Corrective Action Plans

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Finding 2025-001 Non – Adherence to Davis Bacon Act Criteria and Condition: The Authority did not appoint a Labor Compliance Officer, as is required to ensure the Davis Bacon Act is being followed. Recommendation: The auditors recommended that the Authority appoint a Labor Compliance Officer. Manage...
Finding 2025-001 Non – Adherence to Davis Bacon Act Criteria and Condition: The Authority did not appoint a Labor Compliance Officer, as is required to ensure the Davis Bacon Act is being followed. Recommendation: The auditors recommended that the Authority appoint a Labor Compliance Officer. Management Response: The Authority amended their contract with the consulting engineer and established the engineer as the Labor Compliance Officer. Name and Title of Contact Person Responsible for Corrective Action: Mark Catranis, Controller
View Audit 372028 Questioned Costs: $1
Finding 2025-001 - Procurements, Suspension and Debarment Corrective Action Plan Policy Review and Revision: The Executive Director will conduct a comprehensive review of the existing Procurement Policy to identify areas that can be clarified, simplified, or strengthened to ensure full compliance wi...
Finding 2025-001 - Procurements, Suspension and Debarment Corrective Action Plan Policy Review and Revision: The Executive Director will conduct a comprehensive review of the existing Procurement Policy to identify areas that can be clarified, simplified, or strengthened to ensure full compliance with HUD procurement regulations and Uniform Guidance (2 CFR Part 200). Any revisions will be presented to the Board of Commissioners for approval and adopted by the Authority. Staff Training on Procurement Requirements: The Executive Director, Jaime Chioldi, will identify and complete specialized training in federal procurement requirements specific to public housing authorities. The Director of Maintenance, Brian Calderara, will also complete this training. Documentation of training completion will be maintained in personnel files. Training will be with either Nan Mckay or NAHRO. Enhanced Oversight and Monitoring: Because the majority of procurement issues occurred within maintenance operations, the Executive Director will implement additional oversight measures for the Maintenance Department's purchasing activities. Monthly procurement reports will be generated to monitor cumulative vendor spending. The reports will be reviewed to identify when aggregate totals approach procurement threshold limits described in the policy. Any purchases nearing the small purchase or competitive bid limits will be reviewed and approved by the Executive Director before commitment. Documentation and Compliance Verification: The Authority will maintain complete procurement documentation for all purchases above the micro-purchase threshold, including quotes, justification, and vendor selection criteria. A quarterly internal review will be conducted to verify adherence to policy and identify any corrective needs. Responsible Official Jaime L. Chioldi, Executive Director Barre Housing Authority Email: jaime@barrehousing.org Phone: 802-476-7224 Anticipated Completion Date All corrective actions will be fully implemented by March 31, 2026.
View Audit 371931 Questioned Costs: $1
Enhance Controls over Enrollment Reporting Process: We will conduct periodic reconciliations (at least quarterly) between our internal records and NSLDS data to identify discrepancies and implement follow-up procedures for discrepancies, including timely investigation and resolution. lmprove Data Tr...
Enhance Controls over Enrollment Reporting Process: We will conduct periodic reconciliations (at least quarterly) between our internal records and NSLDS data to identify discrepancies and implement follow-up procedures for discrepancies, including timely investigation and resolution. lmprove Data Transmission and Reporting: We will review and update our current data transmission processes to ensure accurate and timely reporting of graduation data to NSLDS. Additionally, we will provide training to staff responsible for enrollment reporting on updated procedures. Monitoring and Quality Control: The Office of the Registrar (MS. Cristian Martinez, University Registrar) will work with the Office of Institutional Research (Ms. Alexandra Purdy, Institutional Research Associate) on enrollment reporting to the National Student Clearinghouse so that accurate records are then submitted to NSLDS to ensure compliance with federal regulations. Regular reviews of NSLDS data will be conducted to ensure accuracy and completeness by the Office of Financial Services (Mr. Preston Wheeler, Associate Director of Financial Aid and Students Accounts) once data are submitted. Responsible Personnel: The Office of the Registrar (Ms. Cristian Martinez, University Registrar) in conjunction with the Office of Financial Services (Mr. Preston Wheeler, Associate Director of Financial Aid and Student Accounts) will be responsible for implementing and overseeing the corrective action plan. The expected date for completion is December 15, 2025.
lmplement a Secondary Review Process: We will designate a financial aid staff member to perform a secondary review and approval of all Return of Title IV funds calculations to ensure accuracy. The Office of Accounting & Business Services will verify the calculations prior to issuing any payments. Th...
