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Uniform Data System Reporting – Significant Deficiency 2025-003 Management agrees with the finding and will enhance procedures for the preparation and review of UDS reporting. Management will implement procedures and controls to ensure amounts reported are reviewed for compliance with UDS requiremen...
Uniform Data System Reporting – Significant Deficiency 2025-003 Management agrees with the finding and will enhance procedures for the preparation and review of UDS reporting. Management will implement procedures and controls to ensure amounts reported are reviewed for compliance with UDS requirements prior to submission.
Sliding Fee Discount Documentation and Application of Policies – Significant Deficiency 2025-002 Management acknowledges that supporting documentation used to determine sliding fee discounts should be consistently maintained and guidelines consistently applied. Management will implement procedures a...
Sliding Fee Discount Documentation and Application of Policies – Significant Deficiency 2025-002 Management acknowledges that supporting documentation used to determine sliding fee discounts should be consistently maintained and guidelines consistently applied. Management will implement procedures and controls to ensure required documentation is maintained and that sliding fee discount policies are consistently applied in accordance with established guidelines.
# 1 A revised case review sheet will include a section for caseworkers to document their calculation confirming that verified electronic income and self-attested income are within the 25% guideline. This will show that the comparison was completed and the income used in the eligibility determination...
# 1 A revised case review sheet will include a section for caseworkers to document their calculation confirming that verified electronic income and self-attested income are within the 25% guideline. This will show that the comparison was completed and the income used in the eligibility determination is accurate. An additional section will be added on to the case review sheet in the event the client is self-employed and provided tax returns to determine eligibility. The section will require staff to confirm they used the corrected Adjusted Gross Income (AGI) from the federal tax return when determining eligibility. # 2 All MAGI employees will attend MAGI Policy training and application processing offered through the state. # 3 Renewals will continue to be reviewed by a specialist, supervisor, or administrator. Cases will be returned and corrected when there are errors.
In response to the deficiencies noted in the audit findings referenced above, management has established a comprehensive framework of inter-departmental controls, routine reconciliations, and independent quality assurance testing. To ensure the absolute accuracy and alignment of records, Financial A...
In response to the deficiencies noted in the audit findings referenced above, management has established a comprehensive framework of inter-departmental controls, routine reconciliations, and independent quality assurance testing. To ensure the absolute accuracy and alignment of records, Financial Aid (FA) and Student Accounts (SA) personnel conduct mandatory monthly reconciliation meetings. During this collaborative process, both departments verify that all federal aid disbursements are properly recorded on the student’s ledger with the correct transactional dates, ensuring perfect alignment with records in the COD system. Supplementing this process, the Financial Aid Office performs independent monthly random spot checks of disbursements directly within the COD system to verify that record dates mirror the actual transaction dates on the student accounts ledger. During these same spot checks, FA personnel validate core academic parameters by cross-referencing student enrollment dates and loan period dates against the official institutional academic calendar, while simultaneously reviewing Cost of Attendance (COA) figures to ensure strict adherence to each student's official award letter. To maintain compliance and reporting during non-standard operational shifts, the Financial Aid Office collaborates immediately with Global Financial Services, our third-party servicer, to update federal records in a timely manner whenever academic dates are modified later than normal. Furthermore, to strengthen institutional data integrity and eliminate enrollment reporting gaps, the Financial Aid Office and the Office of the Registrar participated in joint training sessions focused on National Student Clearinghouse (NSC) and NSLDS reporting mechanics to optimize data transmissions between platforms. As an ongoing monitoring control, the Financial Aid Office now executes an independent monthly random sampling of student records directly from NSLDS. This routine sampling allows management to verify that enrollment statuses are being transmitted accurately and seamlessly from the Clearinghouse to NSLDS
The College will implement enhanced controls to ensure that Title IV credit balances are identified, monitored, and refunded within the required 14 day timeframe. The Student Financial Services team will establish a formal credit balance monitoring process. A designated staff member will review stud...
