Corrective Action Plans

Finding 1206363 (2023-005)

Material Weakness 2023

ME

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

CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by...

CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and us using the new Procurement Policy that addresses this deficiency. Additionally, Department Heads are required to turn in no later than Thursday by 9 am, invoices to be paid on that week’s warrant. The Treasurer has been given authority by the Town Manager to contact Department Heads and request that they come to the office weekly to turn in invoices. All invoices must have the appropriate expense code and be signed by the Department Head. Anticipated Completion Date: This was completed January 23, 2024.

View Audit 398382

Finding 1206359 (2023-003)

Material Weakness 2023

Town of Livermore Falls

ME

Allowable Costs / Cost Principles § 200.303

CORRECTIVE ACTION PLAN (Concerning Finding 2023-003) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-003 The current Town Manager was appointed by...

CORRECTIVE ACTION PLAN (Concerning Finding 2023-003) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-003 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager that has implemented training for the Treasurer and the Select Board. She has implemented a process of having the Treasurer complete a warrant each week. The Select Board meets bi-monthly and the Town Manager has the Select Board review and approve all warrants as a regular action item in their meeting. Additionally, Department Heads are required to turn in no later than Thursday by 9 am, invoices to be paid on that week’s warrant. The Treasurer has been given authority by the Town Manager to contact Department Heads and request that they come to the office weekly to turn in invoices. All invoices must have the appropriate expense code and be signed by the Department Head. Anticipated Completion Date: This corrective action has been implemented as of October 2023.

View Audit 398382

Finding 1206115 (2023-001)

Material Weakness 2023

CITY OF FARRELL

PA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Reporting § 200.403

CONDITION: During the calendar year 2023, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile certain balance sheet accounts, such as interfund receivables and payables, and payroll-related liabilities to the underlying supporting...

CONDITION: During the calendar year 2023, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile certain balance sheet accounts, such as interfund receivables and payables, and payroll-related liabilities to the underlying supporting documentation available at the City. This included the City’s Community Development Block Grant (CDBG) Program. As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the City’s Federal Programs general ledger which accounts for the financial activity of the City’s Community Development Block Grant Program.MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City is reviewing the options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all applicable balance sheet account balances are accurate and supported by the underlying documentation available at the City. The City is currently in continuous communication with the Audit Firm for specific recommendations regarding the handling of interfund receivables and payables, and payroll-related liabilities, so as to ensure the accuracy of the City’s financial reporting. The timeframe for completion of this review will occur during the first six months of calendar year 2026 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

View Audit 398080

Finding 1206065 (2023-005)

Material Weakness 2023

Voices of Tomorrow

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Contact Person: Chief Financial Officer Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. ...

Contact Person: Chief Financial Officer Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. FFATA reporting was not completed for applicable subawards as required under 2 CFR Part 170. Status: Corrective Action Taken Corrective action planned: The revised policy includes tracking of allocation shared cost and perform FFATA review. • Develop and implement a formal FFATA reporting policy. • Confirm FSRS system access and assign reporting responsibility. • Establish a compliance calendar for timely submission. • Complete any outstanding required FFATA filings. • Conduct quarterly review of subawards for FFATA applicability. Anticipated completion date: February 2026

View Audit 397946

Finding 1206064 (2023-004)

Material Weakness 2023

Voices of Tomorrow

WA

Allowable Costs / Cost Principles § 200.438

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management partially disagrees with the characterization of the finding. The ...

