Corrective Action Plans

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Finding 522600 (2024-001)
Significant Deficiency 2024
Starting with the 2024-25 program year, the Office has reinstated its standard for disbusrement reporting to COD, following the replacement of the dedicted Loan Coordinator. Disbursements will now be reported within 48 hours of the internal disbursement to the student account. ...
Starting with the 2024-25 program year, the Office has reinstated its standard for disbusrement reporting to COD, following the replacement of the dedicted Loan Coordinator. Disbursements will now be reported within 48 hours of the internal disbursement to the student account. Furthermore, the procedures for monthly fund reconciliation and disbursement monitoring will be rigorously followed to ensure compliance with federal regulations and to uphold Financial Aid Best Practices in awarding federal aid and managing funds.
CONTACT PERSON: Dennis Locke, Director of Finance and Budget, dlocke@cityofspartanburg.org CORRECTIVE ACTION: The City will ensure that all applicable airport project reports are completed and filed timely. PROPOSED COMPLETION DATE: Prior to June 30, 2025
CONTACT PERSON: Dennis Locke, Director of Finance and Budget, dlocke@cityofspartanburg.org CORRECTIVE ACTION: The City will ensure that all applicable airport project reports are completed and filed timely. PROPOSED COMPLETION DATE: Prior to June 30, 2025
Finding 2024-003 Finding Summary: Current obligation information was not reported correctly to the federal awarding agency Responsible Individual: Lacey Donaldson, Clerk-Treasurer Corrective Action Plan: Internal controls will be put in place to ensure Project and Expenditure Reports were pr...
Finding 2024-003 Finding Summary: Current obligation information was not reported correctly to the federal awarding agency Responsible Individual: Lacey Donaldson, Clerk-Treasurer Corrective Action Plan: Internal controls will be put in place to ensure Project and Expenditure Reports were prepared in accordance with governing requirements. Anticipated Date of Correction Action Plan: Correction will be made on the next annual report due in April of 2025.
Finding 522594 (2024-001)
Significant Deficiency 2024
Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to r...
Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to report that in January 2024 CNY Works welcomed a new Director of Youth Services which has led the department to transform and flourish in the last year. Under the new leadership, the Youth Department has implemented new internal controls, processes and has staff focused and running programs under the Workforce Innovation and Opportunity Act (WIOA). Nonetheless, CNY Work youth staff along with the Executive Director and the Director of Youth Services will review current policies and procedures to ensure these are operating effectively reflecting allowable activities and allowable costs (including hours worked by youth in the program) are allocated and charged accurately to the federal program. Emphasizing the importance of internal controls to ensure documents are signed by designated individuals to comply with requirements. The Director of Youth Services will continue to review timesheets, eligibility forms, and signatures, along with other requirements of the program to ensure internal control procedures are adequate and operating as intended. Finally, management will continue to analyze methods for monitoring the operational effectiveness of the applied internal controls on compliance and document any mitigating controls that are developed and implemented. Contact Person Responsible for Corrective Action Plan: Rosemary Avila-Ticio Executive Director, CNY Works Phone Number: 315-477-6901 Email: ravila@cnyworks.com Anticipated Completion Date of Corrective Action Plan: March 30, 2025
2024-001 Federal Direct Student Loans, ALN 84.268 Condition: There were incorrect cost of attendance amounts used to calculate subsidized loans for 5 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus expected family co...
2024-001 Federal Direct Student Loans, ALN 84.268 Condition: There were incorrect cost of attendance amounts used to calculate subsidized loans for 5 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus expected family contribution and other financial aid to calculate the amount of subsidized loans that students are eligible to receive. Cause: The University’s student information system (SIS) uses rules to determine which budget components should be assigned to students' cost of attendance based on housing choice, program of student, and classification. It was determined early in the packaging process that some of those budget components were being assigned incorrectly. A support ticket was opened with SIS helpdesk and the issue was corrected within 48 hours. Once the SIS was corrected to assign budget components according to the rules for each budget, all students were reassigned budgets to reflect the correct amounts. Effect: Subsidized loans could have been improperly calculated at the time of packaging, but prior to applying these funds to student charges, there are student eligibility criteria (SEC) rules in place that prevents aid from transmitting if the student is not entitled. In addition, staff weekly run reports to review cost of attendance and subsidized/unsubsidized eligibility. Context: During the compliance audit testing of federal direct student loans, it was determined that the incorrect cost of attendance total was used on the student loan worksheet to calculate eligibility for 5 out of 40 students tested, but SIS reflected the updated correct cost of attendance. Recommendation: We recommend the University continue to monitor the system for future issues and consider updating the supporting documentation as appropriate in the future. View of Responsible Officials and Planned Corrective Action: Management has corrected the SIS. In reviewing the students affected, it was determined the calculated subsidized loan amounts were still appropriate even though the student loan worksheet did not match the cost of attendance reflected in the SIS.