The College will implement enhanced controls to ensure that Title IV credit balances are identified, monitored, and refunded within the required 14 day timeframe. The Student Financial Services team will establish a formal credit balance monitoring process. A designated staff member will review student accounts on a routine basis to identify accounts with credit balances and document the date each credit balance was created. A centralized tracking mechanism will be maintained to identify the required refund deadline and document the date the refund was processed. To provide additional oversight, the following controls will be implemented: • Student accounts with credit balances will be reviewed at least twice weekly. • Each identified credit balance will be recorded on a Credit Balance Monitoring Log that includes the student, date the credit balance occurred, amount, required refund date, actual refund date, and responsible staff member. • Accounts approaching the 14 day deadline will be escalated to Student Financial Services leadership for immediate review and resolution. • The Director of Financial Aid and appropriate Student Accounts staff will conduct a monthly reconciliation and supervisory review to verify that required refunds were completed timely. • Documentation supporting the review and reconciliation process will be retained as evidence that the control was performed. • Staff responsible for financial aid disbursements, student accounts, and credit balance refunds will receive annual training on Title IV credit balance requirements and the College’s internal control procedures. • The Dean of Student Success will conduct periodic management reviews during the first year of implementation to verify that the controls are operating as designed and address any identified exceptions.Because this is a repeat finding from the prior audit year, the College will also review the underlying workflow and Student Information System configuration to determine whether additional automated reporting or alerts can be implemented to reduce reliance on manual identification of credit balances.
The Registrar’s Office maintains primary responsibility for submitting student enrollment statuses to the National Student Clearinghouse (NSC) and providing timely status updates (graduations, withdrawals, and Leaves of Absence [LOA]) to the Financial Aid Office. To ensure the accuracy and integrity...
The Registrar’s Office maintains primary responsibility for submitting student enrollment statuses to the National Student Clearinghouse (NSC) and providing timely status updates (graduations, withdrawals, and Leaves of Absence [LOA]) to the Financial Aid Office. To ensure the accuracy and integrity of these transmissions, the following controls and ongoing systemic corrections have been established: • Pre-Submission Validation Control: The Registrar has implemented a mandatory data validation process. Whenever a student is processed as a withdrawal or placed on an LOA, the corresponding Clearinghouse data extract is reviewed prior to transmission. This control verifies that the student’s enrollment status and effective date are entirely accurate before final submission to the NSC.Ad-Hoc Adjustments: Any enrollment status changes that occur outside of the standard, scheduled reporting cycle are updated directly in the NSC secure portal on an ad-hoc basis to prevent reporting lags. • Systemic Technical Resolution: The Registrar’s Office has identified a technical issue within the Student Information System (SIS) data extraction logic that leaves the program-level status blank for students on LOA. The Registrar’s Office is actively collaborating with the SIS vendor and our Academic Data Warehouse Administrator to isolate the root cause and modify the extraction script. This vendor resolution is currently ongoing, and final implementation to correct the extract data mapping is underway. Additionally, The Financial Aid Office is responsible for downstream validation, ensuring that enrollment statuses and effective dates match across internal systems and federal databases, including the Common Origination and Disbursement (COD) system and the National Student Loan Data System (NSLDS). To satisfy the federal 60-day notification requirement, the Financial Aid Office executes the following quality assurance framework: • Reconciliation Sampling: Routine validation samples are compiled using the Student Status Confirmation Report (SSCR) from the NSC alongside internal status change notifications provided by the Registrar. • Proactive Review Timeline: Sample testing is conducted precisely 30 days post-notice of graduation or separation from the college. This 30-day window provides a compliance buffer, allowing the Financial Aid team to identify, research, and correct any reporting discrepancies well before the federally mandated 60-day NSLDS reporting deadline.
Management's Response: Management agrees with the finding. Upon discovery of the error, staff immediately submitted the final federal financial reports. To strengthen the organization's ability to ensure timely filing, management implemented a grant closeout checklist and accounting workflow and upd...
