Corrective Action Plans

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Finding 519470 (2024-002)
Significant Deficiency 2024
Corrective Actions Taken or Planned: In March 2024, the Program Executive Director implemented a formal written signature process on the access database check request sheets as written evidence of the review and approval process for housing payments. Person Responsible for Corrective Action: Rache...
Corrective Actions Taken or Planned: In March 2024, the Program Executive Director implemented a formal written signature process on the access database check request sheets as written evidence of the review and approval process for housing payments. Person Responsible for Corrective Action: Rachel Erpelding, Executive Director, the Kim Wilson Housing Team, and Accounts Payable Specialist.
Finding 519466 (2024-001)
Significant Deficiency 2024
Corrective Actions Taken or Planned: In March 2024, the Kim Wilson Housing Team implemented a formal written process in which the Grant Program Specialist documents evidence of the monthly match tracking process and the Executive Director approves each printed tracking sheet from the housing databas...
Corrective Actions Taken or Planned: In March 2024, the Kim Wilson Housing Team implemented a formal written process in which the Grant Program Specialist documents evidence of the monthly match tracking process and the Executive Director approves each printed tracking sheet from the housing database. Person Responsible for Corrective Action: Rachel Erpelding, Executive Director and Kim Wilson Housing Team.
Response: The Organization has worked with the auditors to ensure that fieldwork is performed timely for the June 30, 2024 year end engagement in order to meet the required deadline for the submission to the Federal Audit Clearinghouse.
Response: The Organization has worked with the auditors to ensure that fieldwork is performed timely for the June 30, 2024 year end engagement in order to meet the required deadline for the submission to the Federal Audit Clearinghouse.
Noncompliance with Special Testing Requirements
Noncompliance with Special Testing Requirements
Criteria: The School’s major federal program carries with it certain special testing requirements where an amount equal to 10% of the monthly principal and interest payments needs to be deposited into a cash reserve account.
Criteria: The School’s major federal program carries with it certain special testing requirements where an amount equal to 10% of the monthly principal and interest payments needs to be deposited into a cash reserve account.
Condition: We noted six months for which the School was not in compliance with the above noted requirement.
Condition: We noted six months for which the School was not in compliance with the above noted requirement.
Known Questioned Costs: None
Known Questioned Costs: None
Likely Questioned Costs: None
Likely Questioned Costs: None
Context: We noted six months for which the School did not have the required amount, equal to 10% of the monthly principal and interest payments, deposited into a cash reserve account.
Context: We noted six months for which the School did not have the required amount, equal to 10% of the monthly principal and interest payments, deposited into a cash reserve account.
Cause: Management oversight.
Cause: Management oversight.
Recommendation: We encourage the School to continue its efforts to ensure that 10% of the monthly principal and interest payments are deposited into a cash reserve account. We recommend performing recalculations and moving the funds at the end of each month.
Recommendation: We encourage the School to continue its efforts to ensure that 10% of the monthly principal and interest payments are deposited into a cash reserve account. We recommend performing recalculations and moving the funds at the end of each month.
Views of responsible officials and planned corrective action: We are in agreement with the finding. Management is in the process of creating an updated system to ensure compliance with this requirement moving forward.
Views of responsible officials and planned corrective action: We are in agreement with the finding. Management is in the process of creating an updated system to ensure compliance with this requirement moving forward.
2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect...
2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 6 had program enrollment effective dates that did not match institutional records, 4 had incorrect program enrollment statuses, and 4 had incorrect program begin dates. Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. View of responsible official: MACC believes some of the current audit finding may be attributed to the SIS system implemented in November 2022; and these finding occurred before we implemented our Corrective Action Plan, which we have faithfully followed every month. As noted below, our CAP is a process in which we review enrollment records reported to NSLDS and update, if needed. Supporting documentation and verification of the work that has been done this past year can be provided, if needed. As a result of the continued commitment to submit correct data from our system to NSLDS every month, this fall MACC paid more than $12,000 to our software vendor (Jenzabar) for enhancements needed to collect, retain and report enrollment data. • Jenzabar created and installed a custom process to update the NSC status start date and NSC program status start date to the Last Date of Attendance. We began running this custom process with the November 2024 NSC enrollment file. • Jenzabar created and installed a custom process to update program begin dates for students returning to the same program to the original program begin date. We have implemented this as a scheduled process beginning December 2024. We are confident future reviews of our NSLDS enrollment reporting records will reflect greater accuracy. MACC would like to note, although the auditors are noting several students with effective date issues and failure to report students timely, we have evidence of student records being exported from our system every month and recorded in the Program Certification Details within NSLDS, but the data is not found in the Program Enrollment Effective Date area of NSLDS. We acknowledge the data must be in both areas of NSLDS, but we believe there is evidence that we submitted our records as required. We are hopeful the new enhancements will correct this issue. As disclosed in our audit response for 2022-2023, the corrective action plan has been slightly altered, but continues: • The Registrar will review data in J1 and submit enrollment records to NSC each month. • The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. • After the enrollment file is accepted by NSC, MACC will review correct enrollment information in NSLDS for all students who have withdrawn from all classes and/or have had an R2T4 calculation, for accuracy. o The Registrar, or designee, will review the data in NSC. o The Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disburs...
