Corrective Action Plans

Finding 519483 (2023-004)

Material Weakness 2023

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded program...

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded programs. Implement a compliance checklist for all federally funded expenditures to ensure alignment with Education Stabilization Fund requirements. Conduct internal audits every quarter to monitor compliance and document findings. Timeline: Immediate implementation; quarterly compliance reviews. Responsible Parties: Finance Director, APSRC, and Directors.

View Audit 338456 Questioned Costs: $1

Finding 519481 (2023-001)

Material Weakness 2023

Mental Health Resource of Texas, Inc.

TX

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

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update:...

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update: History and Board Actions: In FY 2021, Via Hope experienced a significant loss of revenue due to the ending of contracts from its two primary funding streams – the Health and Human Services Commission and the Hogg Foundation for Mental Health. This loss of revenue resulted in the Board recommending and approving the reduction of staff and the departure of the CEO. In FY 2022, the Board recommended and approved the termination of its Accounts Manager and the former Board Chairman stepped in to voluntarily manage the finances until the organization could make other arrangements. The former chairman stepped down from his role and an election of officers was held to install a new Chair. By January 2022, with new revenue coming into the organization, the Board selected a new CEO and in December 2022, a new accounts manager was hired. Once the new accounts manager began reconciling the accounts, a pattern of questionable expenditures became evident with PayPal and other accounts. The CEO and staff informed the Board of what appeared to have happened and recognizing its fiduciary responsibility, the Board approved the engagement of a forensic audit by an external audit firm, The Wesley Peachtree Group (WPG) of Atlanta, Georgia. The forensic audit resulted in findings that fraudulent activity in the amount of $233,000 was likely to have occurred. As a result, the CEO was instructed to file an insurance claim with Frost Insurance. To process the claim, Frost required the involvement of law enforcement which was approved by the Board. Formal investigations were launched and remain ongoing with the Austin Police Department and the Travis County District Attorney's office. Recently, law enforcement met with the Board and provided an update on the investigation. Subsequently, the CEO was requested to follow up with the insurance carrier and state regulatory agencies to ensure the prompt receipt of its insurance claim from PayPal and other potential sources. II. FINDINGS AND RECOMMENDATIONS: Finding 2023-001 - Internal Control Deficiencies (Material Weakness) a) Time and Effort, Payroll and Human Resource Forms and Contracts - In response to the finding, Management will require monthly Time and Effort reports for each employee, develop new human resource forms, and update staff contracts at the beginning of the fiscal year. b) Drawdowns and Written Approvals - With the addition of the new Finance staff member in January 2025, management will initiate a written approval process. All payroll adjustments, drawdowns, credit card purchases, and payments will require invoices, receipts, and written approvals before payment is made. The Accounting Manager will also work with the CEO to ensure that staff provide receipts promptly and that journal entries are recorded on a monthly basis. c) Receipts, Written Approvals, PP&E Schedule - Receipts and written approvals were addressed in Response (C). While the organization maintains an equipment log, we will establish a formal Property, Plant, and Equipment Schedule (PP&E), particularly noting equipment purchased with federal funds. d) Paypal, Frost, Forte - Management continues to work with law enforcement to obtain misappropriated funds from PayPal, and other potential accounts. As indicated, investigators met with the CEO, staff, Frost Bank, and the Board to obtain information regarding these accounts. It is our understanding that they may meet with prior Via Hope executives as well. We will update the auditors when more information is provided. e) Segregation of Duties - Management has begun the process of interviewing qualified staff to segregate duties in the Finance office. This will ensure that one individual will no longer be responsible for handling funds, payments, reconciliations, and General Ledger (GL) postings. The individual will be in place by January 2025.

View Audit 338449 Questioned Costs: $1

Finding 519404 (2023-002)

Significant Deficiency 2023

Crawford County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403 § 200.415

FA 2023-002 Strengthen Budgetary Controls over Expenditures Internal Control Impact: Significant Deficiency Compliance Impact: Activities Allowed or Unallowed Allowable Costs/Cost Principle Prior Year Finding: None Description: A review of expenditures charged to the Elementary and Secondary ...