Management's Response: Management agrees with the finding. Upon discovery of the error, staff immediately submitted the final federal financial reports. To strengthen the organization's ability to ensure timely filing, management implemented a grant closeout checklist and accounting workflow and updated policies and procedures accordingly. Additionally, to strengthen internal controls, moving forward the Managing Director of Finance & Operations will formally approve federal financial report drafts prior to submission. Estimated Completion Date: August 15, 2026 – Already Completed Responsible Party: Amanda Gering Wheatley, Managing Director of Finance and Operations
FINDING 2025-003 Finding Subject: Reporting Contact Person Responsible for Corrective Action: Lisa Simmons, Auditor Contact Phone Number and Email Address: (765) 348-1620 lsimmons@blackfordcounty.in.gov Views of Responsible Officials: The County agrees with the finding regarding internal controls ov...
FINDING 2025-003 Finding Subject: Reporting Contact Person Responsible for Corrective Action: Lisa Simmons, Auditor Contact Phone Number and Email Address: (765) 348-1620 lsimmons@blackfordcounty.in.gov Views of Responsible Officials: The County agrees with the finding regarding internal controls over the reporting requirements associated with the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. Description of Corrective Action Plan: The County recognizes that, although the required Project and Expenditure (P&E) report was prepared and submitted to the U.S. Department of the Treasury, the County did not have an adequate documented oversight and review process in place prior to submission. To strengthen internal controls, the County will establish a formal process for the preparation, review, and submission of all required SLFRF reports. The County Auditor or designated employee will prepare the P&E report using the County's financial records and supporting documentation. Prior to submission, a separate individual with appropriate knowledge and oversight responsibilities will independently review the report for completeness and accuracy. The review will include verification of reported expenditures to the County's accounting records, review of projects and activities reported, and verification of applicable contracts and other required information. The reviewer will document completion of the review and any discrepancies identified will be resolved prior to submission. The County will also maintain a reporting calendar identifying applicable reporting periods and submission deadlines. The calendar will be monitored to ensure reports are prepared, reviewed, and submitted timely. Supporting documentation for the preparation and review of each report will be retained with the County's financial records. Employees responsible for federal grant reporting will receive additional training regarding the applicable Treasury reporting requirements and the County's established procedures. These procedures will provide an additional level of oversight and segregation of duties and are intended to ensure that future SLFRF reports are complete, accurate, properly reviewed, and submitted by the applicable deadlines. Anticipated Completion Date: December 31, 2026
ELIGIBILITY Recommendation: It is recommended that the County start reviewing casefiles. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will start printing a coversheet for the Fiscal Supervisor to sign...
ELIGIBILITY Recommendation: It is recommended that the County start reviewing casefiles. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will start printing a coversheet for the Fiscal Supervisor to sign and retain physical evidence of the review being done. Name of the contact person responsible for corrective action plan: Karen Anderson, Chief Financial Officer Planned completion date for corrective action plan: December 31, 2026
2025-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Defense ALN: 12.002 Recommendation: JSP recommends the Organization strengthen internal controls over cash management by establishing formal payment processing timelines, implementing...
2025-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Defense ALN: 12.002 Recommendation: JSP recommends the Organization strengthen internal controls over cash management by establishing formal payment processing timelines, implementing monitoring procedures to track outstanding reimbursement requests, and conducting supervisory reviews to ensure subrecipient payments are made promptly. Contact person responsible for corrective action: Taylor McEachern, Accounting Manager The EDC agrees with the findings. Management acknowledges that reimbursement payments to subrecipients were not consistently made within 30 calendar days of receipt of the payment request as required by 2 CFR 200.305(b)(3) and agrees that internal controls over cash management should be strengthened. Management notes that during the audit period the EDC experienced delays in receiving payments from the federal awarding agencies associated with this and other grants, which contributed to the condition; management is taking action to ensure that the EDC’s cash-flow timing does not affect the timeliness of subrecipient reimbursements going forward. To correct the conditions, management will implement the following: • Establish formal, written payment processing timelines governing the review and disbursement of subrecipient reimbursement requests, with a defined internal deadline that ensures payment within the 30-calendar-day requirement. • Implement monitoring procedures to log and track all outstanding reimbursement requests from date of receipt through payment, so that requests approaching the deadline are flagged and prioritized. • Conduct periodic supervisory reviews of the payment log to confirm requests are being processed timely and to identify and resolve any delays. • Monitor the timing of drawdowns and reimbursements from the federal awarding agencies and, where recurring delays affect the EDC’s ability to pay subrecipients timely, have an action plan to process the payments within the 30-calendar-day requirement. The Accounting Manager will be overseeing the payment tracking process and report monthly to the C&I Director and Grant Manager to reinforce accountability for timely disbursement Anticipated completion date: September 2026
Finding 2025-001: Significant Deficiency over Internal Controls related to Allowable Costs Corrective Action Plan: Strengthen detailed process for review over payroll charges billed to federal programs. To address the significant deficiency over allowable costs identified in the Single Audit, the Or...
