Corrective Action Plans

Finding 524822 (2024-001)

Significant Deficiency 2024

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

Finding 524810 (2024-002)

None 2024

Corban University

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The Financial Aid Office will conduct monthly reconciliations between student accounts and COD to identify mismatched disbursement dates and correct them. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vic...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The Financial Aid Office will conduct monthly reconciliations between student accounts and COD to identify mismatched disbursement dates and correct them. 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

Finding 524808 (2024-001)

Significant Deficiency 2024

Corban University

OR

Questioned Costs Student Financial Aid Significant Deficiency

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and u...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and understood across the Registrar and Financial Aid offices. 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 Questioned Costs: $1

Finding 524797 (2024-001)

Significant Deficiency 2024

Maniilaq Association

AK

Eligibility Significant Deficiency

Finding 2024-001 Eligibility - Noncompliance and Significant Deficiency in Internal Control Over Compliance Planned Corrective Actions: Historical documentation on patient eligibility for IHS beneficiary status residing in paper financial files (in use at the time of roll and scroll registration) wi...

Finding 2024-001 Eligibility - Noncompliance and Significant Deficiency in Internal Control Over Compliance Planned Corrective Actions: Historical documentation on patient eligibility for IHS beneficiary status residing in paper financial files (in use at the time of roll and scroll registration) will be scanned in the BMW registration system making them a permanent part of the patients’ electronic health record. Registration staff is requesting beneficiary identification at the time of registration for all patients that do not have it in their EHR. Project is ongoing. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance. Individual(s) Responsible for Corrective Action Plan Kandy Barlow VP of Health Services 907-442-7385 Anticipated Completion Date: March 31, 2025

View Audit 344184

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524790 (2024-002)

Significant Deficiency 2024

University of Dubuque

IA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180 Questioned Costs: $1

Finding 524789 (2024-001)

Significant Deficiency 2024

University of Dubuque

IA

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

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the acad...

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the academic year are being reported on a timely basis Financial Aid Office will manually check and enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates Financial Aid Office and Registrar’s Office have been continually working together to ensure timely and accurate reporting of withdrawal dates. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180

Finding 524786 (2024-001)

Significant Deficiency 2024

Villanova University

PA

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

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error hav...

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error have been implemented. The department has created a submission file consisting of new graduates only to be transmitted to the National Student Clearinghouse at the end of May and another at the end of June to identify any additional students to report. In addition, the University has created a Graduation Audit Report to be used internally to verify the change in status for students who graduated, and a final validation check performed by the Senior Assistant Registrar for Student History to confirm accuracy of student status. Name of contact person: Susan Morgan, Director of Technical Student Systems, Registrars Office Anticipated Completion date: May 2025 in conjunction with the next submission of graduation files

View Audit 344168

Finding 524785 (2024-003)

Significant Deficiency 2024

Bethel University and Affiliates

MN

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

View Audit 344164 Questioned Costs: $1

Finding 524779 (2024-002)

Material Weakness 2024

Bethel University and Affiliates

MN

Student Financial Aid Material Weakness Reporting

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that 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 that 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. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

View Audit 344164

Finding 524778 (2024-003)

Significant Deficiency 2024

Mercyhurst University

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: The University is required to report changes in student status within sixty days to the National Student Loan Data System (NSLDS) and, per the testing performed, seven students, whose status changed during the period under audit, were not communicated within the required sixty days to the N...

Finding: The University is required to report changes in student status within sixty days to the National Student Loan Data System (NSLDS) and, per the testing performed, seven students, whose status changed during the period under audit, were not communicated within the required sixty days to the NSLDS. View of responsible officials and corrective action: Management understands the importance of timely reporting of student status changes to NSLDS. The Registrar’s Office has implemented a process change to generate the reports at the 15th and the end of every month for reporting to NSLDS. This should ensure that students that have a late change are identified when the report is run at the end of the month.

View Audit 344161

Finding 524777 (2024-001)

Significant Deficiency 2024

Mercyhurst University

PA

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

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to ret...

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to retain the records of former students. While we are certain that required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance that the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students.

