Corrective Action Plans

Finding 524562 (2024-001)

Significant Deficiency 2024

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Finding 524561 (2024-007)

Material Weakness 2024

Santa Rosa Consolidated Schools

NM

Questioned Costs

The business office will create a document to help determine the worker's relationship status and incorporate it into the process before issuing purchase orders. Additionly, the business office will review all independent contractors providing services to the district to ensure compliance.

View Audit 343991 Questioned Costs: $1

Finding 524554 (2024-001)

Significant Deficiency 2024

University of Miami

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM ...

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM management has since implemented a new process for reporting submission to bypass the technical issues. Timeline for Action Plan The new process was implemented in March 2024. Responsible JndjviduaJs Allen Augustin, Associate Registrar

View Audit 343977

Finding 524552 (2024-002)

Significant Deficiency 2024

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

HUD Housing Programs Subrecipient Monitoring

Statement of Condition 2024-002 (Assistance Listing 14.181): The Property received a Management Occupancy Review (MOR) rating of Below Average and is unable to locate a response to HUD correcting the findings in the MOR. Recommendation: Management should clear all findings from the MOR and follow u...

Statement of Condition 2024-002 (Assistance Listing 14.181): The Property received a Management Occupancy Review (MOR) rating of Below Average and is unable to locate a response to HUD correcting the findings in the MOR. Recommendation: Management should clear all findings from the MOR and follow up with HUD to request a close-out letter. Management Response: Agree. On January 24, 2025, management responded to the MOR findings and believes they have adequately addressed all deficiencies. No further action is required.

View Audit 343963

Finding 524550 (2024-001)

Significant Deficiency 2024

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements ...

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements fund or request a suspension of monthly deposits from HUD. Management Response: Agree. On January 9, 2025, management transferred $19,200 from the operating account to the reserve for replacements fund.

View Audit 343963 Questioned Costs: $1

Finding 524548 (2024-005)

Significant Deficiency 2024

Gibraltar Area School District

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Significant Deficiency § 200.214

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark ...

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

View Audit 343957

Finding 524546 (2024-004)

Material Weakness 2024

Gibraltar Area School District

WI

Procurement, Suspension & Debarment § 200.320

Procurement Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) District will review procurement policies and provide additional training and education to ensure the minimum requirements of 2 CFR 200 and the procurement policies established are being followed. Responsi...

Procurement Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) District will review procurement policies and provide additional training and education to ensure the minimum requirements of 2 CFR 200 and the procurement policies established are being followed. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

View Audit 343957

Finding 524545 (2024-004)

Significant Deficiency 2024

Lawton Independent School District No. 8

OK

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment

Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools did not correctly track the distribution of devices by source of funding. The 700 devices were distributed along with other like-devices. More than 700 devices were originally distributed to the “approved populati...

Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools did not correctly track the distribution of devices by source of funding. The 700 devices were distributed along with other like-devices. More than 700 devices were originally distributed to the “approved population” but not necessarily the 700 devices listed as purchased by the funds. Since the initial distribution, Lawton Public Schools has implemented software tracking of devices that includes the current location and disposition of these devices.

View Audit 343953 Questioned Costs: $1

Finding 524544 (2024-001)

None 2024

Penns Grove-Carneys Point Regional School District

NJ

Cash Management School Nutrition Programs Equipment & Real Property Management

The District will reduce net cash resources by investing in capital equiment where necessary and allocating direct cost overhead expenditures.

View Audit 343951

Finding 524542 (2024-003)

Significant Deficiency 2024

Donnelly College

KS

Student Financial Aid Matching / Level of Effort / Earmarking

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verificati...

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verification. That tracking system did not prevent the awarding of Title IV aid. Therefore, the college will implement a backup tracking system to help track students in verification. Anticipated Completion Date: March 31, 2025

View Audit 343943

Finding 524537 (2024-002)

Significant Deficiency 2024

Landmark College, INC

VT

Subrecipient Monitoring Significant Deficiency

The College continues to document the policies and procedures and implement any outstanding requirements to become fully compliant with GLBA. Where necessary the College will reach out to third parties for assistance. Anticipated completion during late FY 2025 to mid FY 2026.

View Audit 343940

Finding 524536 (2024-001)

Significant Deficiency 2024

Phoenix Union High School District No. 210

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency § 200.303

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was iss...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was issued without proper authorization. Action planned in response to finding: The District concurs with the finding, recognizing that the expenditure was allowable, and that the approval process was not in place for this expenditure. The District has removed access to the quick approval option for the end‐user to ensure bypassing does not occur. The District will continue to provide training ensuring end users follow proper procedures. Internal controls will be evaluated to ensure proper approval systems are in place to prevent this from recurring.

View Audit 343938

Finding 524531 (2024-001)

Significant Deficiency 2024

Housing Authority of Malheur and Harney Counties

OR

HUD Housing Programs

Management of the Housing Authority of Malheur and Harney Counties concurs with the audit finding. Staff will work to put procedures in place to make sure that all housing units are inspected on a regular basis to watch for any issues.