FA 2023-002 Strengthen Budgetary Controls over Expenditures Internal Control Impact: Significant Deficiency Compliance Impact: Activities Allowed or Unallowed Allowable Costs/Cost Principle Prior Year Finding: None Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures has not been properly approved by the pass- through entity. Corrective Action Plans: the School District will work with all entities to confirm that all existing controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures comply with all applicable policies and regulations. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

View Audit 338350 Questioned Costs: $1

Finding 519402 (2023-001)

Material Weakness 2023

Crawford County Board of Education

GA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multipl...

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multiple control categories. Corrective Action Plans: Management will review, design, and implement procedures to strengthen the internal controls over the accounting functions to ensure transactions are properly processed and reported. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

View Audit 338350

Finding 519400 (2023-007)

Material Weakness 2023

Town of Seabrook

NH

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Audit Finding Reference: 2023-007 Management’s Response and Planned Corrective Action: Implement a record keeping process for all rates and weighted rates for payroll. Name of Contact Person and Completion Date: Name: William Manzi

View Audit 338332 Questioned Costs: $1

Finding 519310 (2023-001)

Material Weakness 2023

Startupnv, Inc.

NV

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

StartUpNV, Inc. Corrective Action Plan Year Ended December 31, 2023 2023-001 System of Internal Controls and Resulting Disclaimer of Opinion Criteria: The Internal Revenue Service (IRS) has defined a charitable organization as “organized and operated exclusively for religious, charitable, scient...

StartUpNV, Inc. Corrective Action Plan Year Ended December 31, 2023 2023-001 System of Internal Controls and Resulting Disclaimer of Opinion Criteria: The Internal Revenue Service (IRS) has defined a charitable organization as “organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, educational, or other specified purposes.” As a result of an entity being recognized as an exempt charitable organization, the nonprofit is entitled to favorable treatment(s) reserved for such entities (e.g., reduced taxation). Condition: The Organization was unable to produce sufficient appropriate audit evidence to support its assertion that revenues and expenditures related to StartUpNV, Inc. exclusive activities. Cause: The system of internal controls implemented by the Organization was not well-defined and did not contain appropriate segregation of duties amongst non-interested parties. Effect: The Organization was unable to provide sufficient appropriate audit evidence to support issuance and receipt of an unmodified audit opinion. This led to delays in the overall audit process resulting in late filing of the Data Collection Form to the Federal Audit Clearinghouse (FAC). Recommendation: We recommend management design and implement a system of internal controls whereby clear delineation between StartUpNV, Inc. activities and those of interested parties is supported. Further, we recommend that this system of internal controls be well documented and consistently applied. Risk assessment as it relates to general exempt organization compliance, as well as specific compliance related to federal award receipts, should be consistently performed by appropriate, competent personnel. With these systems in place, StartUpNV, Inc. will be better positioned to support regulatory expectations and requirements. Responsible official: Maggie Saling Title: Chief of Operations Email: maggie@startupnv.org Phone number: 805.302.1862 StartUpNV will create a policy document that shows procedures for internal control of expenditures that includes independent oversight. StartUpNV plans to contract with an outside party to perform an independent review and approval of expenditures prior to grant reimbursement requests and establish formal, documented procedures governing this process. Due to the recent resignation of the board treasurer, the incoming treasurer will assume oversight responsibility for this independent reviewer and budgetary and expenditure controls. The current Executive Director plans to announce his retirement from the non-profit organization – and announce a Board of Directors search process for his replacement. The appointment of a new Executive Director will address the requirements for the segregation of duties and independence. The Chief of Operations will provide guidance and support to the new Executive Director, ensuring a smooth transition of responsibilities through her planned retirement by the end of the year. The search and hiring process for a new Executive Director is anticipated to be completed within a timeline of 6 months.

View Audit 338154

Finding 519295 (2023-003)

Material Weakness 2023

Jacobson Memorial Hospital Care Center and Subsidiary

ND

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Federal Agency Name: Department af Health and Human Services Program Name: Cavid-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing #93.498 Finding Summary: The Hospital's calculation of lost revenue claimed under the federal program as an allowable...