Finding 522589 (2024-001)
Significant Deficiency 2024
Management’s response/corrective action plan: The Town acknowledges the finding and is taking steps to address the deficiency. Actions include implementing procedures to verify and document contractor eligibility. These measures will ensure contractors are not suspended or debarred, particularly for...
Management’s response/corrective action plan: The Town acknowledges the finding and is taking steps to address the deficiency. Actions include implementing procedures to verify and document contractor eligibility. These measures will ensure contractors are not suspended or debarred, particularly for federally funded projects. The Town is committed to maintaining compliance and protecting federal funding.
Management agrees with the finding and is in the process of revising internal controls to address this issue.
Management agrees with the finding and is in the process of revising internal controls to address this issue.
View Audit 341811 Questioned Costs: $1
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) – Material Weakness Condition: While performing our audit procedures, we noted that CAFB included the a $5 million grant from Fairfax County on their SEFA even though CAFB is considered a beneficiary related to this grant. Views of ...
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) – Material Weakness Condition: While performing our audit procedures, we noted that CAFB included the a $5 million grant from Fairfax County on their SEFA even though CAFB is considered a beneficiary related to this grant. Views of Responsible Officials and Planned Corrective Actions: As stated in the report, the Organization respectfully disagrees with both the substance and the severity of the finding. In RSM’s proposal to the Organization, the firm indicates that it offers proactive advice to its clients: “Specialists RSM has a deep bench of specialists locally and nationwide available to advise CAFB and the engagement team on issues as they arise. Relevant specialists cover areas such as: unrelated business income from alternative investments, multi-state taxation, Federal single audits, and information technology. Proactive resolution of accounting issues We find that year-round communication and a proactive approach to accounting issues help clients avoid surprises at the end of the audit process. For this reason, we encourage clients to call us to discuss new transactions as they arise.” [emphasis added] We agree that the independent auditor cannot be part of the Organization’s internal controls. In this instance, the Organization conducted its own research into the nature of the beneficiary agreement and reached a conclusion that it should not be included on the SEFA. During audit planning, we discussed this position with the audit partner and manager who recommended that it should be included on the SEFA. Following the resignation of the engagement partner and manager, a new resource assigned to conclude our engagement by the firm disagreed with that position and raised this finding. Had the initial audit team remained and we excluded the grant, we assume that we would have received a finding for its exclusion. As to the severity of the finding, we disagree that the instance rises to the level of a material weakness. Although we concede the amount of the award ($5 million) is significant, its inclusion/exclusion from the SEFA did not impact the selection of major programs and was a singular decision-making instance of an unusual form of award, irrespective of the amount involved. As for corrective action, considering the infrequency of beneficiary agreement awards to non-profit organizations, it is improbable that the Organization will receive such an award again. Nevertheless, if the Organization encounters an unusual transaction or award, we will continue to perform our own research on the award/transaction and form our independent conclusion (as we did in this instance) and refrain from taking actions that might imply the independent auditor is part of the Organization’s internal control structure.Anticipated Completion Date: February 2025
Finding 2024-003: Special Tests and Provisions – Accountability for USDA Foods – Material Weakness in Internal Control Over Compliance; Other Matter Compliance Finding Condition: On August 8, 2024, the Compliance and Human Resource teams at CAFB received a complaint alleging falsification of reports...
Finding 2024-003: Special Tests and Provisions – Accountability for USDA Foods – Material Weakness in Internal Control Over Compliance; Other Matter Compliance Finding Condition: On August 8, 2024, the Compliance and Human Resource teams at CAFB received a complaint alleging falsification of reports concerning TEFAP items by several employees in DC Operations. An investigation was immediately launched by the HR team. As a result of the investigation, CAFB discovered approximately $60,000 of TEFAP inventory shrinkage was recorded but not timely reported to the state agencies. Views of Responsible Officials and Planned Corrective Actions: The Organization takes seriously any allegation of improper behavior or falsification of reports. As indicated in the finding, the Organization conducted a thorough investigation, notified the affected granting agencies, and proactively addressed root causes identified from the investigation. The Organization has identified the following root causes with corrective actions noted below: See uploaded corrective action plan for chart. Anticipated Completion Date: October 2024 – January 2025
View Audit 341804 Questioned Costs: $1
Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible c...
Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible community partner organization was able to order approximately 100 pounds of TEFAP food from CAFB’s website. CSFP – We noted that for one out of 40 individual participants sampled for CSFP, one participant’s original enrollment documents supporting eligibility was missing. The organization did have the participant’s re-enrollment documents for the subsequent fiscal year. This is related to a person being eligible to receive food. Views of Responsible Officials and Planned Corrective Actions: The Organization's investigation into the root causes of the two incidents revealed clerical errors. For the TEFAP incident, a mistake in the partner organization's profile allowed access to USDA food via our online ordering portal. Regarding the CSFP participant, the initial eligibility documents were misplaced, but subsequent reauthorization documents were available. The Organization’s planned corrective actions with respect to the two instances include the following: TEFAP partner eligibility:  Review and enhance existing procedures for establishing partner organization profiles; and  Establish a periodic reconciliation of partner organization’s authorized to access TEFAP commodities in the online ordering portal with a listing of authorized TEFAP partners CSFP eligibility:  Review and enhance existing procedures for filing individual eligibility documents; and  Continued internal reviews by the Organization’s compliance department covering the filing of individual eligibility documents Anticipated Completion Date: March 2025
View Audit 341804 Questioned Costs: $1
Finding 2024-001: Suspension and Debarment – Material Weakness in Internal Control Over Compliance Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25...
Finding 2024-001: Suspension and Debarment – Material Weakness in Internal Control Over Compliance Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Views of Responsible Officials and Planned Corrective Actions: The Organization's ability to perform the current manual control for suspension and debarment was impacted by the sustained high level of activity. In December 2024, the Organization developed and implemented a Robotic Process Automation (RPA) tool designed to identify new vendors added to the accounts payable system. This tool then searches sam.gov for these vendors and sends an email with the results. Utilizing artificial intelligence, the tool also creates a service ticket for any suspect vendors that require manual research. Anticipated Completion Date: December 2024
Finding No. 2024-001: Financial Statement and Schedule of Expenditures of Federal Awards (SEFA) Preparation Responsible Individuals: Fran White, Executive Director Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the financial st...
Finding No. 2024-001: Financial Statement and Schedule of Expenditures of Federal Awards (SEFA) Preparation Responsible Individuals: Fran White, Executive Director Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the financial statements and will continue to have the independent auditor prepare the annual financial statements. Additionally, the Organization will prepare the credit loss calculation going forward. Anticipated Completion Date: Ongoing
Management is in the process of implementing a more thorough review to ensure purchase orders have been fulfilled and costs have been incurred in order for expenditures to be recognized in the District's accounting system as well as implementing processes to review open purchase orders on an at leas...
Management is in the process of implementing a more thorough review to ensure purchase orders have been fulfilled and costs have been incurred in order for expenditures to be recognized in the District's accounting system as well as implementing processes to review open purchase orders on an at least monthly basis. Additionally, Management is in the process of implementing secondary review and approval procedures of grant expenditures to ensure all grant expenditures have adequate support prior to being included in claim submission reports.
View Audit 341795 Questioned Costs: $1
Personnel Responsible for Corrective Action Plan: Dr. Anika Lodree, Dean of Student Services Anticipated Completion Date: 02.28.2025* Corrective Action Plan: In receipt of these findings, the College intends to heavily scrutinize data files before submission and utilize all resources at its disposal...
Personnel Responsible for Corrective Action Plan: Dr. Anika Lodree, Dean of Student Services Anticipated Completion Date: 02.28.2025* Corrective Action Plan: In receipt of these findings, the College intends to heavily scrutinize data files before submission and utilize all resources at its disposal to obtain guidance on the correct method for submitting any similar future data files at the time of their occurrence and initial submission. * This is assuming that the Gainful Employment reporting is certified through the National Student Clearinghouse. Until the Gainful Employment report is certified, they have advised that no further changes may be submitted.
Action Taken: The district concurs with this finding. The staff of the district has been properly trained to use the Paid Lunch Equity (PLE) Tool provided by USDA to determine adequate price for paid lunches. The CFO will make the calculation annually and will take to the board any changes that need...
Action Taken: The district concurs with this finding. The staff of the district has been properly trained to use the Paid Lunch Equity (PLE) Tool provided by USDA to determine adequate price for paid lunches. The CFO will make the calculation annually and will take to the board any changes that need to be made to ensure compliance with TDA pricing regulations.
Action Taken: The district concurs with this finding. The district has implemented internal controls over the collection of local revenue, in particular the fees for student reduced and full priced meals and ala cart items to include segregation of duties at the campus level. The staff accountant wi...