lmplement a Secondary Review Process: We will designate a financial aid staff member to perform a secondary review and approval of all Return of Title IV funds calculations to ensure accuracy. The Office of Accounting & Business Services will verify the calculations prior to issuing any payments. This process will be implemented within 30 days of the date of this letter. Enhance Documentation: We will develop standardized documentation procedures to accurately record withdrawal dates and payment period parameters including modifications to both PowerFAIDS and Jenzabar systems. This will be completed within 60 days of the date of this letter. Staff Training: We will provide training to staff within the following offices (Financial Services, Accounting & Business Services, Registrar) on the regulatory requirements association with Return to Title IV funds and the updated procedures and calculation processes within 30 days of the date of this letter. Quality Control: We will establish a quality control process to monitor and review Return of Title IV funds calculations on a regular basis, starting immediately. This includes installation of additional technology available to automate the calculation process in our systems. The University will also ensure the Office of Financial Services reviews system configurations at the start of each term. Responsible Personnel: The Office of Financial Services Director of Financial Aid and Student Accounts, Mr. Preston Wheeler, and Vice President for Enrollment Management, Mr. Alan Liebrecht will be responsible for implementing and overseeing the corrective action plan. In addition, the Assistant Vice President for Finance, Dr. Kaisa Holloway-Cripps will verify the implementation of the secondary review process, enhanced documentation procedures, and staff training and completed. Monitoring and Reporting: We will review the effectiveness of the corrective action plan to ensure compliance with federal regulations by mid fall 2025 semester and continue the review throughout the academic year. The Office of Financial Services will maintain records of the corrective actions taken and provide updates to the University's administration as necessary. The expected completion date of this corrective action plan is December 15, 2025.
Finding 2025-004: Student Financial Aid – Enrollment Reporting Finding: For four out of forty (10%) student enrollment reporting selections, the student's status change at the campus level and program was not properly reported to NSLDS with the required timeframe. Cause: The student's status change ...
Finding 2025-004: Student Financial Aid – Enrollment Reporting Finding: For four out of forty (10%) student enrollment reporting selections, the student's status change at the campus level and program was not properly reported to NSLDS with the required timeframe. Cause: The student's status change was after the last scheduled reporting transmission file of the semester, therefore their status change was not captured in the NSLDS reporting submission. Corrective Actions Taken or Planned: During the Summer of 2024, the Registrar’s Office was undergoing a period of transition. The newly appointed Registrar, Mai Aly, had just started in her role, and the Associate Registrar was out on medical leave. This staffing disruption contributed to delays in identifying and processing student status changes, which in turn impacted the timeliness of NSLDS reporting. To address this issue and strengthen compliance with NSLDS reporting requirements, the College has implemented the following measures: 1. Operations Calendar: The Registrar’s Office has developed and implemented a comprehensive Operations Calendar. As part of this calendar, withdrawal reporting tasks have been scheduled at the beginning of June, July, and August to ensure timely identification and submission of summer enrollment changes. 2. Designated Responsibility: The Associate Registrar has been assigned as the primary staff member responsible for reporting summer withdrawals to the National Student Clearinghouse (NSC), ensuring continuity and accountability in the reporting process. 3. Staff Training and Documentation: Relevant staff have been retrained on NSC/NSLDS reporting requirements to reinforce procedures for monitoring and reporting enrollment changes during the summer months to prevent future summer enrollment reporting issues. Contact Person Responsible: Jennifer Kenworth, Associate Registrar Lake Forest College Completion Date: 11/1/2025
Finding 2025-003: Student Financial Aid – Excess Cash Finding: Lake Forest College had excess cash for the FDL program ranging from $24,903 to $3,683,698 during the period of January 30, 2025 through February 7, 2025. In this situation, the excess cash exceeded one percent of total prior year drawdo...
Finding 2025-003: Student Financial Aid – Excess Cash Finding: Lake Forest College had excess cash for the FDL program ranging from $24,903 to $3,683,698 during the period of January 30, 2025 through February 7, 2025. In this situation, the excess cash exceeded one percent of total prior year drawdowns, and the amount was not returned within a seven-day period. Cause: The College drew down funds in advance of the Spring semester which is allowed based on the College’s cash management method. However, due to timing differences, the funds were not ultimately disbursed to students until 8 days after the drawdown was made. Corrective Actions Taken or Planned: On January 27, 2025, the Office of Management and Budget issued a directive pausing the disbursement of federal grants and loans, effective the following day. With uncertainty surrounding whether this pause applied to the FDL program, its duration, and the potential impact on the College’s cash flow, the Business Office made a one-time exception to its longstanding best-practice process. Instead of using finalized disbursement data, the College opted to draw funds based on preliminary disbursement information to mitigate potential financial disruption. To prevent recurrence and ensure compliance with federal cash management regulations, the College has implemented the following corrective measures: 1. Return to Standard Practice: The Business Office has resumed its standard drawdown procedure, which utilizes finalized disbursement data after the College’s add/drop date to ensure alignment with actual student disbursements. 2. Contingency Protocol for Exceptional Circumstances: In the event of future extraordinary circumstances, the Business Office will implement a conservative drawdown buffer, limiting initial draws to no more than 66% of preliminary disbursement estimates. This approach will reduce the risk of excess cash while maintaining operational flexibility. 3. Enhanced Coordination and Communication: The Business Office will maintain close coordination with the Office of Financial Aid, along with federal agencies and monitor guidance during periods of uncertainty to ensure timely and compliant decision-making. Contact Person Responsible: AJ Rodino, AVP for Business Lake Forest College Completion Date: 11/1/2025
View Audit 371906 Questioned Costs: $1
Finding 2025-002: Suspension and Debarment Finding: For two out of two vendors (100%) tested, the College did not provide sufficient documentation that a suspension and debarment check was performed prior to entering into a contract with the vendor. Cause: The College did not have controls in place ...
