Corrective Action Plans

Finding 516378 (2024-004)

Material Weakness 2024

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and a...

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025

View Audit 334325

Finding 516374 (2024-003)

Material Weakness 2024

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024

View Audit 334325

Finding 516372 (2024-002)

Significant Deficiency 2024

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility § 200.303

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation...

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have updated our procedure to reconcile Pell and Loans twice monthly to be able to catch any reporting errors within the 15-day reporting window. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516371 (2024-001)

Significant Deficiency 2024

Clatsop Community College

OR

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516370 (2024-002)

Significant Deficiency 2024

National Trust for Historic Preservation in the United States

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.430

2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing...

2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing monitoring of federal awards. The current internal control policies and procedures will be strengthened and enforced to ensure employees are preparing and certifying, and supervisors and/or program managers are approving hours charged to all federal projects monthly. Individual(s) Responsible for Corrective Action Plan: John Chomiak Chief Financial & Administration Officer, NMSC 312-610-5615 Anticipated Completion Date: June 30, 2025

View Audit 334317

Finding 516363 (2024-001)

Significant Deficiency 2024

Keokuk County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of Contact Person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to...

Segregation of Duties Name of Contact Person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 334234

Finding 516362 (2024-001)

Significant Deficiency 2024

Pacific Northwest University of Health Sciences

WA

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

Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. A...

Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. Action taken: Identified common causation factors that contributed to the finding. In this particular case, the student’s budget was adjusted more than once due to changes in both her graduation date and her tuition rate during her final year. Her budget was not adjusted correctly. The issues identified are: o Identifying when tuition charge has been adjusted. o Having another financial aid staff member review changes to the budget adjustment(s). The following actions were taken: o Reached out for assistance identifying students whose tuition has been reduced. Was provided with a report we can run before financial aid disburses, “FA Registration”, which will capture all changes to each student’s tuition. o Have included running this report in the steps completed prior to aid disbursement. o Reviewed and refined steps already in place, specifically addressing the processing of budgets for students who are off cycle during a semester. Steps are outlined in document “23-24 Budget Adjustment Quality Control Process” and include:  Templates to be used for correct budgets.  Assigned two-letter comment codes that will identify students with budget adjustment for off-cycle attendance.  Created a selection set in PowerFAIDS to capture students with these comment codes in a report.  Created a task in PowerFAIDS that will assign review of completed budget adjustments to a specific FA staff member. She will review the calculations and sign off on them. These actions have been implemented effective immediately. Name of Responsible Party: Laura Pendleton, Director of Financial Aid Anticipated completion date: October 30, 2024

View Audit 334218 Questioned Costs: $1

Finding 516361 (2024-001)

Significant Deficiency 2024

Manhattan School of Music

NY

Student Financial Aid

MSM remain stronly committed to timely and accurate reporting. NSC, MSM's 3rd party processor, investigated the matter and identified a breakdown of its standard processing procedure to notify an institution of any errors in uploaded files to NSLDS. Had NSC followed its standard, MSM would have resu...

MSM remain stronly committed to timely and accurate reporting. NSC, MSM's 3rd party processor, investigated the matter and identified a breakdown of its standard processing procedure to notify an institution of any errors in uploaded files to NSLDS. Had NSC followed its standard, MSM would have resubmitted the file to NSC, and no error or delay in reporting would have occurred Yes MSM acknowledges its responsibility for actions taken by third-party service providers. MSM has reinforced training for the Office of the Registrar staff related to NSC reporting and requested updates of its NSC procedure manual, inlcuding date validation that ensures accurate and timely submission of information to NSC from MSM and, ultimately, NSLDS. Specifically, the Office of the Registrar staff will complete live and on-demand webinards to reinforce knowledge and the strict adherence to federal reporting requirements and timeliness by the end of the calendar year 2024. In addition, training on NSC reporting from our Student Information System (SIS) (Jenzabar 1) will be conducted yearly, or as necessary when upgrades or patches are released affecting NSC reporting. MSM Office of the Registrar staff attended such training on November 25, 2024.