2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
View Audit 338400 Questioned Costs: $1
2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of t...
2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of the responsible official: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required – usually within 1-5 days from the date it is discovered. This finding of a “late return” is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college’s attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Registrar, Deans, and Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
Federal Agency Name: Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Finding Summary: Catholic Charities has documented procurement proced...
Federal Agency Name: Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Finding Summary: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Corrective Action Plan: Procurement, suspension and debarment procedures were largely decentralized across the agency. In response, the organization has an internal, cross-functional compliance team that has reviewed and is developing process changes to ensure appropriate systems are developed and documentation is maintained for purchasing related to federal programs. Responsible Individuals: Chief Legal Officer, Controller Anticipated Completion Date: June 30, 2025
Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Di...
Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Division Director Housing Stability will implement a rent reasonableness completion and review process. Responsible Individuals: Chief Program Officer Anticipated Completion Date: June 30, 2025
In response to the findings identified in the Albert Gallatin Area School District's audit report for the year ending June 30, 2024, the District submits the following corrective action plan. Administration acknowledges the weaknesses and deficiencies in
In response to the findings identified in the Albert Gallatin Area School District's audit report for the year ending June 30, 2024, the District submits the following corrective action plan. Administration acknowledges the weaknesses and deficiencies in
The City's Department of Housing has an established policy in place for determination of initial program eligibility as well as determination of continued program eligibility. The City's Department of Housing will review its procedures for executing Housing Assistance Payment (HAP) contracts and a...
The City's Department of Housing has an established policy in place for determination of initial program eligibility as well as determination of continued program eligibility. The City's Department of Housing will review its procedures for executing Housing Assistance Payment (HAP) contracts and amendments and make any necessary procedural adjustments to ensure that ineligible families do not receive program assistance. The City's Department of Housing will enhance its quality control review in this area and provide additional guidance to staff as necessary.
The City's Department of Housing has an established policy for outlining and tracking documents required for determining initial program eligibility for applicants as well as continued program eligibility for program participants. The policy also addresses the determination and documentation of rent...
The City's Department of Housing has an established policy for outlining and tracking documents required for determining initial program eligibility for applicants as well as continued program eligibility for program participants. The policy also addresses the determination and documentation of rent reasonableness. The department will enhance its quality control review in this area and provide additional guidance to staff as necessary.
The City's Director of Housing will keep abreast of when the "General Depository Agreement," HUD Form 51999 (GDA) expires and will promptly notify the Director of Finance. The City's Director of Finance will ensure a new depository agreement is signed.
The City's Director of Housing will keep abreast of when the "General Depository Agreement," HUD Form 51999 (GDA) expires and will promptly notify the Director of Finance. The City's Director of Finance will ensure a new depository agreement is signed.
The City's Housing Department has reviewed its policy on Housing Quality Standards (HQS) deficiencies and extensions for correction of identified deficiencies and has made procedural adjustments to ensure that any deficiency correction extension is included in the participant file.
The City's Housing Department has reviewed its policy on Housing Quality Standards (HQS) deficiencies and extensions for correction of identified deficiencies and has made procedural adjustments to ensure that any deficiency correction extension is included in the participant file.
Staff turnover and vacancies during the fiscal year resulted in a few timesheets lacking supervisory approval. Additionally, the time sheet submission and approval process throughout the City is currently completed by paper or email. It is manual and cumbersome. To ensure time sheets are approved ti...
Staff turnover and vacancies during the fiscal year resulted in a few timesheets lacking supervisory approval. Additionally, the time sheet submission and approval process throughout the City is currently completed by paper or email. It is manual and cumbersome. To ensure time sheets are approved timely, the payroll coordinator will be auditing all timesheets every payroll and will follow up on those lacking approval to ensure they are approved and accurate. The City is also in the final stages of selecting new ERP software, which will be implemented during fiscal years 2026 and 2027. This new system will support electronic timesheets and approvals which will streamline the process and allow the payroll coordinator to audit the timesheets more efficiently.
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