Corrective Action Plans

Finding 507908 (2023-002)

Significant Deficiency 2023

Centennial Board of Cooperative Educational Services

CO

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they w...

7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they were Centennial BOCES employees regarding collection of time and effort reports following appropriate policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and effort documentation, will be completed.

View Audit 328448

Finding 507907 (2023-001)

Significant Deficiency 2023

Centennial Board of Cooperative Educational Services

CO

Procurement, Suspension & Debarment HUD Housing Programs

7. Management Response: Centennial BOCES will review the expected activities to ensure that they are appropriately listed on the budget submitted to CDE for approval and properly coded throughout the year.

View Audit 328448

Finding 507902 (2023-003)

Significant Deficiency 2023

Community Health Center Dba Alluvion Health, Inc.

MT

Procurement, Suspension & Debarment

Lack of Procurement Support As a result of staffing limitations and employee turnover, there was insufficient understanding and implementation of the organization's procurement policy. The Organization welcomed new financial leadership in June 2023 and November 2023. Looking ahead, the financial ...

Lack of Procurement Support As a result of staffing limitations and employee turnover, there was insufficient understanding and implementation of the organization's procurement policy. The Organization welcomed new financial leadership in June 2023 and November 2023. Looking ahead, the financial leadership team is updating the procurement policy to enhance clarity and comprehension. Additonally, the procurement checklist is being modified to ensure that sufficient supporting documentation is obtained and maintained for certain procurement transactions. Responsible Party: Brenda Ries, CFO Estimated Completion Date: October 31, 2024

View Audit 328436

Finding 507898 (2023-002)

Material Weakness 2023

Community Health Center Dba Alluvion Health, Inc.

MT

Material Weakness Special Tests & Provisions

Misapplication of the Sliding Fee Scale The department responsible for gathering and recording patient income data, and applying sliding fee discounts, experienced high attrition rates due to the role being entry-level. Recognizing these challenges, the Organization is in the process of revising th...

Misapplication of the Sliding Fee Scale The department responsible for gathering and recording patient income data, and applying sliding fee discounts, experienced high attrition rates due to the role being entry-level. Recognizing these challenges, the Organization is in the process of revising the training plan for this department and establishing a quality assurance process for monitoring. Additionally, the Organization will review and revise the sliding fee policy to enhance clarity of the process for application of discounts and proof of income documentation. Responsible Parties: Mark Groeller, Compliance Director, Lisa DeMallie, Associate Vice President of Patient Experience, and Melissa Darko, Revenue Cycle Director Estimated Completion Date: December 31, 2024

View Audit 328436

Finding 507844 (2023-002)

Material Weakness 2023

Washington Gorge Action Programs

WA

Questioned Costs Allowable Costs / Cost Principles

Identify, solve, and prevent future payroll liability and payroll expenses over allocation charged to grantors. Identify and solve errors. Follow financial policy to verify the solution and prevent future noncompliance. Responsible person: Finance Dept. Identify over-allocation amounts for each...

Identify, solve, and prevent future payroll liability and payroll expenses over allocation charged to grantors. Identify and solve errors. Follow financial policy to verify the solution and prevent future noncompliance. Responsible person: Finance Dept. Identify over-allocation amounts for each grant in 2023. Responsible person: Finance Dept. Inform all funders affected. Responsible person: Executive Director. Determine whether policy/procedure need to be updated or established. Responsible Persons: Executive Director and Finance Dept. Monthly check-ins to assess progress on action steps. Reveiw the effectiveness of implemented changes at the end of the fiscal year.

View Audit 328359 Questioned Costs: $1

Finding 507822 (2023-002)

Material Weakness 2023

County of Northampton, Pennsylvania

PA

Reporting

Finding 2023-002 – Reporting (Material Weakness) Repeat Finding – See Finding 2022-001 US Department of the Treasury – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The County’s submitted reports for ARPA do not materially agree to the expenditures reporte...