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management partially disagrees with the characterization of the finding. The Organization had an established cost allocation methodology in place and provided documentation outlining the allocation basis and percentages applied to shared nonpayroll costs. The allocation methodology was reasonable, consistently applied, and based on operational usage. The matter identified during audit testing relates to a difference in interpretation regarding the allocation percentage applied to certain costs. The federal project expected 100% allocation of specific costs directly to the program, whereas the Organization allocated costs proportionally based on a documented cost allocation methodology. The variance was not due to a lack of methodology, but rather a disagreement regarding the appropriate allocation basis under the specific award expectations. While management maintains that the allocation approach was reasonable and consistently applied, we acknowledge the auditor’s interpretation and will revise our documentation and review procedures to ensure alignment with the awarding agency’s expectations going forward. The Organization will accept the adjustment and strengthen formal documentation to eliminate ambiguity in future allocations.Status: Corrective Action Taken Corrective action planned: Management has organized their general ledger to allow for better matching and coding to better identify unallowable costs during the billing process. Additionally, necessary staff were trained on the tracking and approving expenditure on federal cost principles. Reviews will be made on quarterly baises, and all necessary documentation is collected and reviewed. • Develop and formally adopt a written Cost Allocation Plan identifying allocation methodologies. • Implement pre-charge review controls for all federal expenditures. • Establish general ledger coding for unallowable costs. • Provide cost principles training to approving staff. • Conduct periodic allocation consistency reviews. Anticipated completion date: April 2026

View Audit 397946

Finding 1206063 (2023-003)

Material Weakness 2023

Voices of Tomorrow

WA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency § 200.318 § 200.326

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Procurement documentation did not consis...

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Procurement documentation did not consistently evidence compliance with internal policy and 2 CFR §§200.318–200.326. Status: Corrective Action Taken Corrective action planned: Voices of Tomorrow will implement procurement software to automate workflows and approval processes for procurement purchases. Voices of Tomorrow will • Revise and formalize procurement policy to align fully with Uniform Guidance requirements.Implement a standardized procurement documentation checklist requiring evidence of procurement method, cost/price analysis, and approvals. • Require CFO pre-approval for federally funded procurements above established thresholds. • Conduct staff training on federal procurement standards. • Implement quarterly internal procurement compliance reviews. Anticipated completion date: April 2026: Policy revision and training completed within 60 days; quarterly reviews beginning next fiscal quarter.

View Audit 397946

Finding 1206061 (2023-001)

Material Weakness 2023

Voices of Tomorrow

WA

Allowable Costs / Cost Principles § 200.430

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Personnel costs were allocated based on ...

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Personnel costs were allocated based on budget estimates rather than after-the-fact documentation as required under 2 CFR §200.430(i). Status: Corrective Action Taken Corrective action planned: Voices of Tomorrow will strengthen its payroll and time-and-effort documentation practices to comply with 2 CFR 200.430(i). The Organization will implement an after-thefact time and effort reporting process that accurately reflects actual work performed by employees whose compensation is charged to federal programs. Specific actions include: • Implementing standardized time-and-effort certification forms for all staff charged to federal awards • Requiring periodic after-the-fact reviews and supervisory approvals • Updating internal policies to clearly define documentation requirements • Training staff and supervisors on Uniform Guidance time-and-effort standards Anticipated completion date: June, 30 2026

View Audit 397946

Finding 1205675 (2023-005)

Material Weakness 2023

Colorado West, INC and Affiliates

CO

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303 § 200.403

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2023 AUDITOR FINDING: 2023-005 According to 2 CFR Part 200.403 factors affecting allowability of costs - costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the perfo...

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2023 AUDITOR FINDING: 2023-005 According to 2 CFR Part 200.403 factors affecting allowability of costs - costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Organization did not maintain documentation to support that costs and reimbursement invoices had been approved in accordance with their internal control design. CLIENT PLANNED ACTION: To address the audit finding, we affirm that all reimbursement invoices and cost-related documentation are submitted to a Director-level staff member for review and approval prior to sending. All approved invoices and associated documentation are now stored in a centralized shared drive and onsite file cabinets accessible to relevant finance staff to ensure consistent retention and accessibility for audit and review purposes. These documents will also be accessible within the accounting information system, when organization switches to Sage, which is accessible to all parties that have approval responsibilities. CLIENT RESPONSIBLE PARTY: Cassie Kenney, Director of Accounting COMPLETION DATE: This process started as of June 30, 2024. Documents will be stored within Sage as soon as the switch to this software is effective (tentative July 1st, 2025).

