Corrective Action Plans

Finding 513376 (2024-002)

None 2024

City of Charlotte

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.318

CORRECTIVE ACTION PLAN 2024-002 – Written Policies Required by Uniform Grant Guidance Corrective Action: Institute a formal grant policy in accordance with Uniform Grant Guidance. Responsible Party: Finance Director Date to Complete By: 1-31-25

View Audit 331213

Finding 513144 (2024-003)

Significant Deficiency 2024

Community Health Partners, Inc.

MT

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective Action Plan: As of 5/1/2024, Community Health Partners merged with One Health, which utilizes ADP as the electronic payroll service provider. The payroll process within One Health requires review and approval of timecards by supervisors and payroll administrators. One Health will ensure t...

Corrective Action Plan: As of 5/1/2024, Community Health Partners merged with One Health, which utilizes ADP as the electronic payroll service provider. The payroll process within One Health requires review and approval of timecards by supervisors and payroll administrators. One Health will ensure that payroll is processed and reviewed according to approved policies. Anticipated Completion Date: 12/31/2024 Contact Person Responsible for Corrective Action: Emily Faricy – Associate Vice President Finance

View Audit 331131

Finding 513143 (2024-002)

Significant Deficiency 2024

Community Health Partners, Inc.

MT

Allowable Costs / Cost Principles Reporting

Corrective Action Plan: As of 5/1/2024, Community Health Partners merged with One Health, which utilizes a data analytics team along with the finance team to compile and review UDS data. UDS data validation, including classification of provider visits, begins early in the UDS preparation process and...

Corrective Action Plan: As of 5/1/2024, Community Health Partners merged with One Health, which utilizes a data analytics team along with the finance team to compile and review UDS data. UDS data validation, including classification of provider visits, begins early in the UDS preparation process and is verified by multiple sources. Classification of providers is verified by human resources, finance and the data/informatics team. Preparation of the UDS submission includes cross-referencing multiple data sets to ensure accuracy in classification of providers. Anticipated Completion Date: 2/15/2025 Contact Person Responsible for Corrective Action: Emily Faricy – Associate Vice President Finance

View Audit 331131

Finding 513087 (2024-002)

Material Weakness 2024

Village of Lexington

MI

Matching / Level of Effort / Earmarking Questioned Costs Procurement, Suspension & Debarment

While the Village of Lexington followed current internal controls for all aspects of the federal awards granted, we did not adopt a document that covered all five compliance areas as outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. A wr...

While the Village of Lexington followed current internal controls for all aspects of the federal awards granted, we did not adopt a document that covered all five compliance areas as outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. A written policy and procedure document will be adopted by the Council by December 31, 2024.

View Audit 331022

Finding 512973 (2024-001)

Significant Deficiency 2024

Four Corners Regional Educational Cooperative #1

NM

Cash Management Allowable Costs / Cost Principles Reporting § 200.305 § 200.400

Recommendation We recommend a verification process be established to ensure accuracy in manual journal entries and to prevent the occurrence of duplicate recordings. Regular reconciliations should be enhanced and additional review steps should be incorporated during the financial close process to...

Recommendation We recommend a verification process be established to ensure accuracy in manual journal entries and to prevent the occurrence of duplicate recordings. Regular reconciliations should be enhanced and additional review steps should be incorporated during the financial close process to identify and correct errors promptly. Furthermore, future Federal Financial Report should take this error into account to accurately reflect cumulative expenditures. Management Response Corrective Action: Four Corners REC has added additional verification processes to ensure the accuracy of manual journal entries to prevent duplicate entries. Reconciliations will be done timely and accurately with added steps. Additional reviews will be done during financial closing and future federal expenditure reporting has been corrected. Due Date of Completion: Completed as of September 9, 2024 Responsible Party(ies): Finance Director

View Audit 330792

Finding 512924 (2024-003)

Significant Deficiency 2024

Wake County, North Carolina

NC

Allowable Costs / Cost Principles Reporting Student Financial Aid

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCD...

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Medicaid Cluster (Medicaid), Assistance Listing Number 93.778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Supplemental Nutrition Assistance Program (SNAP) Cluster, Assistance Listing Number 10.561, 10.561-COVID, U.S. Department of Agriculture, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Recommendation: We recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. Corrective Action Plan: The county will conduct training on day sheet and time sheet processes. The county will complete random monthly reviews of day sheets and timesheets. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on day sheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2025 for initial department training 2/28/2025 initiate random monthly reviews of day sheets and timesheets 7/31/2025 for additional reviews as needed for identified staff and refresher trainings Name of Contact Person: Yolanda Mcinnis, Economic Services Division Director and Sheila Donaldson Child Welfare Division Director

View Audit 330686

Finding 512875 (2024-005)

Significant Deficiency 2024

Grant Soil & Water Conservation District

OR

Allowable Costs / Cost Principles Reporting

Recommendation: We recommend the organization develop a system to implement a secondary review of all reports prior to submission. We recommend that documentation from the organization’s general ledger or other performance tracking methods be maintained and reconciled with copies of the reports to e...

