Corrective Action Plans

Finding 561273 (2023-003)

Material Weakness 2023

KY

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.306 § 200.318 § 200.329

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will ende...

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will endeavor to make sure the FEMA files are updated and complete after FEMA reimbursement.

View Audit 356900 Questioned Costs: $1

Finding 561180 (2023-002)

Material Weakness 2023

The Association of State Wetland Managers, Inc. Dba National Association of Wetland Managers

ME

Allowable Costs / Cost Principles

Statement of Condition: Internal control weakness - documentation of approval over allowable costs could not be located for select expenses, and ineffective control procedures over posting of approved indirect cost rate allocation. Criteria: National Association of Wetland Managers’ internal control...

Statement of Condition: Internal control weakness - documentation of approval over allowable costs could not be located for select expenses, and ineffective control procedures over posting of approved indirect cost rate allocation. Criteria: National Association of Wetland Managers’ internal control policies and procedures, indirect cost negotiation agreement, and the Uniform Guidance. Cause: Procedures are in place requiring supervisory approval of documentation before costs are coded to grants, but procedures were not performed on all invoices. Also, ineffective control procedures over posting of indirect payroll cost allocation as indicated by compliance finding. Corrective Action Plan: Contact person: Marla Stelk, Executive Director Corrective action to be taken: NAWM does not believe that corrective action is required for this finding. NAWM has strong procedures in place requiring supervisory approval of documentation before costs are coded to grants. In some circumstances, invoices are emailed to the Executive Director, who approves them by giving instructions regarding payment over email. Email approvals are maintained as record of this internal control. In our digital world with the ability to work remotely, there are times when the Executive Director and Accounting Manager are not physically located in the same office space. However, this does not diminish the strength of our internal controls for review and approval of allowable costs. However, as recommended above, NAWM has hired a professional financial consultant to review our indirect cost accounting procedures, make recommendations to improve our processes, and assist in implementation of these recommendations. Anticipated completion date: End of current fiscal year (December 31, 2025)

View Audit 356793

Finding 561179 (2023-001)

None 2023

The Association of State Wetland Managers, Inc. Dba National Association of Wetland Managers

ME

Allowable Costs / Cost Principles

Statement of Condition: Compliance over allowable cost, including application of the indirect cost rate supplied by the United States Department of the Interior. Approved provisional rate of 26.3% not used. Instead, allocation based upon prior month’s payroll. Criteria: The Uniform Guidance, indirec...

Statement of Condition: Compliance over allowable cost, including application of the indirect cost rate supplied by the United States Department of the Interior. Approved provisional rate of 26.3% not used. Instead, allocation based upon prior month’s payroll. Criteria: The Uniform Guidance, indirect cost negotiation agreement, and National Association of Wetland Managers’ internal control policies and procedures. Cause: Management’s misunderstanding of accounting application of the provisional rate method. Corrective Action Plan: Contact person: Marla Stelk, Executive Director Corrective action to be taken: As noted above, NAWM provides the negotiated Indirect cost rates to the Funding Agency at the time when the project budget is developed. Subsequent billing of the indirect cost is based on the time spent on the project. Within six (6) months after year end, a final indirect cost rate proposal is submitted based on actual costs. Billings and charges to contracts and grants are adjusted if the final rate varies from the provisional rate. If the final rate is greater than the provisional rate and there are no funds available to cover the additional indirect costs, NAWM may not recover all indirect costs. Conversely, if the final rate is less than the provisional rate, NAWM is required to pay back the difference to the funding agency. However, as recommended above, NAWM has hired a professional financial consultant to review our indirect cost accounting procedures, make recommendations to improve our processes, and assist in implementation of these recommendations. Anticipated completion date: End of current fiscal year (December 31, 2025)

View Audit 356793

Finding 561098 (2023-005)

Significant Deficiency 2023

Public Health Institute of Metropolitan Chicago

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting § 200.430

Condition: We identified an instance in which a timesheet was not signed off by applicable supervisor and there was no evidence of review. In addition, another instance was identified in which a timesheet was not complete and was missing hours worked. Corrective Action Taken or Planned: Management ...

Condition: We identified an instance in which a timesheet was not signed off by applicable supervisor and there was no evidence of review. In addition, another instance was identified in which a timesheet was not complete and was missing hours worked. Corrective Action Taken or Planned: Management plans to reiterate the applicable policy and ensure timesheets are prepared, reviewed and contain the appropriate approvals. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Karen Reitan, President and Chief Executive Officer Management Response: Management concurs with the finding.