View Audit 344161

Finding 524775 (2024-002)

Significant Deficiency 2024

Mercyhurst University

PA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Managemen...

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Management understands the need for accurate calculation of funds to be returned. An additional step has been added to the process for the return of Title IV funds process. All calculations are now reviewed by a manager before release to ensure funds are calculated correctly and returned in the appropriate timeframe.

View Audit 344161 Questioned Costs: $1

Finding 524768 (2024-005)

Significant Deficiency 2024

Resources for Human Development, INC

PA

Procurement, Suspension & Debarment § 200.318

Management will reinforce the requirements of the procurement policy and the importance of complying with its provisions with the applicable staff. This will be completed by June 30, 2025.

View Audit 344160

Finding 524761 (2024-004)

Significant Deficiency 2024

Resources for Human Development, INC

PA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties § 200.302

Management will review the SFDS protocols and processes with the appropriate staff in order enable the consistent application of sliding fees. This will be completed by June 30, 2025.

View Audit 344160

Finding 524754 (2024-003)

Material Weakness 2024

Resources for Human Development, INC

PA

Cash Management Material Weakness § 200.302

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustm...

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustments in order to allow for the prevention, or timely detection and correction of, errors in federal draw-down requests. This will be completed by June 30, 2025.

View Audit 344160

Finding 524737 (2024-002)

None 2024

Resources for Human Development, INC

PA

Reporting Internal Control / Segregation of Duties

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in ...

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in meeting this goal. Management also believes that audit timing for the fiscal year ended June 30, 2023 was an anomaly based on the identified need for corporate restructuring that was occurring concurrently with audit process. This added complexity to the subsequent event disclosures and testing required. Additionally, RHD formally affiliate with Inperium as disclosed in Note 3 of the accompanying financial statements. The affiliation was closed on December 11, 2024. Systems and closing procedures will be evaluated and redesigned as part of the affiliation integration process.

View Audit 344160

Finding 524730 (2024-001)

None 2024

University of Montevallo

AL

Eligibility

Memorandum TO: Warren Averette FROM: Paul G. Barnes, EdS, Director TRIO Upward Bound Programs SUBJECT: Corrective Action Plan DATE: 13 December 2024 ANTICIPATED COMPLETION DATE: December2024 CONTACT: Paul G. Barnes In order to prevent the loss or misplacement of student applications to the Universi...

Memorandum TO: Warren Averette FROM: Paul G. Barnes, EdS, Director TRIO Upward Bound Programs SUBJECT: Corrective Action Plan DATE: 13 December 2024 ANTICIPATED COMPLETION DATE: December2024 CONTACT: Paul G. Barnes In order to prevent the loss or misplacement of student applications to the University of Montevallo TRIO Upward Bound Programs, the following policy has been implemented: Applications to the UM TRIO Upward Bound Programs (UMUB) are submitted in two ways: electronically or on paper. Paper applications are scanned by the Academic Coordinator and stored as described below. Electronic applications are generally scans of paper applications made by the target school counselors and emailed to us. Those files are stored in the same place as scans of paper applications. The digital copies of all applications are stored on the UMUB SharePoint site, TRIO Upward Bound Programs Staff, access to which is limited to members of the TRIO Upward Bound Program Staff and which is administered by the Director and the Technology Coordinator. Applications are stored in UB Staff > Documents > Academic component > AY XXX-XXX > Recruiting > New Student Applications > PX, where AY XXXX-XXXX is the year designation for the Academic year (e.g. AY 2024-2025) and PX is the designation for the grant that served the school that the student is applying from (e.g. P1 for UB1, and P2 for UB2). There is no P3 (UBMS), as students do not apply directly for the Upward Bound Math Science Program but are placed in there based on their application and interview. Electronically submitted applications are printed out in their entirety, and they and the applications submitted on paper go to the Academic Coordinator who evaluates them for academic need and At High Risk of Academic Failure eligibility. They are then sent to the Director who evaluates them for Low Income and First-Generation eligibility. All Eligibility criteria are marked on page 2 of the application, and pertinent information is recorded on the Applicant Information Sheet by the Technology Coordinator. The paper copies are then given to the Administrative Assistant who will store them until the student has completed the application process and a determination is made to accept the student or not. If the student is accepted, they are added to the Student Information Database (currently Empower) and the hard copy of the application is stored in a binder by anticipated graduation cohort until the sixth year after that cohort graduated (i.e. when they no longer need to be tracked.