View Audit 343916

Finding 524530 (2024-001)

Significant Deficiency 2024

Owensboro Health, Inc.

KY

Equipment & Real Property Management § 200.313

Name of Contact Person: Renee Orange, Assistant Controller Corrective Action: Owensboro Health, Inc. will implement an updated policy for the recipient of the CFDA #93.965 grant (i.e., the Coal Miners’ Clinic) which will ensure that (1) the clinic performs a physical inventory of property purchased...

Name of Contact Person: Renee Orange, Assistant Controller Corrective Action: Owensboro Health, Inc. will implement an updated policy for the recipient of the CFDA #93.965 grant (i.e., the Coal Miners’ Clinic) which will ensure that (1) the clinic performs a physical inventory of property purchased with federal funds on an annual basis, (2) the results of the inventory are reconciled with the property records, and (3) this asset reconciliation is monitored and directed by the Authorized Official. Proposed Completion Date: February 28, 2024

View Audit 343900

Finding 524529 (2024-002)

None 2024

North Little Rock Housing Authority

AR

HUD Housing Programs Reporting

With respect to QAD’s Findings 2023-01 and 2023-02, the Authority will execute the QAD’s recommended Corrected Actions (itemized above). Regarding QAD’s Finding 2023-003, the Authority will implement and execute its revised accounting policy applicable to stale dated checks moving forward. The Aut...

With respect to QAD’s Findings 2023-01 and 2023-02, the Authority will execute the QAD’s recommended Corrected Actions (itemized above). Regarding QAD’s Finding 2023-003, the Authority will implement and execute its revised accounting policy applicable to stale dated checks moving forward. The Authority’s Executive Director, Yulunda White, has assumed the responsibility of executing these recommendations and Corrective Actions, and anticipates closure of QAD’s Findings 2023-01 through 2023-03 by April 30, 2025.

View Audit 343897

Finding 524524 (2024-004)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding:...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Fully implement and utilize existing reporting functionality in Jenzabar for National Student Clearinghouse • Review existing reporting procedures and process configurations for NSC reporting in Jenzabar to ensure that things are working correctly and being reported in a timely manner • Document the full process internally in the Registration and Records department Name(s) of the contact person(s) responsible for corrective action: Chris Cook, Registrar Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524519 (2024-003)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is reviewing the updated GLBA requirements and updating the WISP to ensure it includes all of the required elements. Name(s) of the contact person(s) responsible for corrective action: Justin Sin, IT Director Planned completion date for corrective action plan: May 31, 2025

View Audit 343891

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524508 (2024-002)

Material Weakness 2024

Columbia Cascade Housing Corporation

OR

Procurement, Suspension & Debarment

Finding Reference #: 2024-002 Federal Award Agency: Housing and Urban Development Name of Contact Person: Paula Maden Corrective Action: The Organization has familiarized itself with all compliance requirements with the Economic Development Initiative grant program (and future grants), including ...

Finding Reference #: 2024-002 Federal Award Agency: Housing and Urban Development Name of Contact Person: Paula Maden Corrective Action: The Organization has familiarized itself with all compliance requirements with the Economic Development Initiative grant program (and future grants), including federal suspension and debarment requirements. In the future, it will ensure that this requirement is complied with before contracting for goods or services or passing funds along to a subrecipient when the contract that exceed $25,000. It will take one of these steps: Obtain a signed certificate from the contractor attesting it is not suspended or debarred. Insert a clause in the contract stating the contractor is not suspended or debarred. Check the contractor’s status on the US General Administration website before contracting or purchasing. Documentation for the search will be retained by the Organization (including the date of the search). Date of Planned Corrective Action: 12/23/2024 Submitted by: Paula Maden

View Audit 343890

Finding 524507 (2024-001)

Significant Deficiency 2024

Columbia Cascade Housing Corporation

OR

Finding Reference #: 2024-001 Federal Award Agency: Department of Agriculture Rural Housing Service Name of Contact Person: Paula Maden Corrective Action: 1) Establish workout plan with RD for Carson Springs, White Cap and Wy East Vista. Plan will include pause of reserve deposits. Date of Plann...

Finding Reference #: 2024-001 Federal Award Agency: Department of Agriculture Rural Housing Service Name of Contact Person: Paula Maden Corrective Action: 1) Establish workout plan with RD for Carson Springs, White Cap and Wy East Vista. Plan will include pause of reserve deposits. Date of Planned Corrective Action: 1/1/2025 Submitted by: Paula Maden

View Audit 343890

Finding 524499 (2024-002)

Significant Deficiency 2024

Franklin Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.

View Audit 343871

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524493 (2024-002)

Significant Deficiency 2024

Rogue Community College

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate report...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the student’s last date of attendance did not agree to the student’s withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Anticipated Completion Date: June 25, 2025

View Audit 343860

Finding 524492 (2024-005)

Material Weakness 2024

Henning Public School District 545

MN

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

Contact Person – Melissa Sparks, Superintendent Corrective Action Plan – The District staff will work with the construction manager to ensure wage rates requirements are monitored. Completion Date – June 2025

View Audit 343854

Corrective Action Plans

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