Action Taken: The district concurs with this finding. The district has implemented internal controls over the collection of local revenue, in particular the fees for student reduced and full priced meals and ala cart items to include segregation of duties at the campus level. The staff accountant will reconcile the monthly reports to the deposits received from the campuses. The CFO will verify the reconciliation process. This will be done monthly. We have also included monitoring and collections process of our negative balances. Each week a report will be generated and given to the campuses to be sent home with the students. A principal’s designee at each campus will follow up by phone with the parents. As a part of the district’s internal controls, at least monthly the administrative assistant to the CFO will physically observe and count meals served in each cafeteria and the CFO will compare that count to the point of sale systems reports to insure counting and claiming used for basic claims reporting is reasonable.
Action Taken: The district concurs with this finding. Management has clear job duties established and the CFO will be responsible for obtaining approval from TDA for capital asset purchases of $5000 or above.
Action Taken: The district concurs with this finding. Management has clear job duties established and the CFO will be responsible for obtaining approval from TDA for capital asset purchases of $5000 or above.
View Audit 341786 Questioned Costs: $1
Action Taken: The district concurs with this finding. The district has already addressed and taken action on this item. The 90K fiscal action from TDA was agreed upon. Sodexo reimbursed $45K by applying credit on the food service cost invoice. The administrative assistant to the CFO has been trained...
Action Taken: The district concurs with this finding. The district has already addressed and taken action on this item. The 90K fiscal action from TDA was agreed upon. Sodexo reimbursed $45K by applying credit on the food service cost invoice. The administrative assistant to the CFO has been trained on TDA Basic Claims process and prepares the claim monthly using reports from Systems Design. Going forward The Deputy Superintendent will provide oversight on the food service management company and the claims processing.
Finding Type: Compliance and Material Weakness. Name of Contact Person: Amy Dixon, Superintendent. Recommendation: We recommend that the District complete the required logs for each applicable employee. Corrective Action: The District will begin completing the necessary semi-annual certificat...
Finding Type: Compliance and Material Weakness. Name of Contact Person: Amy Dixon, Superintendent. Recommendation: We recommend that the District complete the required logs for each applicable employee. Corrective Action: The District will begin completing the necessary semi-annual certification and will have both the employee and Superintendent sign the certification. Proposed Completion Date: Immediately.
View Audit 341767 Questioned Costs: $1
Finding 2024-003: Student Financial Aid Cluster Special Tests and Provisions - Return of Title IV Funds View of Responsible Officials and Planned Corrective Action: Challenges with the new SIS resulted in errors in calculations and the delay of the return of Title IV funds to the DOE. After Cases/Ti...
Finding 2024-003: Student Financial Aid Cluster Special Tests and Provisions - Return of Title IV Funds View of Responsible Officials and Planned Corrective Action: Challenges with the new SIS resulted in errors in calculations and the delay of the return of Title IV funds to the DOE. After Cases/Tickets were reported to the SIS the System is now calculating correctly based on system updates and the process of returning funds is working as expected. Human error was a factor in two of the instances noted. The College has implemented internal controls and another level of review of the Return to Title IV calculations and return process based on the functioning of the new SIS.
View Audit 341751 Questioned Costs: $1
Finding 2024-002: Student Financial Aid Cluster Allowable Costs and Allowable Activities and Eligibility View of Responsible Officials and Planned Corrective Action: The College has documented procedures in place - Auto packaging and Repackaging within the new SIS calculates Pell awards based on the...
Finding 2024-002: Student Financial Aid Cluster Allowable Costs and Allowable Activities and Eligibility View of Responsible Officials and Planned Corrective Action: The College has documented procedures in place - Auto packaging and Repackaging within the new SIS calculates Pell awards based on the SAI and the Enrollment Intensity of the student (based on new Regulations starting with the 2024-2025 Academic Year). If the Cost of Attendance needs to be manually adjusted, the Financial Aid Staff member will document the breakdown of the COA. System Reports will be reviewed to allow for a secondary review of awards.
View Audit 341751 Questioned Costs: $1
Finding 2024-001: Student Financial Aid Cluster Cash Management View of Responsible Officials and Planned Corrective Action: The College has documented procedures in place - Prior to drawing funds from the DOE, Student Accounts and Financial Aid will review the amount showing available on COD and th...
Finding 2024-001: Student Financial Aid Cluster Cash Management View of Responsible Officials and Planned Corrective Action: The College has documented procedures in place - Prior to drawing funds from the DOE, Student Accounts and Financial Aid will review the amount showing available on COD and the disbursement amount that was made to students for the first draw of the AY, and then from each draw to the next for the remaining draws for an academic year. The amount drawn will be determined by the posted amounts to students' accounts. After COD is updated with the drawn funds Student Accounts and Financial Aid will again review to see if any excessive funds were drawn, and will return these funds to the DOE within seven days.