View Audit 397388

Finding 1187063 (2023-001)

Material Weakness 2023

Clayton County Community Services Authority, Inc.

GA

Allowable Costs / Cost Principles Reporting

Management Response to Audit Finding No. 2023-01 - MAJOR FEDERAL AWARD PROGRAM AUDIT - REPORTING UNDER GOVERNMENT AUDITING STANDARDS - Annual Audit - Responsible Person: Chief Financial Officer - Anticipated Completion Date: June 30, 2026 / On-going - Corrective Action: The management of Clayton Cou...

Management Response to Audit Finding No. 2023-01 - MAJOR FEDERAL AWARD PROGRAM AUDIT - REPORTING UNDER GOVERNMENT AUDITING STANDARDS - Annual Audit - Responsible Person: Chief Financial Officer - Anticipated Completion Date: June 30, 2026 / On-going - Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the recommendation that all financial reporting and submission requirements and deadlines required by federal and state regulation be adhered to for future periods. The organization is working diligently with the audit firm to complete the fiscal year 2024 and 2025 audit periods. With the completion of the fiscal year 2023 audit, the organization and audit firm immediately began the preparation for fiscal year 2024. The subsequent year's audits have been prioritized and will be completed and submitted as soon as possible in order to bring the organization current and in compliance with this finding. The anticipated timeline for completion is scheduled for completion by the end of the June 30, 2026 fiscal period. This will bring the agency into full compliance for this finding.

View Audit 394779

Finding 1182223 (2023-006)

Material Weakness 2023

Independent Resources, Inc.

DE

Allowable Costs / Cost Principles Period of Performance Matching / Level of Effort / Earmarking

Name of Contact Person Lillian Harrison, Executive Director Management’s Response/Corrective Action The Organization will develop and implement formal written policies and procedures to strengthen internal controls over monitoring the period of performance for all federal awards. In addition, manage...

Name of Contact Person Lillian Harrison, Executive Director Management’s Response/Corrective Action The Organization will develop and implement formal written policies and procedures to strengthen internal controls over monitoring the period of performance for all federal awards. In addition, management will provide training to relevant staff on federal grant compliance requirements related to allowable costs and period of performance to ensure expenditures are incurred within the authorized timeframe.

View Audit 393606

Finding 1182016 (2023-004)

Material Weakness 2023

Voices of Tomorrow

WA

Allowable Costs / Cost Principles Significant Deficiency

Management partially disagrees with the characterization of the finding. The Organization had an established cost allocation methodology in place and provided documentation outlining the allocation basis and percentages applied to shared nonpayroll costs. The allocation methodology was reasonable, c...

Management partially disagrees with the characterization of the finding. The Organization had an established cost allocation methodology in place and provided documentation outlining the allocation basis and percentages applied to shared nonpayroll costs. The allocation methodology was reasonable, consistently applied, and based on operational usage. The matter identified during audit testing relates to a difference in interpretation regarding the allocation percentage applied to certain costs. The federal project expected 100% allocation of specific costs directly to the program, whereas the Organization allocated costs proportionally based on a documented cost allocation methodology. The variance was not due to a lack of methodology, but rather a disagreement regarding the appropriate allocation basis under the specific award expectations.

View Audit 393387

Finding 1182013 (2023-001)

Material Weakness 2023

Voices of Tomorrow

WA

Allowable Costs / Cost Principles Material Weakness

Voices of Tomorrow will strengthen its payroll and time-and-effort documentation practices to comply with 2 CFR 200.430(i). The Organization will implement an after-thefact time and effort reporting process that accurately reflects actual work performed by employees whose compensation is charged to ...

Voices of Tomorrow will strengthen its payroll and time-and-effort documentation practices to comply with 2 CFR 200.430(i). The Organization will implement an after-thefact time and effort reporting process that accurately reflects actual work performed by employees whose compensation is charged to federal programs.