View Audit 356735

Finding 561088 (2023-003)

Material Weakness 2023

Aid for Aids of Nevada

NV

Allowable Costs / Cost Principles § 200.303

2023-003 Internal Controls System Over Allowable Costs. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to main...

2023-003 Internal Controls System Over Allowable Costs. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. Funds utilized under the Housing Opportunities for Persons with AIDS program are required to be expended on costs consistent with those outlined in 2 CRF 200 Subpart E – Cost Principles, and within the core service categories outlined in the grant agreement. Condition: Of the fourteen request for reimbursement (RFR) forms prepared and submitted to the grantor in order to receive reimbursement for expenditures during the year, seven were not reviewed and signed by the Executive Director. AFAN has designed a control such that a review of each RFR is performed to ensure expenditures are for allowable costs and allowable activities allowed for under the grant. However, this control was not performed consistently. Cause: The internal control system over the assessment of allowable costs was not operating effectively. A review of requests for reimbursement was either not performed or documentation was not maintained to support the appropriateness of expenses allocated to the grant. Context: Management failed to consistently perform an internal control to address the risk of improper expenses being reimbursed by the Organization’s grant. Effect: Not performing a review over the documents and allocations supporting requests for reimbursement for the grant increases the risk that inappropriate costs could be submitted for reimbursement which could be a violation of the terms of the federal grant agreement. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of costs and the related supporting schedules being submitted for reimbursement are reviewed on a consistent basis and management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: Management will implement a control whereby the Executive Director will review and sign all requests for reimbursement prepared by the Finance Manager for submission. The Executive Director will ensure all backup is included and that all direct costs are approved and allowable prior to submission. Payroll related reimbursements will be reviewed to ensure the individuals included and allocation amongst grants are appropriate and the allocations agree to the final payroll records.

View Audit 356711

Finding 561086 (2023-001)

None 2023

Moses H Cone Memorial Hospital Operating Corporation, Inc.

NC

Questioned Costs Allowable Costs / Cost Principles

We have revised the calculation of the Paid Annual Leave award and verified that it uses the pay rates in effect at the time of the award for all employees. We confirmed that no other expenses for the COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“Provider Relief F...

We have revised the calculation of the Paid Annual Leave award and verified that it uses the pay rates in effect at the time of the award for all employees. We confirmed that no other expenses for the COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“Provider Relief Fund”) reporting involved costs subject to similar point in time report parameters. The change to this cost item does not impact the full utilization of the Provider Relief Fund due to the presence of other expenses in the same category along with unreimbursed expenses and unused lost revenues remaining after the funds were exhausted. The discrepancy was due to imprecise instructions in the request for information. In the future, such ad hoc requests and the responsive reports will be verified by the Executive Director of Corporate Accounting before use.

View Audit 356706 Questioned Costs: $1

Finding 561002 (2023-004)

Material Weakness 2023

Cedarville Rancheria

CA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.318

Federal Awards Finding 2023-004: Noncompliance with Federal Award Program Requirements Finding/Condition We noted the following deficiencies: 1. The Rancheria was unable to provide supporting documentation for the allocation of expenditures reported for federal award programs. 2. The Rancheria wa...

Federal Awards Finding 2023-004: Noncompliance with Federal Award Program Requirements Finding/Condition We noted the following deficiencies: 1. The Rancheria was unable to provide supporting documentation for the allocation of expenditures reported for federal award programs. 2. The Rancheria was unable to provide actual time records for employees, supporting payroll expenditures claimed as expenditures for federal award programs. 3. The Rancheria was unable to provide documentation to show that it complied with the procurement standards required in 2 CFR 200.318. Additionally, the Rancheria does not have a procurement policy which complies with those standards. Planned Corrective Action The Rancheria will be updating and implementing policies and procedures to address these risks. Anticipated Completion Date December 31, 2024

View Audit 356634

Finding 560993 (2023-008)

Significant Deficiency 2023

Heading Home

NM

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing policies and procedures found in Section II Policy #201 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the ...