Finding 2025-001: Significant Deficiency over Internal Controls related to Allowable Costs Corrective Action Plan: Strengthen detailed process for review over payroll charges billed to federal programs. To address the significant deficiency over allowable costs identified in the Single Audit, the Organization will enhance its existing review procedures by implementing a more detailed monthly review process. This will include verifying payroll charges against supporting documentation such as payroll registers, time records, and allocation spreadsheets. Management will also explore the development of a standardized reconciliation checklist and introduce a secondary review step to ensure accuracy and completeness. These measures, combined with continued monthly oversight by the CFO, are intended to reduce the risk of billing errors due to human oversight and reinforce the reliability of payroll cost allocations. Name of Responsible Person: Nora Davis, Chief Financial Officer Anticipated Completion Date: October 1, 2026
Condition: The Association’s controls were not effective to ensure transactions recorded to payroll liability accounts were appropriate and balances were accurately stated at year end on the trial balance. Explanation of disagreement with audit finding: There is no disagreement with the audit findin...
Condition: The Association’s controls were not effective to ensure transactions recorded to payroll liability accounts were appropriate and balances were accurately stated at year end on the trial balance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment Payroll liability payments are now supported by payroll reports, tax filings, vendor invoices, and other applicable documentation rather than relying solely on general ledger balances. Root Cause The root cause was a prior practice of paying payroll liabilities based on general ledger balances rather than the underlying payroll or vendor documentation. In addition, benefitrelated changes were being made directly in the MIP financial system on the default timesheets when the changes should have been recorded in the HRMS employee record. Action Taken Payroll liability accounts are now reconciled each pay period to payroll reports and supporting documentation. Benefit-related changes are recorded in the HRMS employee record and processed through payroll rather than being manually changed in the MIP financial system. Payroll liability balances are also reviewed as part of the monthly-end close (MEC) process, with discrepancies researched and corrected as needed. As part of the year-end close, OCCDA will also review payroll liability account activity and system configuration to determine whether consolidating payroll liabilities into a single liability account, rather than maintaining separate accounts by liability type, would improve the efficiency and accuracy of reconciliation and financial reporting.
Condition: The Association’s controls were not effective to ensure it was recognizing revenue and unearned revenue for reimbursement-based programming in the same period the expenditure occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ...
Condition: The Association’s controls were not effective to ensure it was recognizing revenue and unearned revenue for reimbursement-based programming in the same period the expenditure occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment Advanced funds are recorded as deferred revenue at time of receipt. Periodic adjustments are made through the Accounts Receivable (AR) module as part of the monthly-end close (MEC) process to reclassify unearned revenue as the related expenditures are incurred. Root Cause The root cause was that, in prior years, grant revenue and related accruals were not consistently reconciled to expenditures. Cash receipts were recognized as grant revenue without adequately considering the timing of the related expenditures. For awards that crossed fiscal periods, this resulted in variances between earned and deferred revenue and, in some cases, expenditures exceeding available grant funding. Action Taken OCCDA has implemented the use of the Accounts Receivable (AR) module for grant revenue reporting and reconciliation. Grant activity is reviewed as part of the monthly-end close (MEC) process, including reconciliation of expenditures, reimbursements, and deferred revenue. Monthly management reports have also been updated to include both earned revenue and deferred revenue, providing management with improved visibility into grant activity and supporting timely recognition of grant revenue.
Low-Rent Public Housing -Assistance Listing No. 14.850 - Eligibility Recommendation: We recommend that the Authority strengthen controls over tenant eligibility and rent determinations by ensuring required income, asset, expense, consent, and release documentation is obtained and retained; annual re...