View Audit 393387

Finding 1181864 (2023-003)

Material Weakness 2023

Restoration Society, INC

NY

Allowable Costs / Cost Principles

The Organization is in the process of strengthening its documentation retention procedures to ensure all federally funded disbursements aresupported by complete source documentation, including invoices, rental reasonablenessforms, management approvals, non-financial support records, and executed con...

The Organization is in the process of strengthening its documentation retention procedures to ensure all federally funded disbursements aresupported by complete source documentation, including invoices, rental reasonablenessforms, management approvals, non-financial support records, and executed contracts. Staffhave been instructed on updated filing and retention requirements, and the accounting department will perform periodic reviews to confirm that required documentation is maintained in the accounting records prior to payment.

View Audit 393148

Finding 1181862 (2023-001)

Material Weakness 2023

Restoration Society, INC

NY

Allowable Costs / Cost Principles

The Organization has implemented a standardized time-and-attendance process requiring all staff whose salaries are charged to federal programs to document actual time worked by program. Supervisors will review and approve these records monthly, and the accounting department will verify that payroll ...

The Organization has implemented a standardized time-and-attendance process requiring all staff whose salaries are charged to federal programs to document actual time worked by program. Supervisors will review and approve these records monthly, and the accounting department will verify that payroll allocations agree to approved documentation before charging costs to federal awards.

View Audit 393148

Finding 1181673 (2023-007)

Material Weakness 2023

Maryland Network Against Domestic Violence, INC

MD

Allowable Costs / Cost Principles

Summary of Findings The Organization does not have a cost allocation plan in place. Due to this, there is a lack of documentation around allocation methodology and lookback on budget to actual analysis. We consider this to be a material weakness in internal controls over compliance with Allowable Co...

Summary of Findings The Organization does not have a cost allocation plan in place. Due to this, there is a lack of documentation around allocation methodology and lookback on budget to actual analysis. We consider this to be a material weakness in internal controls over compliance with Allowable Costs/Cost Principles and is not considered a repeated finding. Although the Organization appears to be allocating costs, they still need to have written cost allocation plan created to make sure the plan is being followed and costs are charged appropriately to programs. Statement of Concurrence or Nonconcurrence MNADV concurs with the finding and recommendation labeled 2023-007. The organization does have a cost allocation process, but it is not a formal written policy. Corrective Action 1. Review the current system in place for cost allocation. 2. Develop and implement a written cost allocation plan to ensure costs are charged appropriately to programs. Responsible Parties: Executive Director and Contractual Bookkeeper Completion Date: Within 60 days of the date of this memo.

View Audit 392932

Finding 1181671 (2023-005)

Material Weakness 2023

Maryland Network Against Domestic Violence, INC

MD

Allowable Costs / Cost Principles § 200.309 § 200.333 § 200.400

Summary of Findings During testing of program expenditures, one of thirty-seven expenditures (2.7%) tested was determined to be an unallowable cost under the grant. The amount identified totaled $13,247. This instance was identified as noncompliance with Allowable Costs/Cost Principles requirements....

Summary of Findings During testing of program expenditures, one of thirty-seven expenditures (2.7%) tested was determined to be an unallowable cost under the grant. The amount identified totaled $13,247. This instance was identified as noncompliance with Allowable Costs/Cost Principles requirements. The finding is not considered a repeated finding. Statistical sampling was not used in making sample selections. Statement of Concurrence or Nonconcurrence MNADV concurs with the finding and recommendation labeled 2023-005. The administrative agent that administers the organization’s health insurance changed their name. As a result, the health insurance bill ($13,247.02) was coded to the wrong GL code. Instead of being posted to the health insurance expense code, this was erroneously posted to the GL code for other consultants. Corrective Action A. Immediate Corrective Action Taken 1. Management reviewed the specific expenditure and confirmed that it was erroneously assigned the wrong GL code. 2. The unallowable cost of $13,247 was removed from the federal award, and properly reclassified. 3. Supporting documentation of correction was retained. Completion Date: Completed prior to issuance of audited financial statements. B. Long-Term Corrective Actions The organization will develop a Vendor Change Monitoring Procedure that will require documentation and review when a vendor changes name, ownership, or payment structure. This will Include verification that the vendor is mapped to the correct GL account before payment is processed. Responsible Parties: Executive Director and Contractual Bookkeeper Completion Date: Within 60 days of the date of this memo.