Finding 2023-002 – Reporting (Material Weakness) Repeat Finding – See Finding 2022-001 US Department of the Treasury – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The County’s submitted reports for ARPA do not materially agree to the expenditures reported in the trial balance. Criteria: In accordance with the federal compliance requirements for ARPA, current reporting period expenditures and cumulative expenditures must be entered for each project. Cause: There was not a review and a reconciliation of the amounts being submitted on the reports to the amounts recorded in the trial balance. Effect: The County is not in compliance with reporting requirements, and failure to comply with grant award requirements could jeopardize future funding and does not allow the funder to adequately oversee the use of their funding. Recommendation: We recommend that the County continue its efforts in evaluating its procedures to ensure that all required reports are accurately submitted. Management Response: External auditors and management discussed ongoing issues with the policies written about reporting and the limits of the reporting system provided by the federal government. To further complicate matters as the federal COVID money is spent and reporting is now coming to an end the federal government is providing less support for the existing reporting system. However, we will continue to work assure timely and accurate reporting of all ARPA funds as required.

View Audit 328327

Finding 507820 (2023-002)

None 2023

Town of Hartland, Maine

ME

Reporting

The Town has put in place a process for more accurate year end closing and financial statement preparation.

View Audit 328326

Finding 507808 (2023-004)

None 2023

Colfax County

NM

Colfax County and Financail Specialist were not trained in Railroad project management. Changes in staff within the County manager's Office and private corporations, and delay in reporting ultimately resulting in disruption of reimubrsement to the COunty. Colfax County worked with NM Department of...

Colfax County and Financail Specialist were not trained in Railroad project management. Changes in staff within the County manager's Office and private corporations, and delay in reporting ultimately resulting in disruption of reimubrsement to the COunty. Colfax County worked with NM Department of Transportation and Fedreal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County

View Audit 328311

Finding 507807 (2023-003)

None 2023

Colfax County

NM

Cash Management

Colfax County worked with NM Department of Transportation and Federal Railraod Administration to collect project status information and submit all outstanding progress reports. To date Colfax has been successful in maintaining open communication and receiving support from NMDOT and FRA. All report...

Colfax County worked with NM Department of Transportation and Federal Railraod Administration to collect project status information and submit all outstanding progress reports. To date Colfax has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County.

View Audit 328311

Finding 507805 (2023-003)

Significant Deficiency 2023

Tazewell County, Illinois

IL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with ...

Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with federal reporting requirements and guidelines. When outside consultants are engaged to aid in grant administration, the appropriate Tazewell County manager will be responsible for reviewing and approving all required reporting and supporting documentation prepared on the County’s behalf.

View Audit 328308

Finding 507799 (2023-003)

Significant Deficiency 2023

Wilsona School District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.439

The District will ensure that all proposed capital expenditures originating from any Federal sources that are in excess of $5,000 are pre-approved by CDE prior to executing the proposed transaction.

View Audit 328293 Questioned Costs: $1

Finding 507793 (2023-002)

Significant Deficiency 2023

Wilsona School District

CA

Subrecipient Monitoring Reporting Significant Deficiency

Moving forward, the District will ensure that all items reported to various agencies, including the California Department of Education, are supported and are retained to external review.

View Audit 328293

Finding 507424 (2023-015)

Significant Deficiency 2023

The Howard University

DC

Subrecipient Monitoring § 200.403

Name of Responsible Individual: Bruce Jones, Vice President of Research, Marchon Jackson, Associate Vice President of Research, Dana Hector, Assistant Vice President, Sponsored Grants & Programs Corrective Action: The process to review subrecipient invoices will be improved by requiring the review ...

Name of Responsible Individual: Bruce Jones, Vice President of Research, Marchon Jackson, Associate Vice President of Research, Dana Hector, Assistant Vice President, Sponsored Grants & Programs Corrective Action: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025. Anticipated Completion Date: March 31, 2025

View Audit 328267

Finding 507058 (2023-014)

Significant Deficiency 2023

The Howard University

DC

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR ...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025 Anticipated Completion Date: December 31, 2024

View Audit 328267 Questioned Costs: $1

Finding 507052 (2023-013)

Significant Deficiency 2023

The Howard University

DC

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporti...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024. Anticipated Completion Date: December 31, 2024

View Audit 328267

Finding 506686 (2023-012)

Significant Deficiency 2023

The Howard University

DC

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding. A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary. Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions. Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process. Anticipated Completion Date: June 30, 2025

View Audit 328267

Finding 506325 (2023-011)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from f...

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings. 5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent. Anticipated Completion Date: June 30, 2025

View Audit 328267

Finding 505964 (2023-010)

Significant Deficiency 2023

The Howard University

DC

Equipment & Real Property Management Procurement, Suspension & Debarment

Name of Responsible Individual: Rawle Howard, Assistant Vice President and Chief Procurement Officer Corrective Action: Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when in...