View Audit 334195

Finding 516357 (2024-002)

Significant Deficiency 2024

Liberty County District School Board

FL

Questioned Costs Procurement, Suspension & Debarment Special Tests & Provisions

Planned Corrective Action - The District has established procedures for ensuring compliance with Davis-Bacon Act requirements. In the future, if Federally funded construction projects are awarded, we will make sure that we require from the contractor weekly certified payrolls and District personnel...

Planned Corrective Action - The District has established procedures for ensuring compliance with Davis-Bacon Act requirements. In the future, if Federally funded construction projects are awarded, we will make sure that we require from the contractor weekly certified payrolls and District personnel will verify the payrolls received. Anticipated Completion Date - December 30, 2024. We will provide documentation to the FDOE supporting the allowability of the questioned costs and discuss the necessary corrective action needed to comply. Responsible Contact Person - Mandie Fowler, Director of Curriculum & Instruction

View Audit 334181 Questioned Costs: $1

Finding 516356 (2024-001)

Material Weakness 2024

Liberty County District School Board

FL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Planned Corrective Action - The District has established procedures for ensuring and documenting that Title I program resources are properly allocated to schools. The District, under a new Director of Finance, has set up spreadsheets to assist in calculating a percentage to be allocated to each sch...

Planned Corrective Action - The District has established procedures for ensuring and documenting that Title I program resources are properly allocated to schools. The District, under a new Director of Finance, has set up spreadsheets to assist in calculating a percentage to be allocated to each school based on a rank system, which will comply with the FDOE guidelines for allocating funds to schools based on the percentage of students from low-income families. These formula-based spreadsheets are used when preparing the budget when applying for the grant each year. Throughout the fiscal year expenditures are checked to make sure the monies spent are still in rank order for each school. Anticipated Completion Date - December 30, 2024. We will provide documentation to the FDOE supporting the allowability of the questioned costs totaling $247,075 or allocate that amount to the applicable underfunded Title I schools. Responsible Contact Person - Mandie Fowler, Director of Curriculum & Instruction

View Audit 334181 Questioned Costs: $1

Finding 516355 (2024-002)

Significant Deficiency 2024

Fox C-6 School District

MO

Questioned Costs

The District has worked with their accounting system and resolved the issues for the report that is generated. The District will print a customized report that includes all expenditures for the specified date range that will include all expenditures. That report will be presented to the Board for al...

The District has worked with their accounting system and resolved the issues for the report that is generated. The District will print a customized report that includes all expenditures for the specified date range that will include all expenditures. That report will be presented to the Board for all expenditures to be approved.

View Audit 334174 Questioned Costs: $1

Finding 516352 (2024-001)

Significant Deficiency 2024

Fox C-6 School District

MO

Allowable Costs / Cost Principles

The District will be sure to complete a time and effort log or have employees complete a semi-annual certification for all employees that are working on the Special Education or Title program.

View Audit 334174

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

Finding: 2024-003

View Audit 334160

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

Department: Food Service

View Audit 334160

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

Name of contact person and title: Melissa Phillips, Administrative Assistant

View Audit 334160

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

Anticipated completion date: 9/30/24

View Audit 334160

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

School’s response:

View Audit 334160

Finding 516321 (2024-003)

Significant Deficiency 2024

Niangua R-V School District

MO

Niangua R-5 School District will train staff to meet verification deadline requirements and have an review and sign off as the confirming official on the applications.

View Audit 334160

Finding 516320 (2024-001)

Material Weakness 2024

Davinci Academy of Science and the Arts

UT

Material Weakness Reporting Internal Control / Segregation of Duties

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of ...

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. DaVinci Academy of Science and the Arts did not properly report the correct amount of all ESSER funds expended. Responsible Individuals: Business Manager and Executive Director Corrective Action Plan: Management will provide the USBE with the correct the amount of all ESSER funds expended. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.

View Audit 334150

Finding 516293 (2024-001)

None 2024

Flossmoor School District 161

IL

Reporting § 200.512

Identifying Number: 2024-001 Finding: Untimely Submission of the Data Collection Form Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are com...