View Audit 392932

Finding 1181664 (2023-008)

Material Weakness 2023

Maryland Network Against Domestic Violence, INC

MD

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.309

Summary of Findings Testing identified one expenditure out of seven sampled (14.3%) totaling $3,300 that was not recorded in the proper fiscal year. This was determined to be an instance of noncompliance in internal control over compliance related to Period of Performance requirements. The finding i...

Summary of Findings Testing identified one expenditure out of seven sampled (14.3%) totaling $3,300 that was not recorded in the proper fiscal year. This was determined to be an instance of noncompliance in internal control over compliance related to Period of Performance requirements. The finding is not considered a repeated finding. Statement of Concurrence or Nonconcurrence MNADV concurs with the finding and recommendation labeled 2023-008. The organization failed to accurately review an expenditure that was billed in the audited fiscal year but was actually a prepay for services in the following fiscal year. The expenditure did appropriately fall within the correct grant award period as the grant spanned both fiscal years. This oversight was due to human error. Corrective Action A. Immediate Corrective Action Taken 1.Management reviewed the transaction in question and verified the correct period of performance. 2.The expenditure was reclassified to the appropriate fiscal year. 3.A review of expenditures recorded near the fiscal year-end for all federal awards was conducted to identify any additional cutoff errors. 4.Supporting documentation for corrections was retained. Completion Date: Completed prior to issuance of audited financial statements. B. Long-Term Corrective Actions The organization will implement enhanced year-end closing procedures that will include review of all invoices for the period of service to ensure that expenditures recorded near the start or end of a fiscal year are aligned with the proper fiscal year. Prepaid service expenditures will be recorded as accruals. Responsible Party: Executive Director and Contractual Bookkeeper Implementation Date: Beginning current fiscal year-end and ongoing.

View Audit 392932

Finding 1181383 (2023-007)

Material Weakness 2023

California Institute of Environmental Studies

CA

Allowable Costs / Cost Principles § 200.403

2023-007 Cash Disbursements and Payroll Allocations and Disbursements Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Criteria: 2 CFR 200.403(a) – Except where otherwis...

2023-007 Cash Disbursements and Payroll Allocations and Disbursements Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Criteria: 2 CFR 200.403(a) – Except where otherwise authorized by statute, costs must meet the following general criteria to be allowed under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: CIES will implement a review and approval process for cash disbursements and payroll allocations and disbursements. Payroll allocations and disbursements will be reviewed and approved by either the Chief Operations Officer or Executive Director. Documentation of review and approval process will be maintained within CIES electronic files. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: March 2026

View Audit 392629

Finding 1181381 (2023-005)

Material Weakness 2023

California Institute of Environmental Studies

CA

Allowable Costs / Cost Principles § 200.302 § 200.403 § 200.414

2023-005 Indirect Cost Rate Agreement (NICRA) Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Specifically, auditors recommend that CIES modify internal controls to inc...

2023-005 Indirect Cost Rate Agreement (NICRA) Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Specifically, auditors recommend that CIES modify internal controls to include a review and approval process for submission of all invoices submitted to grantors, including showing the indirect cost rate calculations. Criteria: 2 CFR 200.414(c) – Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Project invoices will be prepared by a member of the CIES administrative staff with enough details to show direct and indirect cost rate calculations. Invoices will be reviewed and approved by either the Chief Operations Officer or the Executive Director. Review and Signature approvals will be added to all invoices to meet the criteria identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: April 2026

View Audit 392629

Finding 1179783 (2023-009)

Material Weakness 2023

South Bend Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403 § 200.430

FINDING 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of...