Federal Agency Name: Department af Health and Human Services Program Name: Cavid-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing #93.498 Finding Summary: The Hospital's calculation of lost revenue claimed under the federal program as an allowable cost contained no formal review or approval by a separate individual outside of the preparer. In addition, there was no evidence retained that the Hospital's special report submitted to t he Department of Health and Human Services for Period 4 was reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Scott Brooks, CEO and Stephanie La Brie, CFO Corrective Action Plan: Internal controls will be updated to include that all reports and supporting documents will be reviewed by the CEO if the CFO compiles for accuracy and vice versa. The reviewer will sign off by email or by physical signature that they have reviewed and agree with the support. Anticipated Completion Date: 6/30/2024

View Audit 338062

Finding 519151 (2023-004)

Significant Deficiency 2023

Southwest Center for Hiv/aids, INC

AZ

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

Item: 2023-004 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Spec...

Item: 2023-004 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR § 200.430 – Compensation – charges to federal programs for salaries and wages should be supported by a system of internal controls which provides reasonable assurance the amounts charged are accurate, allowable and properly allocated. Condition: Incorrect allocation of employee hours were charged to the federal program. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2024 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. Billings are reviewed by supervisors, including a review of the underlying supporting documentation, prior to submission of the billing. Additional training and record retention practices will be added and/or enhanced to ensure there is evidence of supervisory review of the underlying supporting documentation. Such review and record retention processes will include documentation of noted discrepancies and rationale for such discrepancies if not corrected.

View Audit 337692

Finding 519150 (2023-003)

Material Weakness 2023

Southwest Center for Hiv/aids, INC

AZ

Allowable Costs / Cost Principles Material Weakness Reporting § 200.405

Item: 2023-003 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Spec...

Item: 2023-003 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR § 200.405 – Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2024 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

View Audit 337692

Finding 519149 (2023-002)

Material Weakness 2023

Southwest Center for Hiv/aids, INC

AZ

Allowable Costs / Cost Principles Material Weakness Reporting § 200.405

Item: 2023-002 Assistance Listing Number: 93.914 Programs: HIV Prevention Emergency Relief Project Grants Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Maricopa County Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In acco...

Item: 2023-002 Assistance Listing Number: 93.914 Programs: HIV Prevention Emergency Relief Project Grants Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Maricopa County Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR § 200.405 – Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2024 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

View Audit 337692

Finding 519038 (2023-005)

Significant Deficiency 2023

MacOn and Piatt Counties Regional Office of Education No. 39

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.403

CONDITION: The Regional Office of Education No. 39 did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. PLAN: Although procedures were put into place in March 2023 to ensure that all expenditures were signed by the P...

CONDITION: The Regional Office of Education No. 39 did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. PLAN: Although procedures were put into place in March 2023 to ensure that all expenditures were signed by the Program Directors, or Assistant/Regional Superintendent the previous Business Office Manager and Accounts Payable employee were not consistent on ensuring that all receipts/invoices were reviewed if a PO was created and approved or if it was approved with prior requisition form. A new purchasing process will be implemented that will document all expenditures have been reviewed, approved, and ensured that they are allowable under the federal and state award. This process will be consistent across all purchases to ensure that all approvals and reviews are conducted and documented. ANTICIPATED DATE OF COMPLETION: Implemented May 2024 CONTACT PERSON: Jill Reedy, Regional Superintendent

View Audit 337563

Finding 518925 (2023-003)

Material Weakness 2023

Eclectic Soul Voices Corporation

IN

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.302

Finding 2023-03 Lack of Documentation to Support Expenditures Condition: The Organization failed to maintain financial records that properly substantiated expenditures which limited the ability to test several compliance requirements as part of audit procedures. These issues were most prevalent in ...

