Corrective Action Plans

Finding 524920 (2024-002)

Significant Deficiency 2024

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommenda...

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524916 (2024-005)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation:...

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Finding 524912 (2024-001)

None 2024

Wilkes University

PA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed a...

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

View Audit 344278

Finding 524907 (2024-006)

Significant Deficiency 2024

East Orange Board of Education

NJ

Internal controls be enhanced to prevent cash overdrafts in the payroll Agency and Worker's Compensation bank accounts.

View Audit 344270

Finding 524906 (2024-001)

Significant Deficiency 2024

Licking Valley Community Action Program, Inc.

KY

Procurement, Suspension & Debarment § 200.206

THE EXECUTIVE DIRECTOR AND FINANCE OFFICER WILL IMPLEMENT A DEBARMENT CHECK WITH VENDORS WITH SIGNIFICANT AMOUNTS OF FEDERAL GRANT FUNDING THROUGHOUT THE YEAR TO ENSURE DEBARMENT STATUS. THIS WILL BE ADDED TO THE INTERNAL CONTROL POLICY

View Audit 344264

Finding 524903 (2024-001)

None 2024

Williamsburg-James City County Community Action Agency, Inc.

VA

Equipment & Real Property Management Procurement, Suspension & Debarment

The Agency agrees with this finding. See auditee's corrective action plan. The Agency added funding sourcse to the asset listing and completed an inventory of equipment to add applicable identification numbers and asset condition to the asset listing. Corrective Action contact person(s), Mridul Sing...

The Agency agrees with this finding. See auditee's corrective action plan. The Agency added funding sourcse to the asset listing and completed an inventory of equipment to add applicable identification numbers and asset condition to the asset listing. Corrective Action contact person(s), Mridul Singh, Interim Head Start Director, (757) 229-9332, msingh@weareace.org; Kristy Gamble, Chief Financial Officer, (630) 280-2580, kristy.gamble@wipfli.com. Completed December, 2024.

View Audit 344261

Finding 524897 (2024-002)

Significant Deficiency 2024

Town of Coventry, Connecticut

CT

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. ...

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although there were no errors in the reporting, to ensure efficiencies, staff other than the Finance Director will review grant reporting and sign off before it is submitted. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: February 1, 2025

View Audit 344253

Finding 524890 (2024-001)

Significant Deficiency 2024

Town of Coventry, Connecticut

CT

Procurement, Suspension & Debarment § 200.318 § 200.326

UNITED STATES DEPARTMENT OF THE TREASURY 2024-001 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement wi...

UNITED STATES DEPARTMENT OF THE TREASURY 2024-001 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town was checking for disbarred vendors, but did not date or track when the searches were done. Going forward, a spreadsheet will be kept of vendors and date of search on SAM.gov. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: June 30, 2025

View Audit 344253

Finding 524888 (2024-002)

Significant Deficiency 2024

Eastern Michigan University

MI

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

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the foll...

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a Senior Financial Aid Advisor or member of the Financial Aid Management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

View Audit 344249 Questioned Costs: $1

Finding 524886 (2024-001)

Significant Deficiency 2024

Eastern Michigan University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to ver...

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

View Audit 344249

Finding 524881 (2024-002)

Significant Deficiency 2024

East Windsor Regional School District

NJ

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.430

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245 Questioned Costs: $1

Finding 524876 (2024-001)

None 2024

East Windsor Regional School District

NJ

Reporting Internal Control / Segregation of Duties

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245

Finding 524872 (2024-001)

Significant Deficiency 2024

Cumberland University

TN

Reporting Student Financial Aid Matching / Level of Effort / Earmarking

Finding Summary: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the...

Finding Summary: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the student’s withdrawal date and must return the amount of Title IV funds for which it was responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR 668.22(j)(1)). Annual Single Audit review of Return to Title IV (R2T4) funds found that the return of federal funds was outside the required window. All necessary funds were returned during the 23-24 funding period. While R2T4 calculations were performed within the required time limit, there were three total students with returns that were outside the return window for the 23-24 Academic Year. Corrective Action Plan (CAP): The Associate Director of Financial Aid will be the primary staff member responsible for the R2T4 calculations and returns. If they are unavailable in a given week, the Executive Director will perform the weekly calculations needed. To ensure that the calculations and returns are completed within federal guidelines, the Associate Director will block 2-4 hours at the beginning of each week of the semester to review the prior week’s withdrawals and perform all necessary calculations and returns. At the end of each week, the Associate Director and the Executive Director will meet to review the prior week’s calculations and returns to ensure all returns have been processed through the Department of Education Common Origination and Disbursement (COD) website. A checklist has been created with all the necessary steps for each return, with a sign-off and documentation required to be attached as proof of completion. Anticipated Completion Date: The procedures will be implemented for the 2024-2025 Financial Aid Year. Responsible Parties: Beatrice LaChance

View Audit 344243

Finding 524870 (2024-001)

Significant Deficiency 2024

Markesan District Schools

WI

Internal Control / Segregation of Duties

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of ...

