Corrective Action Plans

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Management Agrees with the findings. The replacement reserve deficiency will be funded in the amount of $1,720. Management will ensure that the replacement reserve deposits are made on a timely basis in the future.
Management Agrees with the findings. The replacement reserve deficiency will be funded in the amount of $1,720. Management will ensure that the replacement reserve deposits are made on a timely basis in the future.
Management Agrees with the findings. The residual receipts account deficiency was funded on November 30, 2023 in the amount of $16,997. Management will ensure that the residual receipts account is properly funded in the future.
Management Agrees with the findings. The residual receipts account deficiency was funded on November 30, 2023 in the amount of $16,997. Management will ensure that the residual receipts account is properly funded in the future.
Management agrees with the finding. The excess funds were accrued to submit to HUD.
Management agrees with the finding. The excess funds were accrued to submit to HUD.
Management Agrees with the findings. The replacement reserve deficiency will be funded in the amount of $149. Management will ensure that the replacement ereserve deposits are made on a timely basis in the future.
Management Agrees with the findings. The replacement reserve deficiency will be funded in the amount of $149. Management will ensure that the replacement ereserve deposits are made on a timely basis in the future.
Management Agrees with the findings. The security deposit deficiency will be funded in the amount of $408. Management will ensure that the securty deposit account is properly funded in the future.
Management Agrees with the findings. The security deposit deficiency will be funded in the amount of $408. Management will ensure that the securty deposit account is properly funded in the future.
Management Agrees with the findings. The managing agent has begun to repay the loan by depositing an extra $10,000 into the account. Management will continue to deposit an additional monthly amount of $5,00 until the loan is paid back.
Management Agrees with the findings. The managing agent has begun to repay the loan by depositing an extra $10,000 into the account. Management will continue to deposit an additional monthly amount of $5,00 until the loan is paid back.
Management Agrees with the findings. Management has requested a retroactive suspension from HUD for the missing debt service saving deposits.
Management Agrees with the findings. Management has requested a retroactive suspension from HUD for the missing debt service saving deposits.
Management Agrees with the findings. The excess funds were accrued to submit to HUD.
Management Agrees with the findings. The excess funds were accrued to submit to HUD.
Finding 503949 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Expl...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid maintains a log of all Title IV withdrawals, and going forward it will provide access to this log to the Registrar’s Office and will notify the Associate Registrar each time a student is determined to be withdrawn for R2T4 purposes. This will ensure that the Financial Aid Office and the Registrar’s Office are aligned with regard to a student’s Title IV enrollment status. This will be particularly helpful to ensure compliance for students enrolled in modules, where a student could be considered withdrawn for a semester even if their transcript shows that credit was earned for all of their officially attempted credits. This compliance issue was discovered and remediated by Drake prior to the audit as part of our own internal review process. Upon each submission of the graduation data file to the National Student Clearinghouse, the Registrar’s Office will double-check the count of awarded degrees that appear on the submission file and compare it to the number of awarded degrees as reported by Drake’s student information system. Additionally, shortly after each file is submitted to the NSC, the Registrar’s Office will cross-check a sample of JD graduates against both the NSC database and the NSLDS database to ensure that the graduation status for graduates of the JD program is being accepted and processed by the NSC as expected, and that they are in turn properly reported to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar and Brandi Miller, Assistant Director of Financial Aid. Planned completion date for corrective action plan: September 1, 2024.
Finding 503947 (2024-002)
Significant Deficiency 2024
Action taken in response to finding: We have 26 active awards that would be non-R&D. Grants and Contracts Accounting (GCA) is currently reviewing each to verify if all had check boxes checked as R&D on Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Sub...
Action taken in response to finding: We have 26 active awards that would be non-R&D. Grants and Contracts Accounting (GCA) is currently reviewing each to verify if all had check boxes checked as R&D on Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward. Once we have the impacted population, GCA will issue a modification for those to draw attention to the error. In addition, GCA will ensure internal procedures are updated to review this field and verify proper identification prior to subaward execution. Anticipated Completion Date: September 30, 2024 Person Responsible: Tracy Walters, Director of Grants and Contracts Contact/Responsible Party: Tracy Walters, Director of Grants and Contracts Contact Information: trwalte@clemson.edu
Finding 503946 (2024-001)
Significant Deficiency 2024
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the r...