Finding 2023-03 Lack of Documentation to Support Expenditures Condition: The Organization failed to maintain financial records that properly substantiated expenditures which limited the ability to test several compliance requirements as part of audit procedures. These issues were most prevalent in testing direct disbursements. As part of audit procedures, 81 transactions were selected in a testing sample from a population which included 315 transactions. Of the 81 transactions tested, the Organization was unable to provide sufficient source documentation to support 21 of the transactions. Further, vendor and contract files were not consistently maintained and failed to provide adequate support to detail the history, method, and selection of procurement. Corrective Actions Taken or Planned: - Collaborate with the CPA firm to develop a standardized process for recording and tracking gift card transactions and allotments, ensuring accountability and traceability. - Add LaKisha (Executive Administrative Assistant) to QuickBooks with specific responsibilities for recording receipts, requisition forms, and matching these to corresponding transactions. Provide QuickBooks training for the Executive Assistant to strengthen understanding and ensure timely and accurate documentation of financial activities. - Develop and enforce a formal policy requiring comprehensive documentation (e.g., invoices, receipts, contracts) for all expenditures over a certain threshold (e.g., $500 or higher). This policy will include requirements for approval and justification prior to disbursement. - Require all staff to complete requisition forms for supplies or purchases in advance of procurement. These forms will include itemized details, purpose of purchase, and approval signatures. - Update processes to ensure vendor and contract files include critical details: procurement history, selection method, contract terms, and vendor agreements. These files will be consistently maintained and reviewed for completeness. - Strengthen the credit card usage process to require staff to submit itemized receipts, purpose of purchase, and pre-approval for all credit card transactions. This will include monthly reconciliations and management review of all credit card statements. - Implement periodic internal reviews to ensure compliance with the new documentation and procurement processes. The CPA firm will assist with quality checks and provide ongoing guidance.

View Audit 337399 Questioned Costs: $1

Finding 518920 (2023-006)

Material Weakness 2023

Eclectic Soul Voices Corporation

IN

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

Finding 2022-06 Unallowable and Improperly Documented Payroll Expenditures Condition: The Organization failed to establish critical processes and internal controls over payroll expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As par...

Finding 2022-06 Unallowable and Improperly Documented Payroll Expenditures Condition: The Organization failed to establish critical processes and internal controls over payroll expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part of audit procedures, 44 transactions were selected in a testing sample from a population of 243 direct payroll transactions. Of the transactions tested, the auditors noted 8 instances of payroll costs overclaimed by way of claiming the same work effort for the same period on multiple grants. The auditors noted 18 instances of failure to properly calculate and allocate the work effort completed by employees that worked on multiple grants and programs. The auditors noted 9 instances of the Organization failing to have approved pay rates on file that matched the amounts paid to the employees. The auditors also noted a significant lack of supervisory approval on timesheets or other time allocation support. Corrective Actions Taken or Planned: - Conduct mandatory training for all supervisors to reinforce the importance of: + Accurate timesheet approval processes. + Proper time allocation for employees working on multiple grants or programs. + Ensuring timely and consistent documentation of payroll expenditures. - Engage Christy Paddock Advisors LLC (CPA firm) to: + Oversee payroll allocation processes to ensure employee time is properly distributed across grants and programs based on actual work effort. + Implement controls to flag and prevent duplicate payroll charges to multiple grants. + Payroll expense reports will be systematically reviewed and approved by the CPA firm and VOICES’ executive team prior to filing federal claims. - Ensure all approved pay rates are documented, signed, and filed for each employee. - Configure QuickBooks to ensure payroll costs and grant allocations are: + Clearly identifiable and traceable. + Linked to corresponding grants and federal claims. - Revise the PTO policy to address liability and improve tracking by: + Implementing a "use-it-or-lose-it" policy with a defined carryover limit. + Removing PTO payout upon termination to reduce financial exposure. + Communicate the updated policy clearly to staff and implement tracking in payroll systems.

View Audit 337399 Questioned Costs: $1

Finding 518919 (2023-005)

Material Weakness 2023

Eclectic Soul Voices Corporation

IN

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.402

Finding 2022-05 Unallowable and Improperly Documented Direct Expenditures Condition: The Organization failed to establish critical processes and internal controls over direct expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part ...