Low-Rent Public Housing -Assistance Listing No. 14.850 - Eligibility Recommendation: We recommend that the Authority strengthen controls over tenant eligibility and rent determinations by ensuring required income, asset, expense, consent, and release documentation is obtained and retained; annual reexaminations are completed timely; rent calculations are based on verified information; and supervisory review checklists are completed, signed, and maintained in each tenant file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NNRHA's Compliance Analyst and Newly hired Asset Manager will execute reports from the PIC system monthly and work with the onsite staff to ensure properties are in full compliance with Public Housing requirements. Name of the contact person responsible for corrective action: Tera L. Lockley Planned completion date for corrective action plan: December 31, 2026
Housing Voucher Cluster - Assistance Listing Nos. 14.871/14.879 - Housing Voucher Cluster - Housing Quality Standards (HQS) Inspections and Enforcement Recommendation: We recommend the Authority review its HQS inspection process to ensure that inspections are performed timely and that all inspection...
Housing Voucher Cluster - Assistance Listing Nos. 14.871/14.879 - Housing Voucher Cluster - Housing Quality Standards (HQS) Inspections and Enforcement Recommendation: We recommend the Authority review its HQS inspection process to ensure that inspections are performed timely and that all inspection related documentation is maintained within Yardi or the tenant file. We recommend the Authority review its processes for tracking failed inspections to ensure that the proper actions are taken timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HCV Senior Inspector runs reports monthly to ensure all inspections are made on a timely basis. For failed inspections, the HCV Senior Inspector reviews all inspections on a daily basis and tracks failed inspections and reports to the HCV Program Manager. The Program Manager will also track the failed inspections and the date to reinspect. Name of the contact person responsible for corrective action: Tera L. Lockley Planned completion date for corrective action plan: December 31 , 2026
Housing Voucher Cluster - Assistance Listing Nos. 14.871/14.879 - Special Tests - Reasonable Rent Recommendation: We recommend the Authority review their processes and internal controls for rent reasonableness to ensure the reasonableness determination is completed prior to the effective date of the...
Housing Voucher Cluster - Assistance Listing Nos. 14.871/14.879 - Special Tests - Reasonable Rent Recommendation: We recommend the Authority review their processes and internal controls for rent reasonableness to ensure the reasonableness determination is completed prior to the effective date of the HUD-50058 Family Report Form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HCV Department procedure is that the coordinators receive the Request for Tenancy Approval form from the client's prospective landlord and that is immediately forwarded to the Landlord Liaison who performs the rent reasonableness test and then forwarded to the Inspection department to perform an inspection. All these steps take place prior to the effective date of the 50058. Name of the contact person responsible for corrective action: Tera L. Lockley Planned completion date for corrective action plan: December 31 , 2026
Finding 2025-005 Federal Agency Name: Department of Treasury Pass-Through Entity: South Dakota Department of Agriculture and Natural Resources Assistance Listing Number: 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: There was no review performed of the requi...
Finding 2025-005 Federal Agency Name: Department of Treasury Pass-Through Entity: South Dakota Department of Agriculture and Natural Resources Assistance Listing Number: 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: There was no review performed of the required annual report prior to its submission to ensure the accuracy and completeness of the reported information. Corrective Action Plan: The City will revise its reporting procedures to provide for a separate preparer and reviewer of required federal program reports. The reviewer will review the report for accuracy and completeness prior to submission, and completion of the review will be documented. Responsible Individual(s): Jordan McQuillen, Finance Officer Anticipated Completion Date: December 2026
Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 – PIC Reporting Recommendation: We recommend that the Authority reviews its process for uploading data to the PIC system to ensure each HUD-50058 recertification gets submitted timely and accurately. Explanation of disagreement with aud...
Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 – PIC Reporting Recommendation: We recommend that the Authority reviews its process for uploading data to the PIC system to ensure each HUD-50058 recertification gets submitted timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During this time, HUD was working to switch reporting systems from PIC to HIP. Our software showed the files in question were submitted and no rejection noted, yet the records are not showing as received on HUD’s end. The Authority will work with our software provider and review any HUD changes affecting the PIC System. We will continue to review all records included in this upload, and work to ensure other records are uploaded manually. Name of the contact person responsible for corrective action: Richard Marshall Planned completion date for corrective action plan: 10/31/2026
Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the Distri...
Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: Testing of the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: • The District has not formalized and adopted a written procurement policy. • In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. • In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for the vendor selection. Corrective Action Plan: The District will develop and formally adopt a written procurement policy addressing procurement activities involving federal awards and the applicable requirements of the Uniform Guidance. The District will establish procedures to document the procurement method utilized and the basis for vendor selection, verify and retain documentation that vendors subject to federal suspension and debarment requirements are not suspended or debarred from participation in federal programs, and ensure that federally funded contracts include applicable federal contract provisions required by 2 CFR Part 200. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: March 2027
Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The District does not have an internal control system designed to provide for a ...
Federal Agency Name: Department of Energy Pass-Through Entity: Nebraska Department of Environment and Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The District does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards (the schedule) being audited. We requested our auditors to assist with the preparation of the schedule and the accompanying notes to the schedule. Corrective Action Plan: Due to the specialized nature of the SEFA, the District will continue to utilize qualified external assistance with its preparation. Management will maintain the underlying federal award and expenditure records and will review the completed SEFA and accompanying notes for completeness and accuracy prior to issuance. Responsible Individuals: Mandy Backer, Chief Financial Officer, and Josh Strafelda, Engineer Anticipated Completion Date: Ongoing
Audit Finding Reference: 2025-002 Corrective Action Plan: Timecard Review and Approval Documentation Finding: A significant deficiency was identified related to the lack of documented evidence that timecard review and approval controls were performed. Root Cause: The review and approval process exis...
Audit Finding Reference: 2025-002 Corrective Action Plan: Timecard Review and Approval Documentation Finding: A significant deficiency was identified related to the lack of documented evidence that timecard review and approval controls were performed. Root Cause: The review and approval process existed but formal documentation evidencing management review was not consistently retained. Corrective Action: Paylocity generates a Timecard Approvals Summary log for each payroll period. The report identifies employee timecard activity and includes evidence of supervisor approval through the system's Supervisor Approved indicator. The report will be submitted to the Director of Human Resources, who will review the report for completeness, verify supervisor approvals, investigate any exceptions, and document completion of the review by signing and dating the report. The signed report will be retained with payroll records as evidence the control was performed. Preventive Measures: Payroll procedures will be updated to require retention of the signed Timecard Approvals Summary report for each payroll cycle. Payroll and HR personnel will be trained on the revised documentation requirements. Periodic monitoring reviews will be performed by the Controller. Responsible Parties: Director of Human Resources, Payroll Department, and Controller. Implementation Date: Effective immediately beginning with the next payroll cycle. Evidence of Completion: Signed and dated Timecard Approvals Summary reports, updated payroll procedures, and monitoring documentation.
Audit Finding Reference: 2025-001 Corrective Action Plan: Reimbursement Request Review and Approval Documentation Finding: The Center was unable to provide documentation demonstrating that reimbursement requests submitted to federal funding agencies received supervisory review and approval by the Co...
Audit Finding Reference: 2025-001 Corrective Action Plan: Reimbursement Request Review and Approval Documentation Finding: The Center was unable to provide documentation demonstrating that reimbursement requests submitted to federal funding agencies received supervisory review and approval by the Controller prior to submission. While reimbursement requests were reviewed, evidence of such review and approval was not consistently documented and retained. Root Cause: The review and approval process existed; however, formal documentation evidencing the Controller’s review and approval was not consistently retained with the reimbursement request records. Corrective Action: The Center has implemented enhanced procedures to ensure that all reimbursement requests submitted under federal awards receive documented supervisory review and approval prior to submission. Grant accounting staff will prepare the reimbursement request and supporting documentation and submit the complete package to the Controller for review. The Controller will review the request for accuracy, allowability, allocability, reasonableness, adequate supporting documentation, reconciliation to grant records and approved budgets, and compliance with applicable federal regulations and award requirements. Approval will be documented through electronic approval, email authorization retained with the reimbursement records, or signature and date on the reimbursement package or standardized checklist prior to submission. Preventive Measures: The Center has developed a standardized reimbursement request checklist that must be completed and retained with each reimbursement package. Grant accounting personnel will be trained on the revised documentation requirements, and the Executive Director will perform quarterly spot checks of reimbursement request files to confirm that evidence of review and approval is consistently maintained. Any exceptions identified will be addressed through corrective training and process improvements. Responsible Parties: Controller, Grant Accounting Staff, and Executive Director. Implementation Date: Effective immediately upon adoption. Evidence of Completion: Completed reimbursement request checklists, documented Controller approvals through signature, electronic approval, or retained email authorization, supporting reimbursement documentation, and quarterly monitoring documentation.
