billing Manager are responsible for implementing this action plan which will be complete by end of December 2025. In the interim, the payroll accrual and reversal process is being subject to particular and focused review during the monthly billing process to ensure compliance while we implement the long-term plan.
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the in...
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the twelve students selected for enrollment reporting testing, eleven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The College concurs with the finding. The College will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Corrective Action: Annette MacMullin, Director of Financial Aid Anticipated Completion Date: September 18, 2025
The South Central Cooperative Direcctor, Kristi Hilzendeger, is the contact person responsible for the corrective action plan for this finding. This finding is due to the size of the South Central Cooperative, which precludes staffing at a level sufficient to provide an ideal environment for interna...
The South Central Cooperative Direcctor, Kristi Hilzendeger, is the contact person responsible for the corrective action plan for this finding. This finding is due to the size of the South Central Cooperative, which precludes staffing at a level sufficient to provide an ideal environment for internal controls. The Cooperative has developed policies to help monitor the lack of segregatin of duties, but due to the size of the Cooperative it is not feasible, or fiscally responsible to implement anything else at this time. The Cooperative will continue to follow the controls currently in place.
The reports in question will be submitted on time in the future. UACD discussed the timing of reports with the grantor, and they were not concerned with the timing of reports as the reports were completed prior to the submitting of a claim reimbursement and the portal due date is wrong for certain r...
The reports in question will be submitted on time in the future. UACD discussed the timing of reports with the grantor, and they were not concerned with the timing of reports as the reports were completed prior to the submitting of a claim reimbursement and the portal due date is wrong for certain reports, however UACD will be conscious of the actual due date according to the statement of work (SOW).
Funds beyond actual expenses will be credited to the grant on the next claim request. UACD has discussed the mistake with the grantor and they have agreed to this action.
Funds beyond actual expenses will be credited to the grant on the next claim request. UACD has discussed the mistake with the grantor and they have agreed to this action.
Allowable Costs - Special Education Cluster (IDEA) (Significant Deficiency - Other Matter) Description of Finding 1 employee’s pay rate was not updated to reflect the new fiscal year 2025 collective bargaining agreement for their specific union after its implementation in December 2024. Although ret...
Allowable Costs - Special Education Cluster (IDEA) (Significant Deficiency - Other Matter) Description of Finding 1 employee’s pay rate was not updated to reflect the new fiscal year 2025 collective bargaining agreement for their specific union after its implementation in December 2024. Although retroactive pay for hours worked prior to ratification was correctly calculated and paid, the payroll system continued using the prior contract’s rate for all subsequent pay periods through the end of the school year. This occurred due to a failure in the payroll update process following contract implementation. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education will implement additional controls over payroll updates and establish a documented process for updating pay rates immediately after contract ratification. Additionally, review and verification of rate changes, along with periodic reconciliation against approved salary schedules or union agreements, should be performed to ensure accuracy and compliance. Name of Contact Person Christian Strickland, BOE Chief Operating Officer Projected Completion Date June 30, 2025
Procurement - Special Education Cluster (IDEA) (Significant Deficiency) Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. The Board of Education failed to solicit written quotations (in nonc...
Procurement - Special Education Cluster (IDEA) (Significant Deficiency) Description of Finding The Board of Education must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. The Board of Education failed to solicit written quotations (in noncompliance with federal UG for procurements over $10,000) related to a contract paid under the grant. Under local policy, sealed bids should have been obtained for a competitive procurement over $25,000. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education will review its procurement processes to ensure they comply with local policies and federal guidance. Name of Contact Person Christian Strickland, BOE Chief Operating Officer Projected Completion Date June 30, 2025
Reporting - Community Development Block Grants - Non-Entitlement (Significant Deficiency - Other Matter) Description of Finding The Town must adhere to the reporting submission deadlines established in its agreement with the State of Connecticut. The Town is required to submit the CT DOH Form S-730 ...
