Open Recommendations

We recommend that the Chief Operating Officer for FSA, in conjunction with the Commissioner for NCES, require SNHU to update its policies and procedures for collecting, verifying, and reporting accurate data for the Graduation Rates survey to align with current IPEDS reporting requirements and ensure accurate classification of first-time, full-time undergraduate students seeking their first postsecondary education degree or certificate.

We also recommend the Chief Operating Officer for FSA consider taking appropriate action pursuant to subpart G of 34 C.F.R. 668 because the school reported inaccurate and incorrect information to IPEDS through the Graduation Rates survey for the 2021–2022 reporting period.

We recommend that the Chief Operating Officer for FSA, in conjunction with the Commissioner for NCES, require SNHU to update its existing policies and procedures to ensure that the cost of attendance data reported for the IPEDS Institutional Characteristics survey are accurate and supported by source documentation.

Ensure that financial reporting control activities require documentation to evidence management’s analysis of accounting updates, planned changes and rationale for such changes, and management’s review and approval of any planned accounting updates.

Perform ongoing monitoring of anticipated accounting changes and communicate potential updates to relevant stakeholders.

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We recommend that EXIM design, document, and implement controls to ensure [language withheld based on applicable Freedom of Information Act exemptions] that logical access is restricted to only authorized users.

Update its annual retrospective review through a grant recipient survey, review of invoice documentation, and/or other means for a lookback period greater than 4 months to analyze the results of the prior year accrual and determine if the 4-month lookback period remains sufficient to validate the grant accrual methodology in subsequent periods.

Analyze the reasons for the changes in the calculated average billing cycle and grant recipient billing patterns in recent periods and document the impact on its grant accrual methodology as part of its annual retrospective review prior to year-end.

Design and implement procedures to document the analysis performed to support any future changes to the grant accrual methodology prior to implementing such changes.

Implement a procedure, as part of its process for recording SF-132 activity, to reconcile the SF-132 line number to the applicable United States Standard General Ledger account to verify that the transaction is recorded accurately and in accordance with OMB Circular No. A-11.

Implement processes to perform administrative functions without the use of shared accounts.

Design and implement controls over privileged developer access to certain systems, including periodic recertification of accounts and enforcing segregation of duties.

Design, implement, and re-enforce requirements for controls to consistently approve and document recertification requests as required by internal policy and standards for effective internal control systems.

We recommend the Department implement comprehensive training for new control operators, focusing on accurate completion and review of financial statement templates and related disclosures. Training should emphasize understanding control objectives, consistent application of policies and procedures, and thorough review practices to detect and correct errors.

We recommend that the Department continue to design policies to perform and document a risk assessment of new or revised accounting standards.

We recommend the Department implement a periodic retrospective review to verify the data, methods, and assumptions are accurate, complete, and consistent with established estimation methodologies.

We recommend the Department periodically assess the effectiveness of training and update materials as needed to reflect changes in personnel, processes, or reporting requirements.

We recommend the Department assign experienced personnel as the reviewer or a second review by a different employee when new employees are performing the control.

We recommend the Department provide ongoing guidance and training to process owners to ensure compliance with the standards.

We recommend the Department enhance risk assessment procedures to identify and implement changes needed to internal processes and controls to ensure ongoing compliance with SFFAS 54.

We recommend the Department establish and document a formal control requiring periodic review and validation of the application of the data used to generate the accounting estimate.

The New York/New Jersey VA Healthcare Network Director evaluates the circumstances that led to Network and Syracuse VA Medical Center leaders not following clinical restructuring requirements according to VHA Directive 1043.

The Syracuse VA Medical Center Director evaluates the implementation of high reliability organization principles when communicating changes to clinical operations that include stakeholders, service and section leaders, and staff input.

The Syracuse VA Medical Center Director evaluates facility contract processes and takes action to ensure leaders maintain adequate oversight of contracting milestones.

The Syracuse VA Medical Center Director evaluates the communication of established contingency plans and ensures alignment with high reliability organization principles.

The Syracuse VA Medical Center Director ensures the monitoring and evaluation of patient transfers according to Veterans Health Administration Directive 1094(1) and takes action as warranted.

The Syracuse VA Medical Center Director ensures annual procedural complexity designation infrastructure reviews are completed accurately and ensures administrative actions are performed as required.

The New York/New Jersey VA Healthcare Network Director evaluates fiscal year 2026 procedural complexity designation infrastructure reviews for all Veterans Integrated Service New York/New Jersey VA Health Care Network facilities and takes action to ensure reviews are accurate and deficiencies are addressed as required.

The Under Secretary for Health ensures a timeliness expectation for infrastructure waiver submissions pursuant to Veterans Health Administration Directive 1220(1).

The New York/New Jersey VA Healthcare Network Director evaluates the circumstances that led to Network and Syracuse VA Medical Center leaders not following clinical restructuring requirements according to VHA Directive 1043.

The Syracuse VA Medical Center Director evaluates the implementation of high reliability organization principles when communicating changes to clinical operations that include stakeholders, service and section leaders, and staff input.

The Syracuse VA Medical Center Director evaluates facility contract processes and takes action to ensure leaders maintain adequate oversight of contracting milestones.

The Syracuse VA Medical Center Director evaluates the communication of established contingency plans and ensures alignment with high reliability organization principles.

The Syracuse VA Medical Center Director ensures the monitoring and evaluation of patient transfers according to Veterans Health Administration Directive 1094(1) and takes action as warranted.