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstatements on a timely basis. Cause: A small number of individuals within the District’s administration perform substantially all accounting functions and have control over both records and assets. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the District’s operations. Response: We agree and will continue to provide supervision and monitor accounting information and operations, obtain explanations for variances from unexpected results and work to increase segregation of duties. The Assistant to the Business Manager will continue to clear checks in Skyward as part of the bank reconciliation process. The District Administrator will review and initial all journal entries. The Assistant to the Business Manager will review payroll on a monthly basis, and the District Administrator will review payroll on a quarterly basis. Contact Person: Tim Zacharias Anticipated Completion: Not Applicable

View Audit 344235

Finding 524867 (2024-001)

Significant Deficiency 2024

John A Logan College, Community College District #530

IL

Special Tests & Provisions Student Financial Aid Reporting

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted ...

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported to the Clearinghouse after withdrawing from the institution. Plan: After contacting Jenzabar One, the College has determined it cannot alter the pre-made Clearinghouse report; however, the College can alter its withdrawal process to ensure accurate withdrawal dates are reported in the correct area within the SIS. Admissions and Records will modify withdrawal and school determination dates, so the SIS gathers the correct information to be reported for future reporting. The Registrar will also work with and crosscheck students with Financial Aid to ensure all students who attended, but dropped before census, will be reported to the Clearinghouse. Anticipated Date of Completion: January 2025 Name of Contact Person: Dr. Stephanie Hartford, Provost

View Audit 344230

Finding 524862 (2024-001)

Significant Deficiency 2024

Family Voices

MA

Allowable Costs / Cost Principles

Corrective action plan: Beginning in the pay period of October 2024, the new Finance Director issued a memo of accounting policy change. The memo outlined the deficiencies in both the payroll allocation method as well as the cause and effect of other allocations that used time and effort as the allo...

Corrective action plan: Beginning in the pay period of October 2024, the new Finance Director issued a memo of accounting policy change. The memo outlined the deficiencies in both the payroll allocation method as well as the cause and effect of other allocations that used time and effort as the allocation method. The policy was put into effect in October 2024 with plans to recalculate the allocations that occurred prior to that time frame within the 2025 Fiscal Year. The new allocation method has been implemented and as of December 2, 2024 the organization is in compliance with the standards of allowable cost grants. Personnel responsible for corrective action plan: Smythe Kannapell, CPA Estimated corrective action completion date: October 2024

View Audit 344229

Finding 524859 (2024-002)

Significant Deficiency 2024

High Point University

NC

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program fi...

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students must not be working during scheduled class hours regardless of whether the class is cancelled or let out early. The Student Employment Program holds annual training sessions for and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects that supervisors continue to obtain students class schedules each semester and updates students work schedules accordingly each semester to ensure students are not working during times they are in class. The University continues to use the internal audit process it instituted in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure students are not working during class hours. This review will be performed by Michael Peeler, Vice President for Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and to the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication reminds them of their responsibility to adhere to student employment guidelines and their responsibility to keep their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Since the hours of overpayment appeared to be resulting from students failing to clock out and managers failing to catch inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving timesheets has been provided to student employee supervisors as part of the monthly email communication. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each semester. This process will continue to sample student work records at the midpoint and end of the fall and spring semesters, where students’ class schedules are compared to hours worked to ensure students are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this review. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: March 31, 2025

View Audit 344215 Questioned Costs: $1

Finding 524858 (2024-001)

Significant Deficiency 2024

High Point University

NC

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

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. Our next steps include consolidating student returns to each of the different lenders, working with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2025

View Audit 344215

Finding 524822 (2024-001)

Significant Deficiency 2024

The College of New Jersey

NJ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administra...

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

View Audit 344210

Finding 524819 (2024-002)

Significant Deficiency 2024

Octorara Area School District

PA

Reporting Significant Deficiency

During the audit of the 2023-2024 school year, it was determined that the expenditures reported for the 2022-2023 fiscal year did not align with the expenses recorded and reported on the Schedule of Expenditures of Federal Awards (SEFA). Cause: The discrepancy appears to be a result of coding err...

During the audit of the 2023-2024 school year, it was determined that the expenditures reported for the 2022-2023 fiscal year did not align with the expenses recorded and reported on the Schedule of Expenditures of Federal Awards (SEFA). Cause: The discrepancy appears to be a result of coding errors or weaknesses in internal controls over the financial reporting process. Corrective Action Plan: 1. Review and Reconciliation Process Improvement - Implement a standardized reconciliation process to ensure that all expenditures reported in federal grant filings match the SEFA and general ledger records. - The reconciliation process will be conducted monthly to ensure expenditures are accurately recorded and categorized. 2. Independent Review of Reports - Assign an independent reviewer, separate from the preparer, to verify the accuracy of all grant-related reports before submission. - This reviewer will cross-check expenditures with SEFA, general ledger records, and supporting documentation to ensure consistency and compliance. 3. Enhanced Internal Controls - Develop and document a formalized grant reporting procedure that includes clear steps for expenditure tracking, coding, and verification. - Require dual sign-off on all grant expenditure reports before submission to the Pennsylvania Department of Education. 4. Staff Training and Accountability - Provide targeted training to finance and grants management personnel on proper coding procedures and federal grant compliance requirements. - Conduct annual refresher training to reinforce best practices in financial reporting and compliance. 5. Regular Monitoring and Audits - Conduct quarterly internal audits of grant expenditures to proactively identify and correct any discrepancies before external audits. - Establish a compliance checklist to ensure all reporting aligns with federal and state requirements. 6. Follow-Up and Monitoring: - A follow-up review will be conducted after the next reporting cycle to assess the effectiveness of corrective actions and ensure compliance. By implementing these corrective measures, the District aims to strengthen internal controls, improve reporting accuracy, and ensure compliance with federal grant requirements.