Reporting - Community Development Block Grants - Non-Entitlement (Significant Deficiency - Other Matter) Description of Finding The Town must adhere to the reporting submission deadlines established in its agreement with the State of Connecticut. The Town is required to submit the CT DOH Form S-730 for each six-month period during the project. The Town did not submit the required report for the period 7/1/2024-12/31/2024 on a timely basis. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Town will review its reporting processes and related controls to ensure that all grantor required forms are timely filed. Name of Contact Person Richard Monico, Director of Administration/Procurement Projected Completion Date June 30, 2025
The Cornbelt Educational Cooperative Business Manager, Pamela Selken is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the Cooperative's business office. Staffing the office at an efficient and financiall...
The Cornbelt Educational Cooperative Business Manager, Pamela Selken is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the Cooperative's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough personnel to provide an ideal environment for the Internal controls. The Administration and Advisory Board is aware of the weakness in internal controls and will continue to develop policies and procedures and provide compensating controls to reduce the risk. We will also communicate this concern with our Board of Directors. The Cornbelt Educational Cooperative did adopt an Internal Controls and Procedures policy on March 13th, 2018 that does address many of these issues, and would ask for consideration reflecting this implementation. This finding will be an ongoing process, requiring continued analysis of processes and procedures in order to minimize the risk.
2025-001 – Significant Deficiency in Internal Controls over Compliance – Time and Effort Documentation
2025-001 – Significant Deficiency in Internal Controls over Compliance – Time and Effort Documentation
Responsible Party: Carmen Rubner, Superintendent
Responsible Party: Carmen Rubner, Superintendent
Corrective Action Plan: Proper time and effort documentation will be required for all employees paid from federal awards to ensure compliance with the District’s federal grant manual and 2 CFR 200.430. This includes clearly stating cost objectives, support for the allocation of payroll, documentatio...
Corrective Action Plan: Proper time and effort documentation will be required for all employees paid from federal awards to ensure compliance with the District’s federal grant manual and 2 CFR 200.430. This includes clearly stating cost objectives, support for the allocation of payroll, documentation of time and effort subsequent to work being performed, and documentation to support an after-the-fact review.
Expected Completion Date: October 2025
Expected Completion Date: October 2025
Name of the Contact Person Responsible for the Corrective Action Plan: Toni Jo Howard, Finance Director. Anticipated Completion Date: June 30, 2026. Corrective Action Plan: The City will ensure that controls are in place to prevent recording duplicate expenditures
Name of the Contact Person Responsible for the Corrective Action Plan: Toni Jo Howard, Finance Director. Anticipated Completion Date: June 30, 2026. Corrective Action Plan: The City will ensure that controls are in place to prevent recording duplicate expenditures
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: Two students were identified who were not awarded the full amount of Pell for which they were qualif...
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: Two students were identified who were not awarded the full amount of Pell for which they were qualified. Both students were registered in the summer session. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College will implement a control process to ensure all semesters are properly identified and taken into account when creating a financial aid package for students. An evaluation will be done to ensure that no students who are eligible for Pell are precluded from receiving it. Anticipated Completion Date: Spring 2026
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – NSLDS Reporting Finding Summary: During review of student statuses on NSLDS, 3 students were noted with a status of “no record found”, and 18 students w...
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – NSLDS Reporting Finding Summary: During review of student statuses on NSLDS, 3 students were noted with a status of “no record found”, and 18 students where the status change was not submitted within the required timeframe established by DOE. Responsible Individuals: Director of Financial Aid and Registrar Corrective Action Plan: The College is coordinating efforts between the Office of Financial Aid and the Registrar’s Office to ensure that timely and accurate reporting of student status is made to NSLDS. Anticipated Completion Date: Spring 2026
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: School is required to provide specific and timely notification when direct loans are being credited ...
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: School is required to provide specific and timely notification when direct loans are being credited to a student’s account. During the review of the direct loans disbursed to students, it was noted that notifications were not sent to students and parents as required. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College is aware of the requirement and the timing of the notification. The College will create a control process to ensure proper notification of loans is sent as required. Anticipated Completion Date: Fall 2025
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: During the review of the calculation of student disbursements, a student was noted whose awards exce...