Name of Responsible Individual: Rawle Howard, Assistant Vice President and Chief Procurement Officer Corrective Action: Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data. In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number. Anticipated Completion Date: June 30, 2025

View Audit 328267

Finding 505603 (2023-009)

Significant Deficiency 2023

The Howard University

DC

Procurement, Suspension & Debarment

Name of Responsible Individual: Rawle Howard, Assistant Vice President and Chief Procurement Officer Corrective Action: The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take man...

Name of Responsible Individual: Rawle Howard, Assistant Vice President and Chief Procurement Officer Corrective Action: The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures. OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance. OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form. Anticipated Completion Date: May 31, 2025

View Audit 328267

Finding 505602 (2023-008)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Name of Responsible Individual: Nate R. McGill, Associate Director, Center for Career & Professional Success, Ben Carmichael, Associate Director for Compliance, John Hooth, Senior Director of Payroll Corrective Action: Federal Work Study supervisors are required to have training on the appropriate...

Name of Responsible Individual: Nate R. McGill, Associate Director, Center for Career & Professional Success, Ben Carmichael, Associate Director for Compliance, John Hooth, Senior Director of Payroll Corrective Action: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this. The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester. The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services is anticipating hiring a full-time Federal Work Study Coordinator by the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any Federal Work Study students and the first review of timesheets to ensure accuracy/timeliness in payment, as well as no supervisor approves time prior to the student working.

View Audit 328267

Finding 505595 (2023-007)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Reporting Special Tests & Provisions

Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Ai...

Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024. Anticipated Completion Date: The policy and procedure for V4 verification intake was updated in February 2024 and the training of Financial Aid Counselors occurred in February and March 2024. There will be annual training of Financial Aid Counselors on following appropriate verification procedures as needed. The Associate Director for Compliance performed a review of V4 verification documents processed by Financial Aid Counselors in March 2024 and June 2024. All V4 verification documents received after the training followed the updated policy and procedure. Another review of V4 verification will be completed in September 2024 and any additional training required will be scheduled.

View Audit 328267

Finding 505588 (2023-006)

Significant Deficiency 2023

The Howard University

DC

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

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Robin Whitfield, Associate VP for Finance & Bursar Corrective Action: It was discovered in December 2021 t...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Robin Whitfield, Associate VP for Finance & Bursar Corrective Action: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Anticipated Completion Date: December 2024 is the anticipated date by which Howard would expect the comparison process to be completed. Howard has been in contact with ECSI and the comparison process is still ongoing.

View Audit 328267

Finding 505587 (2023-005)

Significant Deficiency 2023

The Howard University

DC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 da...

Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard. The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe. Anticipated Completion Date: This finding was mitigated in May 2023. The responsibility of Title IV reconciliation was performed and worked by two consultants who had experience with Title IV reconciliation. The Assistant Director for Compliance hired in January 2024 has experience with Title IV reconciliation and was trained by the two consultants on Howard procedures for Title IV reconciliation and working rejected disbursements. The responsibility for Title IV reconciliation now lies entirely within the Office of Financial Aid.

View Audit 328267

Finding 505585 (2023-004)

Significant Deficiency 2023

The Howard University

DC

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The Universit...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations. Anticipated Completion Date: October 31, 2024. The Senior Executive Director of Financial Grants and Contracts is currently working with the Associate Director for Compliance and the Executive Director of Financial Aid to improve communication between all departments responsible for cash management.

View Audit 328267

Finding 505583 (2023-003)

Significant Deficiency 2023

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Konya White, Director of Enrollment Systems and LaTrice Byam, Executive Director of Academic Planning and Curriculum Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and ...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Konya White, Director of Enrollment Systems and LaTrice Byam, Executive Director of Academic Planning and Curriculum Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators). The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.” After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday. The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared. Anticipated Completion Date: The correction to the “3Q” status took place in January 2024 and testing has shown this issue to be resolved. Additional testing will occur in the new ERP Workday to ensure incorrect reporting of students who are ¾ time does not occur. Enrollment reporting samples will be pulled approximately 2-3 weeks after the first Fall 2024 enrollment file is sent to National Student Clearinghouse.

View Audit 328267

Corrective Action Plans

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