View Audit 344154

Finding 524729 (2024-001)

None 2024

Nybdc Local Development Corporation

NY

Subrecipient Monitoring Matching / Level of Effort / Earmarking

We acknowledge the auditor’s comments and can confirm that the following corrective action has been implemented as of December 2024: Management has revised the process for identifying, segregating, and transferring Microloan repayments from a monthly process to a weekly process. This change will ens...

We acknowledge the auditor’s comments and can confirm that the following corrective action has been implemented as of December 2024: Management has revised the process for identifying, segregating, and transferring Microloan repayments from a monthly process to a weekly process. This change will ensure Microloan repayments received by our operating account are transferred to the appropriate MRF accounts within 10 working days. By changing the frequency of this task, we will enhance our compliance with Microloan requirements and more effectively manage Microloan program funds.

View Audit 344151

Finding 524727 (2024-001)

Significant Deficiency 2024

American Near East Refugee Aid

DC

Subrecipient Monitoring Reporting

Identifying Number: 2024-001 Finding: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Corrective Actions Taken: The first step is to submit the outstanding FFATA under U.S. Department of State coope...

Identifying Number: 2024-001 Finding: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Corrective Actions Taken: The first step is to submit the outstanding FFATA under U.S. Department of State cooperative agreement SPRMCO22CA0136, which was completed on February 17, 2025. Moving forward, Anera will implement a centralized tracking system to ensure the timely and accurate submission of all annual and government reporting requirements, as well as reports that may be triggered based on spending. A centralized tracker will be created for all agreements under the grants and compliance team, including specific deadlines and submission dates with links to those submissions. This system will provide visibility across all departments and stakeholders, ensuring that all reporting obligations are met promptly and preventing any oversight. The tracker will be maintained and regularly updated to reflect any changes in requirements or deadlines, fostering better coordination and accountability across Anera. Additionally, in order to enhance transparency and avoid potential siloing, the grants and compliance team will be expanded to include multiple team members with clear roles and responsibilities. This expansion will ensure that there is no over-reliance on any one individual, allowing for cross-functional knowledge sharing and greater collaboration. The team will work together to review and validate all reporting requirements, ensuring a more thorough and accurate submission process moving forward. This approach will also facilitate the identification and mitigation of any potential risks early in the process, strengthening overall compliance efforts. Name of Responsible Official and Title: Shanna Todd, International Grants Director Date Corrective Action Plan Executed: 2-3 Months (This time includes the onboarding new team members, building out the trackers, cross referencing all current obligations and rolling out to wider team.)

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Finding 524726 (2024-001)

Material Weakness 2024

Detroit Housing Commission

MI

HUD Housing Programs Material Weakness Reporting

Condition: The Commission did not submit the required financial report and performance report timely. Planned Corrective Action: The Capital Team Project Manager will reconcile HUD’s EPIC and ELOCCs system with Yardi monthly to ensure the timely filing of capital projects close out. This tracking cr...

Condition: The Commission did not submit the required financial report and performance report timely. Planned Corrective Action: The Capital Team Project Manager will reconcile HUD’s EPIC and ELOCCs system with Yardi monthly to ensure the timely filing of capital projects close out. This tracking critical spreadsheet created by the Lead Performance Officer, will trigger key reporting dates for the DHC Capital Fund Program to remain in compliance with HUD reporting deadlines. At a minimum, monthly, this critical spreadsheet is distributed to the Supervisor of Capital and the Lead Performance Officer to ensure compliance. Contact person responsible for corrective action: Michael Edwards, Capital asset & Skilled Trades Supervisor Anticipated Completion Date: 6/30/2025

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Corrective Action Plans

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