Finding 2022-05 Unallowable and Improperly Documented Direct Expenditures Condition: The Organization failed to establish critical processes and internal controls over direct expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part of audit procedures, 81 transactions were selected in a testing sample from a population of 315 direct expense transactions. Of the transactions tested, the auditors noted 15 instances of payments to contractors for work that were not sufficiently documented to support the allocatable work efforts performed on the grants in which they were charged. The auditors noted 4 instances where the costs charged to the federal grant were determined to not be reasonable, as they were either unallowable per Uniform Guidance, or were outside of the allowable costs approved in the federal award budgets. The auditors noted 1 instance of a transaction being claimed twice on different federal grants. The auditors also noted a significant lack of approvals for costs spent, as well as a failure to maintain adequate documentation, as noted in Finding 2023-003. Corrective Actions Taken or Planned: - Develop and implement a formal procurement policy to ensure all contractor and vendor selections are based on program needs and comply with federal regulations. The procurement process will include: + Clear criteria for vendor selection and justification. + Requirement to document scope of work, deliverables, and costs before engaging contractors. + Verification of vendor eligibility against the Suspension and Debarment list. - VOICES’ executive team will formally review, approve, and sign off on all expenditures charged to federal grants. - A pre-approval process for all expenditures over a specific threshold (e.g., $500) will be enforced to ensure costs are allowable, reasonable, and allocable to the appropriate grant - Require all contractors to submit detailed invoices that include: + Specific tasks performed + Hours worked or deliverables completed + Allocation to the corresponding grant(s) - Implement procedures to ensure expenses are not claimed more than once on multiple grants. This will include: + Regular reconciliation of federal grant expenses. + Review of expenditures by the executive team and CPA firm to detect duplicates. - Create and enforce a policy for documentation that requires all expenditures over a specific amount to be supported by: + Invoices or receipts + Approved requisition forms + Proof of deliverables (for contractors)

View Audit 337399 Questioned Costs: $1

Finding 518870 (2023-003)

Material Weakness 2023

The Astraea Foundation, Inc.

NY

Allowable Costs / Cost Principles Material Weakness Reporting

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work stream...

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work streams and projects.This information is detailed in a level of effort (LOE) spreadsheet tracked against timesheets and budgets regularly. However, the processes for instituting regular updates to the LOE spreadsheet and timesheet allocations remained time-consuming and highly manual in FY2023 – which we believe resulted in misallocations. Astraea is currently reviewing internal processes to ensure, 1) that review and revision of the LOE spreadsheet and timesheet allocations can happen in a timely manner with less administrative burden, and 2) allowance of a more detailed review of the payroll allocation approval and entry process. As of November 2024, the Astraea Finance team was in the process of transitioning to a more sophisticated finance and accounting system. This system will allow for automation of the processes. Since this system is expected to be live starting in January of 2025, the anticipated completion date remains January 31, 2025.

View Audit 337275

Finding 518701 (2023-007)

Significant Deficiency 2023

State of Mississippi

MS

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.308 § 200.309 § 200.403

2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Period of Performance lnternal controls over period of performance were not consistentlv performed Response: Of the five instances noted in the auditor's "Period of Perfor...

2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Period of Performance lnternal controls over period of performance were not consistentlv performed Response: Of the five instances noted in the auditor's "Period of Performance" test work, we concur with four. With one of the sample items, however, we argue that since the service was invoiced on a State Fiscal Year, it was impractical to further split the invoice into the various appropriate Federal periods of performance, especially given the way those specific invoices are allocated between other shared program areas within our agency, etc. Corrective Action Plan: Our agency takes these findings seraously and will continue to evaluate ways of improving controls. At a minimum, it is our intent to increase and provide additional training to the staff overseeing and approving these types of transactions so that they can accurately apply transactions to the appropriate periods. This was something we had already begun (i.e. provrding additional guidance and training to stafD during the current fiscal year. So, we hope our agency is already on a corrective path. But, we will continue to push for more training in the immediate future and strive for improvement in all other aspects. We also think it is important to note that, of the findings identifled by the auditors related to "Period of Performance," those items were discovered out of a total sample size oI 120 items (i.e. 60 sample items related to thejr "Period of Performance" test work and 60 sample items related to "General Disbursements" test work). So, a slightly larger sample size than that of the 60 referenced in the auditor's schedule of flndings. Additionally, the auditor's sample appeared to selectively target the specific periods and transactions that would have been most susceptible to these types of potential errors. And, although we are not objecting to the way in which the sample was selected, we would.just point out that this approach of sample selection may not be truly reflective of a purely random sample covering all transactions across the entire fiscal year. Therefore, although we ultimately concur with the findings here, we do not necessarily believe these results paint the fairest picture on the overall effectiveness of our agency's controls across the more than '100,000 transactions that would have been processed during the period of audit for this program. Again, we take these findings seriously. But, based on the audit test work and results, we feel the controls we have in place are ultimately working adequately enough to mitigate the potential for material misstatements. Regardless, we will continue to monitor and evaluate our controls to help further reduce the risk of these types of issues moving forward. Planned completion date for corrective action plan: lmmediately. But, additional training for managers to be provided by September 30, 2024.