Corrective Action Plan for Fiscal Year Ending December 31, 2025 Institution: ICOHS College OPE ID #: 04265500 Audit Period: January 1 – December 31, 2025 Date of CAP Submission: 09/24/2026 Finding 2025-001 – Reporting (COD Date Disbursed) Programs: Student Financial Assistance Cluster – Federal Dire...
Corrective Action Plan for Fiscal Year Ending December 31, 2025 Institution: ICOHS College OPE ID #: 04265500 Audit Period: January 1 – December 31, 2025 Date of CAP Submission: 09/24/2026 Finding 2025-001 – Reporting (COD Date Disbursed) Programs: Student Financial Assistance Cluster – Federal Direct Loans (84.268), Federal Pell Grant (84.063) Type of finding: Significant deficiency in internal control over compliance; noncompliance Questioned costs: None Cause. Under Heightened Cash Monitoring 1 (HCM1), the College credits Title IV aid to student accounts using institutional funds before requesting reimbursement from the Department of Education. The College interpreted the COD Date Disbursed as the later date associated with COD processing or federal reimbursement rather than the date the funds were credited to the student’s ledger account. The College also lacked a formal reconciliation between the student ledger and COD that would have detected the difference. Corrective Action 1. Immediate change in reporting practice Effective September 28, 2026, the Financial Aid Office will report the COD Date Disbursed as the date Title IV funds are credited to the student’s ledger account, including when institutional funds are used in advance of reimbursement under HCM1. Disbursement records will be reported to COD within the Department’s required timeframe. 2. Updated written disbursement procedure The College will update its written Title IV disbursement procedure to define the disbursement date as the date Title IV funds are credited to the student’s account or paid directly to the student or parent (34 CFR 668.164(a)), and to distinguish anticipated or estimated aid entries from actual disbursements. The procedure will identify who prepares, reviews and approves each step. 3. Staff training Business Office and Financial Aid staff responsible for Title IV disbursements and COD reporting will be trained on the revised procedure, including the treatment of institutional funds used to make Title IV disbursements under HCM1. Attendance will be documented. 4. COD-to-ledger reconciliation for every disbursement cycle For each disbursement cycle, the Financial Aid Office will complete a reconciliation (maintained as the College’s Title IV disbursement tracker) comparing: • Student name and ID • Title IV fund type • Disbursement amount • Student ledger credit date • COD Date Disbursed • COD status (accepted / rejected / pending) Any difference is researched and corrected in COD before the reconciliation is marked complete. The tracker documents each exception, its cause and the correction made. 5. Independent review and sign-off A Business Office staff member who did not prepare the disbursement will review each completed reconciliation and document approval with name and date. Exceptions will be resolved before sign-off. 6. Lookback review of 2025 and 2026 disbursements The Financial Aid Office and Business Office will compare the COD Date Disbursed with the ledger credit date for all Title IV disbursements made from January 1, 2025 through the effective date of the corrected practice. Results will be documented by student and disbursement. 7. Correction of prior records in COD Discrepancies identified in the lookback review will be corrected in COD to reflect the date funds were credited to the student’s account, to the extent permitted by COD and in accordance with Department of Education requirements. Any records that cannot be corrected will be documented with the reason. 