FINDING 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Payroll Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Vendor Contracts All contracts and MOUs follow a controlled approval process to ensure proper oversight and legal compliance. Once drafted, each agreement is submitted for review, and the Legal Department evaluates any document requiring an Opinion of Counsel or involving a waiver of the Corporation’s or School Board’s legal rights. Legal also maintains electronic copies of all finalized agreements. Contracts may only be approved by the Superintendent or the School Board, and MOUs must first be reviewed and approved by the Superintendent before going to the Board. After all required reviews and approvals are completed, the agreement is formally executed and electronically filed by the Legal Department. All required documentation specified in the contract will be retained, along with all related vendor invoices. Correction Date October 5, 2023 payroll and December 2024 vendor

View Audit 392186

Finding 1179778 (2023-008)

Material Weakness 2023

South Bend Community School Corporation

IN

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

FINDING 2023-008 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of ...

FINDING 2023-008 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Correction Date October 5, 2023

View Audit 392186

Finding 1179770 (2023-004)

Material Weakness 2023

South Bend Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.334 § 200.403 § 200.430

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us View...

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. Corrected Date 06/30/2025

View Audit 392186

Finding 1179668 (2023-005)

Material Weakness 2023

Lake County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-005 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between T...

FINDING 2023-005 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop and implement a proper system of internal controls and segregation of duties. This will ensure accuracy and correctness of all quarterly P & E Reports in the future. Completion Date: June 2026

View Audit 392081

Finding 1179665 (2023-003)

Material Weakness 2023

Lake County

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303 § 200.308 § 200.403

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the f...

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding with reservations on a portion of the Finding. Description of Corrective Action Plan: \ This program is completed and the period of performance is over therefore there is not a need to formally adopt any Corrective Action Plan. The Subrecipient Contractor that administered the program has agreed that this finding was due to their internal error in submitting administration invoices too late to be properly processed and approved by the County. They will be reimbursing the ERA1 fund for the error in the amount of $154,812.56 that will be sent back to the US Treasury. Reservation: The US Treasury required the local grant recipient to prosecute ERA1 fraud activities. There were two fraud cases that were prosecuted by our local attorney. His fees were then deducted from the ERA1 fund as administration costs. The grant recipient should not be penalized for doing as directed to prosecute fraud cases without being able to pay for the services rendered. We do not control the timelines of the local courts nor the responses/actions of the defendants delaying the actions beyond the Period of Performance. Anticipated Completion Date: None, no corrective action plan is necessary.

View Audit 392081

Finding 1179662 (2023-002)

Material Weakness 2023

Fall Mountain Regional School District

NH

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.313 § 200.318 § 200.319 § 200.320 § 200.431

Cause: While policies were in place, detailed written procedures for consistent grant administration had not been developed or formally documented. Corrective Action Taken: A procedure manual has been written to incorporate required compliance areas, including allowability of costs, procurement, equ...

Cause: While policies were in place, detailed written procedures for consistent grant administration had not been developed or formally documented. Corrective Action Taken: A procedure manual has been written to incorporate required compliance areas, including allowability of costs, procurement, equipment management, cash management, time and effort reporting, suspension and debarment, and record retention. Planned Corrective Actions / Preventive Measures: 1. Procedure Development: Document clear written procedures including requisitioning, approvals, reimbursements, reporting, and monitoring. 2. Training and Implementation: Provide training to all staff involved in grant administration on the new procedures. Establish a schedule for periodic refresher training and updates when regulations or program requirements change. 3. Ongoing Monitoring: Designate the Business Administrator (or designee) to monitor compliance and review procedures annually. Update policies and procedures as needed to reflect changes in federal requirements or internal practices. Timeline: Procedures completed: September 2024. Staff training and implementation: June 2026. Ongoing monitoring: Annually, beginning March 2026 Responsible Parties: Lori Schmidt, Business Administrator: Oversight of policy and procedure revision, implementation, and monitoring. Scott LaFortune, Finance Manager/Grant Manager: Day-to-day adherence to procedures and reporting. School Board: Formal policy approval.

View Audit 392071

Corrective Action Plans

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