View Audit 337153 Questioned Costs: $1

Finding 518700 (2023-008)

Significant Deficiency 2023

State of Mississippi

MS

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

2023-008 Assistance Listing No. 96.001, 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Allowable Costs lnternal Controls gtver glant disbursements were not consistently performed Response: There is no disagreement with the audit finding. Corrective Action Pla...

2023-008 Assistance Listing No. 96.001, 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Allowable Costs lnternal Controls gtver glant disbursements were not consistently performed Response: There is no disagreement with the audit finding. Corrective Action Plan: Item is isolated and immaterial. And, we feel effective controls are in place to mitigate the likelihood of this type of error. We have also, since, reached out to the vendor to redeem the $14 associated with this transaction. However, we will continue to monitor and reinforce, with our managers, the importance of being vigilant during their review and approval processes for this type of situatlon. Planned completion date for corrective action plan: lmmediately Name(s) of the contact person(s) responsible for corrective actions: Andy Salin Finance Director 601-853-5220.

View Audit 337153 Questioned Costs: $1

Finding 518669 (2023-026)

Material Weakness 2023

State of Mississippi

MS

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.400

2023-026 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements ALN #21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the pr...

2023-026 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements ALN #21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the program. As such, DFA was not in a position to assess eligibility determinations or perform monitoring. DFA drew down funds on behalf of Mississippi Home Corp in light of an impending federal deadline. Mississippi Home Corporation had eligibility and fraud prevention policies in place for the ARPA programs. These policies included, but are not limited to, contracting with a third-party law firm to review all applications with a three-tier review system, monitoring with random sample selections for every 10% completed, employing an internal, qualitycontrol auditor, and reviewing any applications submitted that were greater than $10,000. As a result of their monitoring, MHC was able to identify suspicious applications and report them to the Mississippi Attorney General for investigation. MHC continues to report all expenditures directly to U.S. Treasury on a quarterly basis. It is also worth noting that the program stopped taking applications in September of 2022 which was prior to the issuance of the 2022 Single Audit Report that was released on July 31, 2023. Thus, policies and controls in place could not be changed for this. DFA is taking the position that corrective action is no longer necessary for these funds. Corrective Action: A. The Mississippi Department of Finance and Administration is taking the position that corrective action is no longer necessary. The program stopped taking applications in September of 2022, which is prior to the current 2023 single audit report dated November 21, 2024. Policies and controls in place could not be changed for this. B. N/A C. N/A D. The Emergency Rental Assistance program stopped taking applications September of 2022.

View Audit 337153

Finding 518655 (2023-002)

Significant Deficiency 2023

America Walks, Inc.

WA

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Contact person(s) responsible: Nicole Smith, Operations Manager Corrective action planned: We will prepare the manual of financial and federal compliance policies and procedures (including cash management, allowable costs, and procurement) as required by the Uniform Guidance. Pertinent employees wil...

Contact person(s) responsible: Nicole Smith, Operations Manager Corrective action planned: We will prepare the manual of financial and federal compliance policies and procedures (including cash management, allowable costs, and procurement) as required by the Uniform Guidance. Pertinent employees will be trained to use this manual to ensure compliance. Anticipated completion date: December 31, 2024

View Audit 337123

Finding 518643 (2023-003)

Significant Deficiency 2023

Mandaree Public School District No 36

ND

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Contact Person: Business Manager and Human Resource Manager Planned Corrective Action: The District currently does have processes and controls in place to ensure grant expenditures have been approved. Specific to this audit finding of employee contracts and employee timecards missing proper approval...

