Corrective Action Plans

Finding 508401 (2024-002)

Significant Deficiency 2024

TX

Questioned Costs School Nutrition Programs Eligibility

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verif...

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verification of Eligibility for Free or Reduced Price Meals The District has reviewed the findings and identified areas of improvement for Child Nutrition. The district will audit the Child Nutrition information after verification each year to ensure that the correct changes have been made in the software. Internal Controls will be reviewed and strengthened to ensure proper coding moving forward.

View Audit 329023 Questioned Costs: $1

Finding 508396 (2024-001)

Significant Deficiency 2024

Manchester University, Inc.

IN

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Offic...

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Office of Institutional Effectiveness will be held responsible for specific deadlines each month. The report will be completed after verification of graduation requirements and credentialing or other status changes are completed in Colleague by the Registrar's Office. Ellucian Colleague processes will be fully utilized for NSC file generation. The Registrar and Associate Registrar complete different steps in the credentialing process, but will review the student records together to ensure accuracy and timely completion. Submission of graduation status to NSC will occur after each academic term (fall and spring semester, January and summer sessions) and submission of other status changes will occur monthly and follow-ups will occur within four business days.

View Audit 329021

Finding 508387 (2024-002)

None 2024

Point Loma Nazarene University and Subsidiary

CA

Student Financial Aid Matching / Level of Effort / Earmarking

Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Finan...

Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Financial Aid software: • Disbursement Eligibility criteria that flags “Exceeds COA”, preventing disbursement • Automatic calculations of the COA based on the number of weeks in which the student is enrolled. (Our previous software required all manual review and adjustments to COA when a student was only enrolled in a single module.) Any changes to the number of weeks or to enrollment as a whole, will result in a Need Packaging Reaction, prompting staff to re-run Cost of Attendance calculations and Need Packaging as needed. Furthermore, Point Loma will review and revise procedures for mandatory recalculations of COA, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024

View Audit 329006

Finding 508383 (2024-001)

None 2024

Point Loma Nazarene University and Subsidiary

CA

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

Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Acti...

Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024

View Audit 329006

Finding 508382 (2024-001)

None 2024

Faith Evangelical Lutheran Seminary

WA

This Finding was addressed by a retraining session held on October 15, 2024, during which staff and faculty discussed the reasons this Finding occurred. All parties were reminded that impartial SAP compliance monitors, and not faculty, will determine when a student should be administratively withdra...

This Finding was addressed by a retraining session held on October 15, 2024, during which staff and faculty discussed the reasons this Finding occurred. All parties were reminded that impartial SAP compliance monitors, and not faculty, will determine when a student should be administratively withdrawn for non-participation(un-offcial withdrawal), according to school policy. This will that un-official withdrawals will be addressed withing the quarter of attendance, and will ensure that R2T4 funds are returned within the regulated timeline. In addition, the institution is implementing an internal audit policy to test students at week eight or nine of the ten-week quarter who may be subject to an unoffical withdrawal. This will allow the Administration time to contact the student and administer forced withdrawal and, if needed, submit R2T4 within 45 days.

View Audit 329004

Finding 508381 (2024-001)

Significant Deficiency 2024

Oklahoma City Community College

OK

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student...

October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student enrollment reporting is critical, as it is sent to the National Student Clearinghouse, which then provides this data to the National Student Loan Data System (NSLDS). This information is used to determine students' enrollment status, which is essential for the administration of financial aid, particularly for calculating grace periods and repayment timelines for student loans. Corrective Actions and Process Changes Once we identified the reporting issue, we re-ran the reports using the previous method, prior to the saved list implementation, to compare the results. We thoroughly reviewed the enrollment numbers for both semesters to ensure all students were correctly reported. In addition, we contacted the National Student Clearinghouse to make the necessary corrections. To ensure this issue is fully resolved moving forward, we have implemented a more rigorous internal process, including thorough testing and random sampling. We now compare reported enrollment data against actual student enrollment for each semester, allowing us to verify that all students are accurately reported. These enhanced measures will safeguard against similar oversights in the future. Challenges with Clearinghouse Resolution While we completed our internal corrections, we experienced significant delays in finalizing the data updates due to customer service challenges on the National Student Clearinghouse’s side. After escalating the issue, we were able to receive assistance from a representative on October 23rd, which we believe will resolve the discrepancies. Expected completion date: 10/31/24 Partys Responsible: Dr. Jason Johnson, Vice President for Student Affairs - Amanda Williams- Mize, Assistant Vice President for Enrollment Services, Registrar Contact Information: jason.k.johnson@occc.edu 405-682-1611 ext. 7784 amanda.williams-mize@occc.edu, 405-682-7537

View Audit 328998

Finding 508380 (2024-003)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documenta...

Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documentation. IHA hired a full time, HQS/NSPIRE certified inspector in August 2023 to ensure HQS inspections are completed in a timely manner and within regulation. IHA has also purchased the BOB.AI software which monitors and schedules upcoming initial, reinspection’s, annual and special inspection requests. Inspection letters are generated in this program as well as results/finding items. Inspections spreadsheets have been created for tracking purposes by the HCV Director. The inspector reviews his weekly schedule with the HCV Director for accuracy.

View Audit 328993

Finding 508379 (2024-002)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Cash Management Internal Control / Segregation of Duties

Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper proced...

Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper procedures for calculations and allowances. All HCV program specialists have received rent calculations certifications and have been instructed to correct any prior errors immediately. The Compliance Officer is also doing random tenant file audits on a monthly basis. This should make finding

View Audit 328993

Finding 508378 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Subrecipient Monitoring

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a mon...

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a monthly basis to prevent the accumulation of interfund receivables and payables. IHA will also strengthen its cash management practices by reviewing and reconciling inter-program balances on a monthly basis. This process will include a detailed review to ensure that program-level cash components are accurate, and resources are being used exclusively for their intended purposes.

View Audit 328993

Finding 508377 (2024-005)

Significant Deficiency 2024

Walthill Public Schools District #13

NE

Subrecipient Monitoring

The district has received the subcontractor list and is gathering the certified payroll certifications for the subcontractors onsite. We will work with the general contractor to ensure the documents we have are complete. We will monitor that these controls are taking place as planned.

View Audit 328983

Finding 508376 (2024-004)

Significant Deficiency 2024

Walthill Public Schools District #13

NE

Reporting Subrecipient Monitoring Cash Management

The district will add procedures to monitor that additional spending is not being done after the grant is fully spent. In addition, the District will implement controls to ensure approved budget amendments are secured prior to spending. The District will also implement controls to ensure prior year ...

The district will add procedures to monitor that additional spending is not being done after the grant is fully spent. In addition, the District will implement controls to ensure approved budget amendments are secured prior to spending. The District will also implement controls to ensure prior year spending is considered for reimbursement requests. The District will work with the grantor agency on any necessary correction of reports and submission of supporting documentation since both grants' reimbursement requests have been fully paid for the total grant amounts.

View Audit 328983

Finding 508375 (2024-003)

Significant Deficiency 2024

Walthill Public Schools District #13

NE

Reporting

We had run an incorrect report for the children with disabilities, but have added procedures to ensure the correct report is ran of the survey date. We will add procedures to review the list of children to ensure it is accurate for current IEP's prior to submitting the application.

View Audit 328983

Finding 508373 (2024-001)

None 2024

Housing Authority of the City of Lumberton

NC

Questioned Costs HUD Housing Programs

The Authority continues to strengthen its procedures surrounding tenant rent calculations at initial and recertification reviews in the Low-Income Housing Program. A second review, conducted by a Public Housing Manager, will be required for all such calculations. All Public Housing staff will be req...

The Authority continues to strengthen its procedures surrounding tenant rent calculations at initial and recertification reviews in the Low-Income Housing Program. A second review, conducted by a Public Housing Manager, will be required for all such calculations. All Public Housing staff will be required to maintain a Rent Calculation Certification on a bi-annual basis. For the file in question, a correction was made with an effective date of May 1, 2024.

View Audit 328981 Questioned Costs: $1

Finding 508352 (2024-001)

Material Weakness 2024

Family Life Academy Charter Schools

NY

Subrecipient Monitoring Cash Management Reporting

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and...

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and ARP grants to report since we had incurred expenses exceeding the cash payments received prior to 6/30/2022. The original reports were reviewed by NYSED during their desk audit and they did not report any issues with it. In the future, we will contact the agency for the reporting instruction clarifications.

View Audit 328954

Finding 508347 (2024-001)

Material Weakness 2024

Kuspuk School District

AK

Eligibility School Nutrition Programs Cash Management

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear...

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

View Audit 328940

Finding 508344 (2024-002)

Significant Deficiency 2024

Mountain View Housing, INC

NC

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

Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue ...

Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to approve and sign checks and periodically review the financial statements. Proposed Completion Date: The Board will implement the above procedure immediately. Findings and Questioned Costs - Major Federal Awards Programs Audit Finding: 2024-002 Segregation of Duties Same as above.

View Audit 328919

Finding 508343 (2024-001)

Significant Deficiency 2024

Aransas Pass Housing Authority

TX

Questioned Costs HUD Housing Programs Significant Deficiency

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. C...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Christina Beard, Executive Director, will be responsible to implement this corrective action by March 31, 2025.

View Audit 328914 Questioned Costs: $1

Finding 508330 (2024-004)

Significant Deficiency 2024

Northeast (webutuck) Central School District

NY

Allowable Costs / Cost Principles HUD Housing Programs

Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages o...

Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certification or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee’s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy that specific requirement of this and other appendices under 2 CFR Part 225, and that the total compensation for the individual employees: (3) is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3)). Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly or semi-annual certifications and that the time allocation on the grant is reported accurately. Corrective Action: A comprehensive tracking plan has been implemented to ensure the costs objectives associated with each employee for each period is tracked and PAR is returned for the corresponding period. Corrective Action Implemented by: The Corrective Action will be implemented by Robert Farrier, School Business Administrator in conjunction with Treasurer Kelly Kilmer. Corrective Action Implementation Date: This corrective action plan has already been implemented on 9/15/24.

View Audit 328890

Finding 508325 (2024-001)

Significant Deficiency 2024

Oakridge Public Schools

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Ent...

Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Entitlement Commodities, 230900 and 240900 Award Year End: September 30, 2023 and September 30, 2024 Recommendation: The School District should follow established procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Food Service Director, October 2024 If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.

View Audit 328887

Finding 508324 (2024-003)

Significant Deficiency 2024

Independent School District No. 32

MN

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

2024-003 FINDING Contact Person – Mark Lundin, Superintendent Corrective Action Plan – The District will review policies and procedures for submitted certified payrolls. Completion Date – November 30, 2024

View Audit 328884

Finding 508306 (2024-003)

Significant Deficiency 2024

Isd #599 Fertile-Beltrami

MN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency

2024-003 Contact Person – Superintendent Brian Clarke Corrective Action Plan – The District will ensure all payroll rates are approved by the Board. Completion Date – November 30th, 2024

View Audit 328881

Finding 508304 (2024-001)

Material Weakness 2024

Creo College Preparatory Charter School

NY

Subrecipient Monitoring Cash Management Reporting

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and ...

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and consult with on financial management and will work closely with the new partner to ensure that future Education Stabilization Fund Annual Reports are completed based on the amount of reimbursement payments received. Management will review the report and confirm the reported amounts agree to the reimbursement payments received on the NYSED Grants Finance reports via the NYSED website.

View Audit 328877

Finding 508302 (2024-002)

Material Weakness 2024

Hebrew Language Academy Charter School 2

NY

Subrecipient Monitoring Cash Management Reporting

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensur...

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

View Audit 328856

Finding 508299 (2024-001)

Material Weakness 2024

Hebrew Language Academy Charter School

NY

Subrecipient Monitoring Cash Management Reporting

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensur...

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

View Audit 328855

Finding 508286 (2024-001)

Significant Deficiency 2024

Higher Institute of Arts and Technology, Inc.

IN

Equipment & Real Property Management § 200.313

CORRECTIVE ACTION PLAN Nov 6, 2024 Higher Institute for Arts and Technology (the School) provides its Corrective Action Plan for the fiscal year ended June 30, 2024. FINDING 2024-001 – RECONCILIATION OF PHYSICAL INVENOTRY – Significant Deficiency Planned corrective action: The School through the edu...

CORRECTIVE ACTION PLAN Nov 6, 2024 Higher Institute for Arts and Technology (the School) provides its Corrective Action Plan for the fiscal year ended June 30, 2024. FINDING 2024-001 – RECONCILIATION OF PHYSICAL INVENOTRY – Significant Deficiency Planned corrective action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will implement procedures and provide additional training to school staff that are responsible for taking physical inventory to ensure results are reconciled with fixed asset property records maintained by EVE. Responsible officers: Jeffrey Larkins, Director of Finance and Accounting; Javier Dimas, Vice-President of Operations Estimated completion date: May 15, 2025 22

View Audit 328831

Corrective Action Plans

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