View Audit 344208

Finding 524815 (2024-007)

Significant Deficiency 2024

Coastal Alabama Community College

AL

Student Financial Aid Significant Deficiency

Management’s View and Corrective Action Plan: Management concurs with the above finding, and it has been corrected. In the case of A01441826, when the student’s enrollment was captured for Title IV eligibility (02/01), the student was enrolled in 10 credit hours. The student’s 3 credit hour CIS 146 ...

Management’s View and Corrective Action Plan: Management concurs with the above finding, and it has been corrected. In the case of A01441826, when the student’s enrollment was captured for Title IV eligibility (02/01), the student was enrolled in 10 credit hours. The student’s 3 credit hour CIS 146 class was deleted on 02/21 and Financial Aid was unaware. This caused the overpayment. In the case of A01454524, enrollment was captured for Title IV eligibility (02/01), the student was enrolled in 13 credit hours, but only 10 of those were in the student’s program of study. The student made an adjustment to their schedule and dropped the class that was out of program and picked up a class in program. This adjustment was not caught by Financial Aid. There is a report in ARGOS to assist with catching the multiple schedule changes. Moving forward there will be more than one person reviewing this report on a bi-weekly basis at a minimum. This report will be saved, and notes will be added so that it will be available to auditors moving forward. Corrective action will be implemented by April of 2025.

View Audit 344201

Finding 524814 (2024-001)

Significant Deficiency 2024

City/county Association of Governments of San Mateo County

CA

Procurement, Suspension & Debarment § 200.214

The following corrective actions have either been implemented or will be implemented to prevent recurrence: 1. Audit Documentation: For the identified contract, C/CAG obtained and affidavit from the vendor affirming their compliance with suspension and debarment requirements at the time of contract....

The following corrective actions have either been implemented or will be implemented to prevent recurrence: 1. Audit Documentation: For the identified contract, C/CAG obtained and affidavit from the vendor affirming their compliance with suspension and debarment requirements at the time of contract. C/CAG also confirmed that the consultant is currently not on the suspension and debarment list. This documentation has been shared with the auditors and added to the project file. 2. Quality Assurance: Staff confirmed that the C/CAG’s other federally funded contracts included the required suspension and debarment requirements. 3. Staff Training: All staff members that work or might work on federally funded activities have completed training on federal procurement requirements, including guidance on suspension and debarment protocols. This training references the necessity of conducting SAM.gov checks and obtaining certifications for all federalized contracts. The specific training was: "Navigating the Uniform Guidance: Procurement Standards," and it was conducted on December 18, 2024. The provider of the training was “Federal Grants Training.” Ten C/CAG staff attended the training, including staff in the following positions: Executive Director, Deputy Director, Stormwater Program Director, Transportation Systems Coordinator, Senior Program Specialist, and Program Specialist. Copied of the completion certificates are available upon request. To ensure ongoing compliance, all future staff working on federally funded activities will also complete training on relevant federal requirements as part of their onboarding or ongoing professional development. 4. Contract Template and Procurement Policy Update: C/CAG is in the process of updating its standard contract template and the Procurement Policy to include suspension and debarment language for all contracts, regardless of funding source. This proactive measure ensures compliance across all contracts, even if funding transitions from non-federal to federal sources. Starting in February 2025, all relevant new contracts will have suspension and debarment language. The new contract template is expected to take effect beginning in April of 2025, and all contracts signed from that time onward will use the updated template. Furthermore, C/CAG will continue to review and update its contracts and policies regularly to ensure compliance with evolving regulations and standards. 5. Verification Procedures: Moving forward, C/CAG will: o Require vendors to provide a certification of compliance with suspension and debarment requirements before executing any agreement. o Conduct SAM.gov checks for all federally funded contracts.

View Audit 344199

Finding 524811 (2024-003)

None 2024

Corban University

OR

Student Financial Aid Reporting

FISAP Reporting Planned Corrective Action: Independent of the individual who prepares the FISAP, Corban will assign another team member to review the completed FISAP for quality assurance (QA). We have retained all FISAP related records for the current year and are in the process of better organizin...

FISAP Reporting Planned Corrective Action: Independent of the individual who prepares the FISAP, Corban will assign another team member to review the completed FISAP for quality assurance (QA). We have retained all FISAP related records for the current year and are in the process of better organizing our FISAP files. Financial Aid professionals have also been added to internal meetings where decisions on programs, academic calendars, and other significant timing decisions are made to better enhance our ability to comply. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190

Corrective Action Plans

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