Finding 2024-003 Recommendations: The Director and the accounting department need to create procedures to ensure that both parties are reporting the same expenditures. Within the procedures created, there needs to be checks and balances to ensure that the recording is occurring before reporting figu...
Finding 2024-003 Recommendations: The Director and the accounting department need to create procedures to ensure that both parties are reporting the same expenditures. Within the procedures created, there needs to be checks and balances to ensure that the recording is occurring before reporting figures to the State. Action Taken: We agree with the recommendation. Our targeted implementation date is February 2025.
View Audit 341750 Questioned Costs: $1
Posting Financial Activity: (Currently being implemented) We are ensuring all financial activity is posted as intended, as part of our overall monitoring and grants administration processes. This involves enhanced oversight and verification procedures to confirm the accuracy of entries. Consistent R...
Posting Financial Activity: (Currently being implemented) We are ensuring all financial activity is posted as intended, as part of our overall monitoring and grants administration processes. This involves enhanced oversight and verification procedures to confirm the accuracy of entries. Consistent Reconciliation: (Currently being implemented with 3 meetings since July 1, 2024) Biweekly/monthly reconciliation meetings are conducted between the finance team and grants administration personnel. This ensures that adjusting entries are posted in a timely manner, maintaining the accuracy of the general ledger and financial reports filed with pass-through entities. Evaluation of Grants Management Policies and Procedures: (This has been included as part of our biweekly meetings) We are conducting a thorough evaluation of our current grants management policies and procedures. This review focuses on identifying areas for improvement and refining our practices to enhance accuracy and compliance. As part of our routine risk assessment program, we are incorporating regular evaluations of our grants management processes to identify and mitigate risks proactively. Staff Training and Development: (Upon review, it is evident that current staff possess the skills to execute the necessary procedures and processes. Former business office management did not monitor staff or provide opportunities for departmental communication. These issues are in the process of being corrected through regular staff meetings and discussions) We are providing training for our finance and grants administration staff to ensure they are well-versed in the updated procedures and reconciliation processes. This will help in maintaining the accuracy and integrity of our financial records. Cross-training programs are being implemented to ensure continuity and coverage during staff absences or turnover. Monitoring and Continuous Improvement: (In process of implementation. See details in attached documents) A monitoring process is being established to continuously assess the performance of our internal controls and reconciliation processes. Regular internal reviews are being conducted to ensure compliance and identify areas for further improvement. We have established clear timelines and reporting methodologies to facilitate ongoing monitoring and timely detection and correction of errors and misstatements.
Control Environment: (Currently being implemented through weekly staff meetings, individual finance meetings {accounts payable, payroll, accounts billable})We have established a stronger control environment by facilitating a tone of open communication and accountability throughout the business offi...
Control Environment: (Currently being implemented through weekly staff meetings, individual finance meetings {accounts payable, payroll, accounts billable})We have established a stronger control environment by facilitating a tone of open communication and accountability throughout the business office, reinforcing and ensuring proper governance structures are in place. This includes consistent oversight from administration and timely monitoring of all financial processes; including accounts billable, accounts payable, payroll, grants management and general accounting. Policies are being reviewed and updated on a consistent basis to reflect our commitment to a strong internal control framework. Risk Assessment: (See Risk Assessment Process Document) A comprehensive risk assessment process has been implemented to identify, evaluate, and manage financial reporting risks. This has included monthly and quarterly meetings with the business office staff and grants management personnel to identify and identify potential risks and corresponding mitigation strategies. We are implementing formal documentation procedures to ensure all evaluations and decisions are recorded systematically. Information and Communication: (See Procedures for Financial Information Management Document) We are designing and implementing procedures and records to support the identification, capture, and exchange of pertinent information. This includes grants management review meetings that are monthly, as well as monthly meetings with facilities, technology, athletics and food service directors. Training sessions are being conducted to ensure relevant staff understand their roles and responsibilities in maintaining effective communication channels. Control Activities: (See Procedure for Ensuring Effective Financial Management and Governance Document) We are developing and enforcing policies and procedures that ensure management and governance directives are carried out effectively. This includes cross-training, where appropriate, are implemented to ensure staff competency and adequate coverage during turnover or absences. Monitoring: (Monitoring and timeline development are in progress. Expecting completion by October, 2024) A monitoring process is being established to continuously assess the performance of internal controls. This includes regular management reviews, and follow-up procedures to ensure corrective actions are implemented in a timely manner. We have defined expected timelines and reporting Methodologies to facilitate ongoing monitoring and timely detection and correction of errors and misstatements.
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