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: During the review of the calculation of student disbursements, a student was noted whose awards exceed the unmet needs. This over award that was created was in the form of non-Title IV scholarships. Responsible Individual: Director of Financial Aid Corrective Action Plan: The Office of Financial Aid is refining and validating the process for monitoring unmet need and potential over-awarding. The College will put extra effort on ensuring that this situation does not re-occur and ensure that all staff are following the established process to evaluate unmet need. Anticipated Completion Date: Fall 2025
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.003 Student Financial Assistance Cluster – Cash Management and Reporting Finding Summary: During the review of the reconciliation process, it was noted that only the month of January was reconciled as required by the DOE. The...
Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.003 Student Financial Assistance Cluster – Cash Management and Reporting Finding Summary: During the review of the reconciliation process, it was noted that only the month of January was reconciled as required by the DOE. The school is required to reconcile funds received from G5 with actual disbursement records submitted to COD. The school is required to account for any differences between the DOE’s records and the school’s financial and business records. Responsible Individuals: Director of Financial Aid and Director of Finance Corrective Action Plan: The College will implement a process that requires regular reconciliation of funds received with disbursement records submitted to COD. This reconciliation will be reviewed by both the Director of Financial Aid and the Director of Finance to ensure the records are reconciled. Anticipated Completion Date: Fall 2025
Federal Agency Name: Department of Education – Direct Programs ALN #84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provisions – Returns to Title IV Finding Summary: During the review of the return to Title IV funds, there were eleven instances out of thirty i...
Federal Agency Name: Department of Education – Direct Programs ALN #84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provisions – Returns to Title IV Finding Summary: During the review of the return to Title IV funds, there were eleven instances out of thirty in which the Title IV funds to be returned were not calculated and returned if required within the 45-day maximum timeframe allowed. The R2T4 calculations for fall 2024 were not performed until February 2025. Responsible Individual(s): Director of Financial Aid Corrective Action Plan: This finding was due to the turnover of key personnel in the financial aid office during the academic year. Staffing in the office is currently stable and properly trained on regulations and the timing requirements and calculation of Return to Title IV. College is developing and refining a process to review and return Title IV funds in a timely manner. The calculations for subsequent semesters have been made in a timely manner. Anticipated Completion Date: Fall 2025
Condition: It was noted that the District did not hold consultation with private schools where students that live within the districh boundaries attend. Even though there are no private high schools in the district boundaries, the District should make an effort to determine if there are any students...
Condition: It was noted that the District did not hold consultation with private schools where students that live within the districh boundaries attend. Even though there are no private high schools in the district boundaries, the District should make an effort to determine if there are any students attending a private high school outside of the district boundaries. This process should be documented so it can be reviewed during future audits. Plan: Management will implement procedures to ensure that the consultation with private schools, if any and required documentation is completed. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Beth Reich, CSBO/Business Manager Management Response: N/A
Condition: It was noted that the District did not complete the documentation of personnel expenses. Plan: Management will implement procedures to ensure that the documentation of personnel expense is completed. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Beth Reich, CSBO/Busine...
Condition: It was noted that the District did not complete the documentation of personnel expenses. Plan: Management will implement procedures to ensure that the documentation of personnel expense is completed. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Beth Reich, CSBO/Business Manager Management Response: N/A
Condition: During the course of the audit, various applications were found to be imporperly completed and/or the status was improperly determined. There was also an audit conducted by the State in the current year which found the same conditions to be true. Plan: The District has received guidance f...
Condition: During the course of the audit, various applications were found to be imporperly completed and/or the status was improperly determined. There was also an audit conducted by the State in the current year which found the same conditions to be true. Plan: The District has received guidance from the State, as an audit was performed by them. The staff involved in approving applications has gone through additional training and a checklist was developed to follow and verify accuracy. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Beth Reich, CSBO/Business Manager Management Response: N/A
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Jacob Heuchan, Business Manager Contact Phone Number and Email Address: 317-878-2100, jheuchan@nhj.k12.in.us Views of Responsible Officials: We concur with the finding. Descripti...
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Jacob Heuchan, Business Manager Contact Phone Number and Email Address: 317-878-2100, jheuchan@nhj.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Food Service Director will work together to implement a system of controls surrounding eligibility. The Business Manager and Food Service Director will meet on a regular basis to verify eligibility outcomes to ensure accuracy. Anticipated Completion Date: Immediate. INDIANA STATE
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