8. Monitoring and evidence retention Tim Tandio (Operations & Compliance) will review the reconciliations and tracker monthly and report results to the Executive Director quarterly. Reconciliations, sign-offs, the tracker, lookback results and training records will be retained for audit and program review. Timeline Action Responsible Target completion 1. Report COD Date Disbursed as the ledger credit date Financial Aid Office Effective September 28, 2026 2. Update written Title IV disbursement procedure Financial Aid Office / Business Office; approved by Tim Tandio October 15, 2026 3. Staff training on revised procedure Tim Tandio October 15, 2026 4–5. COD-to-ledger reconciliation and independent review Financial Aid Office (prepare); Business Office (review) First disbursement cycle after September 28, 2026, and every cycle thereafter 6. Lookback review of 2025 and 2026 disbursements Financial Aid Office / Business Office Review complete by November 30, 2026 7. Correct discrepancies in COD Financial Aid Office Submitted by December 31, 2026, to the extent permitted by COD 8. Monitoring and evidence retention Tim Tandio; Executive Director Monthly and quarterly, ongoing Prior Year findings: Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting Status: Corrected Corrective action was implemented to strengthen the College’s enrollment reporting procedures, including monitoring and timely reporting of enrollment status changes to NSLDS. Based on the results of the 2025 audit, no findings related to enrollment reporting were identified. Finding 2024-002 – Special Tests and Provisions – Return of Title IV Funds Status: Corrected Corrective action was implemented to strengthen the monitoring and timely processing of Return of Title IV Funds (R2T4), including additional oversight of the third-party service provider and internal monitoring procedures. Based on the results of the 2025 audit, no findings related to the timely return of Title IV funds were identified.
Finding 1238046 (2025-001)
Material Weakness 2025
Finding 2025-001 – Major Federal Award Programs Audit Finding, Significant Deficiency, Inadequate internal control to ensure personnel costs charged to the federal program are supported in accordance with federal requirements. HopeSparks acknowledges the auditor's finding that certifications of pers...
Finding 2025-001 – Major Federal Award Programs Audit Finding, Significant Deficiency, Inadequate internal control to ensure personnel costs charged to the federal program are supported in accordance with federal requirements. HopeSparks acknowledges the auditor's finding that certifications of personnel activity for staff whose compensation was charged in whole or in part to the federal award were not completed on a periodic basis during the grant period, as required by 2 CFR 200.430. During the applicable period, personnel and grant-related costs were monitored on an ongoing basis through HopeSparks' regular weekly budget review process and were charged consistently with the approved award budget; however, the specific certification format required by federal effort-reporting standards was not completed contemporaneously. Following the finding, HopeSparks conducted a thorough review of employee activities during the grant period. This process included documenting all relevant work performed and comparing it directly to personnel costs charged to the program. Our review confirmed that each cost charged to the federal award was allowable, allocable, and adequately supported. Going forward, HopeSparks will establish a periodic, contemporaneous certification process for personnel whose compensation is charged to federal awards, with implementation details to be finalized and incorporated into HopeSparks' written policies and procedures. HopeSparks' Chief Financial Officer, William Bowman, will oversee the development and execution of this process, and the President and CEO, Joseph Le Roy, will be responsible for ensuring it is carried out. If you have any questions or require additional information, please feel free to contact him at 253-565-4484 or jleroy@hopesparks.org.
Finding Number: 2025‐002 Program Name/Assistance Listing Title: Tribal Self Determination Assistance Listing Number: 93.441 Contact Person: Tahnee Brown, Controller Anticipated Completion Date: Implemented ‐ Effective Immediately Planned Corrective Action: Pine Hill Health Center has instructed Pati...
Finding Number: 2025‐002 Program Name/Assistance Listing Title: Tribal Self Determination Assistance Listing Number: 93.441 Contact Person: Tahnee Brown, Controller Anticipated Completion Date: Implemented ‐ Effective Immediately Planned Corrective Action: Pine Hill Health Center has instructed Patient Registration staff to obtain and retain documentation supporting patient eligibility. If documentation is not available, the patient will be classified as “Pending Verification” or “Ineligible” until the required documentation is provided. The Billing Manager will monitor the process and ensure eligibility documentation is retained in the patient's health record.
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