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the requestor if they had also added the missing hours via a CU Special Pay. Additionally, as of 06/21/2024, the Late Timesheet option was turned off on CU Special Pay to strengthen controls. Individuals now contact payroll@clemson.edu for assistance. Once contacted the payroll/timekeeping team will update the timecard and ensure the missed pay is added to the next payroll cycle, assuming an emergency/off-cycle check is not needed. The College of Engineering and Applied Sciences (CECAS) will take action to strengthen internal controls to ensure accuracy and compliance. We will establish clear procedures to verify employee payroll data via paylines, as well as cross checking with CU Payroll to ensure changes are properly documented and authorized. We will provide ongoing training for departmental payroll staff on best practices and compliance requirements. Anticipated Completion Date: September 17, 2024 Person Responsible: Central Payroll – Ami Hood, Payroll Director; CECAS – Keri Cortese, Director of Procurement and Payroll Operations Contact/Responsible Party: Ami Hood, Payroll Director Contact Information: hooda@clemson.edu
View Audit 326225 Questioned Costs: $1
Management should ensure there is enough oversight by qualified accounting personnel who have the ability to research and resolve reconciling items. Additionally, management should create a review process where they can enforce their existing policies.
Management should ensure there is enough oversight by qualified accounting personnel who have the ability to research and resolve reconciling items. Additionally, management should create a review process where they can enforce their existing policies.
The management company should reimburse the project for overpaid management fee in the amount of $10,442 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the HUD approved management agreement.
The management company should reimburse the project for overpaid management fee in the amount of $10,442 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the HUD approved management agreement.
View Audit 326223 Questioned Costs: $1
Recommendations Management should establish internal controls and procedures to ensure that excess residual receipts reserve funds are remitted timely.
Recommendations Management should establish internal controls and procedures to ensure that excess residual receipts reserve funds are remitted timely.
View Audit 326223 Questioned Costs: $1
Management should transfer $3,391 from the operating account in order to fully fund the tenant security deposits account.
Management should transfer $3,391 from the operating account in order to fully fund the tenant security deposits account.
View Audit 326223 Questioned Costs: $1
Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required fili...
Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required filing is completed timely.
Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350....
Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Management agrees with the finding and has transferred the residual receipts.
Management agrees with the finding and has transferred the residual receipts.
View Audit 326222 Questioned Costs: $1
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
View Audit 326222 Questioned Costs: $1
Management has submitted their Affirmative Fair Housing Marketing Plan with an effective date of September 27, 2024.
Management has submitted their Affirmative Fair Housing Marketing Plan with an effective date of September 27, 2024.
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely...
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds. Move in EIVs - All move in files will be sent to our in house comp...
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds. Move in EIVs - All move in files will be sent to our in house compliance department and Franklin Group has an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90 day reminders for all move in. Existing Tenant EIV - It is the policy that all existing tenant EIV and 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The RM is required during monthly visits to spot check at least 5 existing tenants. Gross Rent Change and Medical Reporting - The policy states that all Gross Rent Changes are to be completed as approved by the new rent schedule - The Community Manager is required to scheduled appointments with all residents to sign the effective gross rent change and file in tenants files, it is also required that residents 50059s are signed and in the file, the Community Manager has taken the latest HUD training with our in house HUD Compliance Manager- The Regional Manager will also spot check files to be certain that all Gross Rent Changes are in its 6 part file folders. Medical reporting records were discussed in our HUD Compliance Training and all expenses must be in the 6-part file folder. Again, the RM will continue to spot check files during the monthly required inspections. All HUD Communities were required to participate in the HUD Training as a reminder tool. Security Deposit - Franklin Companies has a policy that all security deposit refunds must be submitted within the 3 days move out period. This situation was due to the changeover in Management.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and loans will not be permitted based on HUD requirements going forward.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and loans will not be permitted based on HUD requirements going forward.
View Audit 326222 Questioned Costs: $1
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
View Audit 326221 Questioned Costs: $1
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