Identifying Number: 2024-001 Finding: Untimely Submission of the Data Collection Form Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are completed on a timely basis. The Business Office will continue to follow internal policies and procedures, including deadlines for fiscal year-end process. Contact Person Responsible for Corrective Action Plan: Frances A. LaBella, Associate Superintendent Completion Date: December 30, 2024

View Audit 334142

Finding 516286 (2024-004)

Significant Deficiency 2024

Western Oregon University

OR

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

Finding: 2024-004 Federal Agency Name: U.S. Department of EducationAssistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Awards must be coordinated among the various programs and with other federal and nonfede...

Finding: 2024-004 Federal Agency Name: U.S. Department of EducationAssistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA minus the student’s EFC (as computed by the central processor and included on the student’s SAR/ISIR). During the testing of compliance for Eligibility, it was noted students who worked as Resident Advisors for the University, did not have their Title IV aid adjusted for amounts they received via direct payments to cover the cost of their housing. As a result, the University compensated the students for the cost of their housing outside the normal processing and packaging of Title IV aid, resulting in $26,572 of Direct Loans being disbursed to student’s in excess of their financial need. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: The current year (2024-25) Resident Assistant benefits have been taken into consideration for all applicable students. Anticipated Completion Date: 9/10/2024

View Audit 334105 Questioned Costs: $1

Finding 516280 (2024-003)

Significant Deficiency 2024

Western Oregon University

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 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 ti...

Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 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 timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: There is documentation of the student’s enrollment status in the National Student Clearinghouse (NSC) for each month starting Fall term 2023. The enrollment reporting process functions such that each month, the National Student Loan Data System (NSLDS) sends a file to NSC for the students who have been awarded federal aid. NSC then sends a file back to NSLDS for the students on the list. This return file then updates the NSLDS enrollment reporting section in their system. NSC will not send enrollment for students if they are not on the NSLDS list. To do so would be a FERPA violation. For the student in question, NSLDS did not place their name on the list for reporting enrollment until June 2024. A second call to NSLDS has been placed requesting a response as to why this student was not reported. Anticipated Completion Date: 12/6/2024

View Audit 334105

Finding 516274 (2024-002)

Material Weakness 2024

Western Oregon University

OR

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. As a result of implementing a new Student Information System, the SAS reconciliations were not completed during the current year. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: Management agrees with this finding. Compliance on this finding was resolved by the end of the award year with reconciliation being completed by the end of June 2024. Financial aid implemented a new Financial Aid Management System (FAMS) starting with the 2023-24 year which caused delays in processes; however, the office is caught up with reconciliations, and going forward this compliance area is not an issue. Anticipated Completion Date: Completed June 2024

View Audit 334105

Finding 516273 (2024-002)

Significant Deficiency 2024

Anne Arundel County Board of Education

MD

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

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-...

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the Board continue with established policies and procedures implemented in November 2023 to ensure that documentation supporting the Board’s review and approval of the monthly FSR reimbursement requests are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Reporting and Grants Management will ensure that the Board’s review and approval of monthly FSR reimbursement requests and documented and retained. Name(s) of the contact person(s) responsible for corrective action: Ruth Grasty Director of Financial Reporting and Grants Management Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 334095

Finding 516272 (2024-001)

Significant Deficiency 2024

Anne Arundel County Board of Education

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-...

2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Purchasing Office had processes in place to ensure debarment status was checked before contract award. Both the contract checklist (attached) and the Qualifications Affidavit in the solicitation template contained debarment status language to ensure the necessary checks took place. Despite these processes, a contract for curriculum materials was not checked for debarment status before contract award. The cause of that oversight seems to be the different procurement processes used in instructional materials procurements. The contract was not competitively awarded, so they did not require a qualifications affidavit, which would have ensured the debarment status was checked. In this instance, a checklist was not included in the contract file as required, which would have also triggered a debarment check. In response, the Purchasing Office is adding a third layer of oversight - requiring that a revised contract affidavit (sample attached) is completed for every contract award. Language was added to the current contract affidavit that contains an affirmation by the contractor that they are not suspended or debarred by any government entity – local, state, and federal. The relevant section is highlighted in the attachment. To summarize, the Purchasing Office will engage the three processes listed below to ensure timely debarment checks are conducted on every contract, regardless of funding source. 1) Contract Checklist 2) Qualifications Affidavit 3) Contract Affidavit Name(s) of the contact person(s) responsible for corrective action: Mary Jo Childs Director of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 334095

Corrective Action Plans

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