Finding 2025-002: Suspension and Debarment Finding: For two out of two vendors (100%) tested, the College did not provide sufficient documentation that a suspension and debarment check was performed prior to entering into a contract with the vendor. Cause: The College did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. Corrective Actions Taken or Planned: As part of the procurement process review, a more robust policy will be developed related to vendor management. The policy will include specific definitions and limits for the types of transactions (non-procurement, procurement contracts, “covered transactions”). By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026
Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurem...
Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026
Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...
Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.
Management agrees with the finding and funds will be included in current year's residual receipts deposit.
Management agrees with the finding and funds will be included in current year's residual receipts deposit.
View Audit 371873 Questioned Costs: $1
Finding 1162004 (2025-001)
Material Weakness 2025
Finding 2025-001: Reporting Planned Corrective Action: To prevent continued issues with late grant invoice submissions, we are implementing the following items: 1. Alignment of position responsibilities and cross-training within the Finance department – roles and updated job descriptions are being f...
Finding 2025-001: Reporting Planned Corrective Action: To prevent continued issues with late grant invoice submissions, we are implementing the following items: 1. Alignment of position responsibilities and cross-training within the Finance department – roles and updated job descriptions are being finalized to identify clear responsibilities with primary and backup employees responsible for these submissions, including always having three individuals in the department trained on the process. 2. Monitoring and review of grant submissions – we are now utilizing two monthly checklists, one for month-end processes and one for grant invoicing process, that are closely monitored by the CFO and the Accountant to ensure tasks are completed timely. Additionally, and prior to submitting, the grant invoice will be reviewed by an additional departmental sta􀆯, who is trained on the grant process. 3. Documentation – as part of the alignment of position responsibilities, the Finance department is working to fully update the standard operating procedure (SOP) for the grant invoicing process to ensure accurate steps and instructions are available to support the user(s) completing the tasks. Anticipated Completion Date: November 30, 2025. Responsible Contact Person: Phillip London, Chief Financial O􀆯icer
Management agrees with the findings and will ensure residual receipts deposits are made timely.
Management agrees with the findings and will ensure residual receipts deposits are made timely.
View Audit 371826 Questioned Costs: $1
2025-002 SEMAP Certification 1. The PHA Board will formally approve all future SE MAP submissions via board resolution prior to submission to HUD. 2. The Executive Director will ensure SEMAP is presented at the first board meeting following fiscal year-end for review and approval. 3. A compliance ch...
2025-002 SEMAP Certification 1. The PHA Board will formally approve all future SE MAP submissions via board resolution prior to submission to HUD. 2. The Executive Director will ensure SEMAP is presented at the first board meeting following fiscal year-end for review and approval. 3. A compliance checklist will be added to year-end reporting procedures to verify board approval and resolution documentation. Responsible Parties • Executive Director - Oversight • Board Chair-Approval Completion Date • Effective Immediately Tami Lucia Executive Director
Corrective action for the 2024-25 academic year has been completed. The Annual Cost information will be updated automatically by Herring Bank by August 30th each year to our website. The director of student accounts or her assignee will review the fees charged by Herring Bank at least every two year...
Corrective action for the 2024-25 academic year has been completed. The Annual Cost information will be updated automatically by Herring Bank by August 30th each year to our website. The director of student accounts or her assignee will review the fees charged by Herring Bank at least every two years to ensure they are at or below market value.
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Dominique J. Dunn, In...
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Dominique J. Dunn, Interim Executive Director, will be responsible to implement this corrective action by March 31, 2026.
View Audit 371807 Questioned Costs: $1
Authority's Response 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. Dominique J. ...
Authority's Response 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. Dominique J. Dunn, Interim Executive Director, will be responsible to implement this corrective action by March 31, 2026.
View Audit 371807 Questioned Costs: $1
The Township will designate the Township Treasurer with the responsibility of overseeing the construction draw requests, to ensure that the draw requests are not being duplicated across funding sources. The Township will also work with the Engineer to be sure they develop procedures on their end to ...