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing policies and procedures found in Section II Policy #201 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure all invoices and funds requests are properly reviewed and approved prior to processing. All invoices and requests for funds for fiscal year 2024 will be reviewed to ensure the payment request is reasonable and necessary. The invoice or funds request will be signed and dated by the preparer, as well as by the reviewer as evidence of approval for processing the payment. All invoices and funds requests will be maintained in the cloud server in a manner that allows them to be easily retrieved when needed. The disbursements in question were reviewed and found to be to vendors regularly used by Heading Home and Heading Home firmly believes that documentation of approval existed at one point in time. However, with the complete turnover in executive personnel during 2023, and the fact that the prior administration utilized an online system for document storage that the current administration has very little access to, we were unable to locate the approvals for these payments. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.

View Audit 356632

Finding 560843 (2023-004)

Significant Deficiency 2023

Beaufort Jasper Hampton Comprehensive Services, Inc.

SC

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

We concur with the auditor's findings. The Organization engaged a single contractor for services but did not maintain the necessary supporting documentation to demonstrate that the suspension and debarment verification procedures, as outlined in our procurement policy were conducted prior to securin...

We concur with the auditor's findings. The Organization engaged a single contractor for services but did not maintain the necessary supporting documentation to demonstrate that the suspension and debarment verification procedures, as outlined in our procurement policy were conducted prior to securing the services. We will update and revise our procurement policies to align with 2 CFR 200 standards. Lastly, we will develop templates for purchase justifications, bid evaluations, suspension/debarment checks, and cost/price analysis. We will ensure the use of this documentation is enforced across all departments.

View Audit 356598

Finding 560759 (2023-008)

Significant Deficiency 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate contract and/or contract extensions for federal funding awarded expended d...

U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate contract and/or contract extensions for federal funding awarded expended during the period. Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation, such as contracts or agreements, is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a contract database and review process for all new and existing contracts. This process includes appropriate naming conventions across all platforms to ensure accuracy in records. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2024.

View Audit 356548

Finding 560743 (2023-007)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Material Weakness Reporting

U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages...

U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a new process for wages charged to a program to ensure accuracy. This will also be monitored regularly and tracked through the accounting software in the grant spend management module. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

View Audit 356548

Finding 560722 (2023-006)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Period of Performance Material Weakness § 200.403

U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During ou...

U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Organization expanded contract compliance to include financial contract compliance. The organization will also implement grant tracking and spend management modules in the accounting software to assist with monitoring expenses applied to contracts. A new process will also be implemented regarding payroll related expenses to ensure the correct period is used for federal expenditures. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

View Audit 356548

Finding 560690 (2023-005)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness

U.S. Department of Agriculture U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) – Assistan...

U.S. Department of Agriculture U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) – Assistance Listing No. 10.569 and 10.565 Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there was a lack of supporting documentation and/or an approval for expenses charged to the federal programs. Recommendation: The Organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a more robust contract compliance process. This process included internal audits which will include review of financial records. The organization has also developed a credit card policy which staff will be trained on before completion date. The organization also implemented a new credit card platform which allows for better tracking, approval and documentation of purchases. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

View Audit 356548

Finding 560679 (2023-004)

Significant Deficiency 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Eligibility School Nutrition Programs

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in plac...

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. CACLV has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2025.

View Audit 356548

Finding 560668 (2023-003)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities duri...

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.

View Audit 356548

Finding 560651 (2023-010)

Material Weakness 2023

Shenandoah School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

FINDING 2023-010 Finding Subject: Education Stabilization Fund – Allowable Cost/Cost Principles Summary of Finding: To receive reimbursement for ESSER expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Director of Curriculum reviewed it. The documentation at...

FINDING 2023-010 Finding Subject: Education Stabilization Fund – Allowable Cost/Cost Principles Summary of Finding: To receive reimbursement for ESSER expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Director of Curriculum reviewed it. The documentation attached to the reimbursement request; however, did not include the following items: 􀁸 For one teacher, the School Corporation did not provide a Board approved contract or Salary Ordinance showing the approval of this teacher's position as a part-time tutor at $50 per hour. There was only an offer letter to the teacher from the Director of Curriculum. 􀁸 For the purchase of equipment in the amount of $318,922, the School Corporation did not provide a contract instead only a PO with a quote and a letter with the School Board’s approval to purchase. Additionally, there was no indication in the board minutes that this purchase had been put out to bid to the suppliers. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the Business Manager and Director of Curriculum review the reimbursement form each month, an additional check for contracts of all employees paid will be added. All procurement documentation, including contracts, will be added to the archived documentation for purchase orders. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560646 (2023-009)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Non-Profit School Food Service Accounts Summary of Finding: Receipts for the grant were posted to the ledger by one individual without an oversight or review process in place to ensure the remitter, amount, fund, and receipt classification ...