Contact Person: Business Manager and Human Resource Manager Planned Corrective Action: The District currently does have processes and controls in place to ensure grant expenditures have been approved. Specific to this audit finding of employee contracts and employee timecards missing proper approvals, the Business Manager will meet with the Human Resource Manager to review the current control and approval processes for employee contracts and timecards and make changes as appropriate. Planned Completion Date: January 2025

View Audit 337094

Finding 518631 (2023-004)

Significant Deficiency 2023

Mandaree Public School District No 36

ND

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Contact Person: Business Manager and Human Resource Manager Planned Corrective Action: The District currently does have processes and controls in place to ensure grant expenditures have been approved. Specific to this audit finding of an employee contract and salary authorization forms not having pr...

Contact Person: Business Manager and Human Resource Manager Planned Corrective Action: The District currently does have processes and controls in place to ensure grant expenditures have been approved. Specific to this audit finding of an employee contract and salary authorization forms not having proper approvals, the Business Manager will meet with the Human Resource Manager to review the current control and approval processes for employee contracts and salary authorization forms and make changes as appropriate. Planned Completion Date: January 2025

View Audit 337094

Finding 518474 (2023-002)

Material Weakness 2023

Rhode Island Association of Conservation Districts

RI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

RIACD has instituted a system by which all transactions are reviewed by the Treasurer (or a delegate), completed by the Secretary or President, and recorded by a contracted administrator. This system, instituted in early 2024, ensures adequate separation of duties to ensure that all federal funds ar...

RIACD has instituted a system by which all transactions are reviewed by the Treasurer (or a delegate), completed by the Secretary or President, and recorded by a contracted administrator. This system, instituted in early 2024, ensures adequate separation of duties to ensure that all federal funds are spent appropriately. RIACD’s current Treasurer is an experienced businessman who is knowledgeable about accounting principals and budget management, and his expertise is a credit to the Board. He recently committed to serve an addition two-year term in the role. Marcum has reviewed this new approval system and advised that it is an appropriate way to proceed with this correct action. RIACD identified Phil Moreschi, Treasurer, as the party responsible for this corrective action. You can contact Phil Moreschi and philmor54@comcast.net.

View Audit 336931

Finding 518152 (2023-016)

Material Weakness 2023

Mental Health Association of Columbia-Greene Counties Inc.

NY

Allowable Costs / Cost Principles Procurement, Suspension & Debarment

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive ...

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditures must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

View Audit 336457

Finding 518086 (2023-001)

Significant Deficiency 2023

The Montessori Network

IL

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties

Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal yea...

Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal year 2020, and corrective actions were taken by the School in 2021. To address the issue, the School implemented new procedures that require a monthly review by management, which includes a detailed reconciliation of submitted personnel activity reports to vouchers prepared for federal and other programs. This reconciliation process helps to ensure that payroll cost allocation accurately reflects the submitted personnel activity reports. In addition, the School has made changes to its payroll system to ensure accurate time tracking for its various programs. This includes changing the service provider responsible for voucher submissions. These changes will help to prevent similar issues from occurring in the future and ensure that employee-related costs are accurately allocated to the appropriate programs. As of 2022, the School has successfully implemented these changes and continues to review and monitor its procedures to maintain compliance with federal and other program regulations. Finding was repeated during FY23, as the School was in the process of transitioning accounts during the period of exceptions noted. Anticipated Completion Date: June 30, 2023 Contact Person: Rita Nolan, Executive Director

View Audit 336394

Finding 517955 (2023-012)

Material Weakness 2023

Unified Government of Wyandotte County and Kansas City, Kansas

KS

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083 Management’s Response: During 2024, management worked with the Fire Department and Payroll to ensure only straight time was coded to this grant and no overtime was charged to this grant. This was a...

U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083 Management’s Response: During 2024, management worked with the Fire Department and Payroll to ensure only straight time was coded to this grant and no overtime was charged to this grant. This was a finding in 2022 but we were not aware until the audit was completed in 2024 there was an issue the existing payroll system was not flagging. This has been corrected in in 2024 and should not be a recurring issue. Views of Responsible Officials and Corrective Action: The reason for recurrence is the finding was communicated late in the prior year. Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

View Audit 336226

Corrective Action Plans

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