The Township will designate the Township Treasurer with the responsibility of overseeing the construction draw requests, to ensure that the draw requests are not being duplicated across funding sources. The Township will also work with the Engineer to be sure they develop procedures on their end to also ensure draw requests are not being duplicated.
View Audit 371795 Questioned Costs: $1
Corrective Actions: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid di...
Corrective Actions: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid disbursements and credit balance refunds in compliance with federal regulations. In the new system, financial aid disbursements will occur after the add/drop period, which better aligns with federal compliance timelines. Workday also provides automated reporting capabilities that allow the Student Financial Services office to easily identify students who have received Title IV funds, enabling staff to prioritize those accounts and ensure refunds are issued within the required timeframe. The system automates many manual processes, which increases efficiency and reduces the likelihood of delays. In addition, staff have received training on the new system and procedures, and an internal monitoring process now in place to ensure continued compliance with refund requirements. Contact Clara Wells at cwells1@trinity.edu or (210)999-7333.
In June 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the assets of...
In June 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the assets of the Cooperative.
In June 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the assets of...
In June 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the assets of the Cooperative.
Finding Number: 2025-001 Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Shorter University has reviewed its policies and procedures related to the timely Return of Title IV financial aid. On October 24, 2025 the Provost will meet with the SU faculty to review the importance of ...
Finding Number: 2025-001 Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Shorter University has reviewed its policies and procedures related to the timely Return of Title IV financial aid. On October 24, 2025 the Provost will meet with the SU faculty to review the importance of reporting a student's non-attendance to the Office of Student Engagement and Success. The Director of Student Engagement and Success is responsible for identifying students who have not attended classes in the last 14 calendar days. Upon identification, the non-attending students will be forwarded to the Office of the Registrar who will withdraw them from the University. The Director of Financial Aid runs the withdrawal report weekly and will verify that the last date of attendance and the date of notification are 14 days apart. The Director of Information Technology will modify the withdrawal report by adding a Notification Date that is 14 days from the last date of attendance. The late returns were a result of using an incorrect date of determination. The new amended withdrawal report will provide the actual date of notification based on the last date of attendance rather than the date manually entered into the system of record. Beginning with the 2026-2027 academic year Shorter University will no longer be an attendance taking institution for the traditional student population. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: 10/31/25
In Finding 2025-005, a condition was noted that a Federal Financial Report (FFR) submitted to the Department of Health and Human Services for the period ended September 14, 2024, contained incorrect data for the federal share of expenditures for the Organization’s federal grant C8ECS44676. Managemen...
In Finding 2025-005, a condition was noted that a Federal Financial Report (FFR) submitted to the Department of Health and Human Services for the period ended September 14, 2024, contained incorrect data for the federal share of expenditures for the Organization’s federal grant C8ECS44676. Management recognizes the importance of complying with federal reporting guidelines. In response to Finding 2025-005, management concurs, and procedures will be established to ensure that FFR filings are reviewed by a person other than the preparer prior to submission to ensure accurate reporting.
In Finding 2025-004, a condition was noted that the Uniform Data System (UDS) report submitted to DHHS for the year ended December 31, 2024 contained incorrect data for federal grant reporting, patient revenue and total expenses. Management recognizes the importance of complying with federal reporti...
In Finding 2025-004, a condition was noted that the Uniform Data System (UDS) report submitted to DHHS for the year ended December 31, 2024 contained incorrect data for federal grant reporting, patient revenue and total expenses. Management recognizes the importance of complying with federal reporting guidelines. In response to Finding 2025-004, management concurs, and efforts will be made to ensure that the revenue and expenses recorded are reconciled to the revenue and expenses on the UDS report prior to submission.
Finding 2025-003 Compliance Requirements A/B – Activities Allowed or Unallowed and Allowable Costs / Cost Principles, E – Eligibility, and N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding Auditee has not had time to evaluate Auditor’s finding. Corrective Act...
Finding 2025-003 Compliance Requirements A/B – Activities Allowed or Unallowed and Allowable Costs / Cost Principles, E – Eligibility, and N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding Auditee has not had time to evaluate Auditor’s finding. Corrective Action We will keep all required documentation in tenant files and establish processes and procedures to ensure compliance with the provisions in HUD Handbook 4350.3, HUD Handbook 4381.5, and the Regulatory Agreement. Anticipated Completion Date December 31, 2025
Finding 2025-002 Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comments on Finding We agree with the auditors’ finding. Corrective Action On July 24, 2025 we filed HUD Form 9839-B requesting retroactive approval to March 1, 202...
Finding 2025-002 Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comments on Finding We agree with the auditors’ finding. Corrective Action On July 24, 2025 we filed HUD Form 9839-B requesting retroactive approval to March 1, 2025. Anticipated Completion Date July 24, 2025
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