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Non-Profit School Food Service Accounts Summary of Finding: Receipts for the grant were posted to the ledger by one individual without an oversight or review process in place to ensure the remitter, amount, fund, and receipt classification were accurate. Additionally, the same individual received the ACH notifications when monies from monthly meal reimbursements were credited to the School Corporation's bank account and performed the bank reconciliations. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Food Service Director and Business Manager hold a monthly financial meeting to review the food service finances. A report listing all receipts for the previous month to the food service fund will be reviewed at this meeting. This item will be added to the agenda. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560628 (2023-004)

Material Weakness 2023

Shenandoah School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403 § 200.430

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the det...

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The School Corporation paid $23,682 of administrative salaries that were allocated to the School Lunch fund based on fixed percentages. There was no supporting documentation to indicate how the percentages were determined or time records indicating time spent on the program by the applicable administrators. INDIANA STATE BOARD OF ACCOUNTS 40 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently 50% of Pam Frost’s salary is paid from the Lunch Fund. A new internal control will be created to document that 50% of her time is spent on food service work and 50% of her time is spent as the ECA treasurer for the elementary school. Anticipated Completion Date: August 31, 2024

View Audit 356534 Questioned Costs: $1

Finding 560556 (2023-001)

Significant Deficiency 2023

Town of Bellingham, Massachusetts

MA

Allowable Costs / Cost Principles Significant Deficiency

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteri...

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Responsible for Corrective Plan: Director of Finance, Schools Estimated Completion Date: December 2024 Action Taken: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

View Audit 356487

Finding 560537 (2023-001)

Material Weakness 2023

Elverado Community Unit School District

CO

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

The District will establish policies and procedures to be followed to ensure proper review, approval and recording of federal expenditures.

View Audit 356444

Finding 560487 (2023-001)

Significant Deficiency 2023

Town of Sturbridge, Massachusetts

MA

Questioned Costs Allowable Costs / Cost Principles

Department of Education Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of ...

Department of Education Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that an employee’s payroll charged to the Education Stabilization Fund – ESSER III major program was for services that was not included as part of the grant application/budget. Criteria: Costs charged to the major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of the payroll charged to the major program it was noted that one of the employees charged to the grant was for stipend pay for work as a ELL Coordinator that was charged to the Salaries budget of the grant, which does not support the services charged. Thus the payroll expense would be unallowable. Effect: Town of Sturbridge was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $862.50 Cause: The stipend for the ELL Coordinator was considered salary by the school department. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Sturbridge follow procedures to ensure that payroll expenditures charged to the grant is allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Business and Finance Estimated Completion Date: October 2024 Action Taken: Moving forward the school department bookkeepers will work to ensure expenditures are properly established, funded and within allowable cost guidelines.

View Audit 356376 Questioned Costs: $1

Finding 560313 (2023-002)

Material Weakness 2023

Springboard Collaborative

PA

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification...

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification process, which requires eligible employees, their managers, and the grant management staff to review and certify effort charged to grant funding during the applicable reporting period. **The effort report certification process was fully enabled and completed in response to Single Audit review during the FY23 audit process and in preparation for FY24 audit. Grant management staff (Associate Director, Fiscal Grant Management) Completed Corrective Action

View Audit 356226 Questioned Costs: $1

Finding 560269 (2023-002)

Material Weakness 2023

Benton Franklin Community Action Committee

WA

Questioned Costs Allowable Costs / Cost Principles

BFCAC made a change in personnel during 2024. Subsequently BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this...

BFCAC made a change in personnel during 2024. Subsequently BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

View Audit 356210 Questioned Costs: $1

Finding 560111 (2023-003)

Significant Deficiency 2023

Town of Enfield

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency

We will implement more internal training with the Accounts Payable department to ensure manifests are signed.

View Audit 356131

Finding 560078 (2023-002)

Significant Deficiency 2023

Town of Marlborough

CT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: The...

Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town has a system in place to review contractors. A written process will be prepared to record and maintain appropriate documentation. Name of the contact person responsible for corrective action: Town Manager and Finance Director Planned completion date for corrective action plan: Since this report is overdue, the estimated date is before the start of the FY 24 audit.

View Audit 356034

Corrective Action Plans

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