Recommendation: We recommend the organization develop a system to implement a secondary review of all reports prior to submission. We recommend that documentation from the organization’s general ledger or other performance tracking methods be maintained and reconciled with copies of the reports to ensure the personnel responsible for providing secondary review and approval for the reports prior to submission can verify totals and metrics reported to ensure completeness and accuracy.

View Audit 330638

Finding 512874 (2024-004)

Material Weakness 2024

Grant Soil & Water Conservation District

OR

Allowable Costs / Cost Principles Equipment & Real Property Management Internal Control / Segregation of Duties

Recommendation: We recommend that the district re-review all costs charged to the program and isolate direct costs that comply with cost principle requirements. This should only include costs that are documented as directly applicable to the program. Direct costs should be charged at cost. Indirect ...

Recommendation: We recommend that the district re-review all costs charged to the program and isolate direct costs that comply with cost principle requirements. This should only include costs that are documented as directly applicable to the program. Direct costs should be charged at cost. Indirect costs including overhead, general administrative salaries and wages, untracked employee time, coordination fees, and other general and administrative costs associated with inventories should then be excluded from being charged to the program and applied to the grant using the indirect cost rate outlined in the grant agreement and reported accordingly. Further, we recommend the district implement a method of secondary review and approval over calculations for the indirect cost rate to ensure it is calculated completely and correctly

View Audit 330638

Finding 512608 (2024-004)

Significant Deficiency 2024

Northeastern Oklahoma Agricultural An Mechanical College

OK

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303 § 200.430

2024-004 Higher Educational Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit...

2024-004 Higher Educational Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A standard template will be used for all grants for time and effort reporting and a standard procedure for approvals will be enforced to show proper approvals from supervisors. Name(s) of the contact person(s) responsible for corrective action: Dr. Dustin Grover, VP of Academic Affairs; Amy Ishmael, VP of Student Affairs; Brando Glick, VP of Fiscal Affairs Planned completion date for corrective action plan: 12/31/24

View Audit 330423

Finding 512475 (2024-005)

Material Weakness 2024

Chippewa Hills School District

MI

Allowable Costs / Cost Principles § 200.402

Finding 2024-005 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-005 - Activities Unallowed or Allowed and Allowable Costs Cost Principles Type: Material weakness in internal control over compliance / Noncompliance. Condition: Expenditures charged to the grant were not authoriz...

Finding 2024-005 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-005 - Activities Unallowed or Allowed and Allowable Costs Cost Principles Type: Material weakness in internal control over compliance / Noncompliance. Condition: Expenditures charged to the grant were not authorized in the grant budget. Corrective action to be taken: Grant agreements will be reviewed, approved, and maintained by all applicable shareholders with correlating budgeting metrics in place to ensure compliance continuity throughout the life cycle of the grant. The collaborative approach is designed to provide a thorough understanding of allowable costs, provide redundancy in grant metrics in the event of personnel changes, and support the established internal controls to assure charges to the grant do not exceed the budget and only allowable costs are charged to the grant. Corrective action timeline: The corrective action is effective immediately. District leader responsible for Corrective Action Plan: The Finance Director will be responsible for ensuring compliance with this corrective action. Respectfully submitted, Marc Forrest, Director of Finance

View Audit 330250

Finding 512474 (2024-004)

Material Weakness 2024

Chippewa Hills School District

MI

Allowable Costs / Cost Principles § 200.402

Finding 2024-004 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-004 - Activities Unallowed or Allowed and Allowable Costs Cost Principles Type: Material weakness in internal control over compliance / Noncompliance. Condition: Expenditures charged to the grant were not authoriz...

Finding 2024-004 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-004 - Activities Unallowed or Allowed and Allowable Costs Cost Principles Type: Material weakness in internal control over compliance / Noncompliance. Condition: Expenditures charged to the grant were not authorized in the grant budget. Corrective action to be taken: Grant agreements will be reviewed, approved, and maintained by all applicable shareholders with correlating budgeting metrics in place to ensure compliance continuity throughout the life cycle of the grant. The collaborative approach is designed to provide a thorough understanding of allowable costs, provide redundancy in grant metrics in the event of personnel changes, and support the established internal controls to assure charges to the grant do not exceed the budget. Corrective action timeline: The corrective action is effective immediately. District leader responsible for Corrective Action Plan: The Finance Director will be responsible for ensuring compliance with this corrective action. Respectfully submitted, Marc Forrest, Director of Finance

View Audit 330250

Finding 512422 (2024-001)

None 2024

Metropolitan Transit Authority

TN

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

Management concurs with the finding that the internal control policy as it relates to cash disbursements was not followed. Management is committed to following the internal control policy and has added two additional reviews of all checks issued for greater than the specified threshold to ensure tha...

Management concurs with the finding that the internal control policy as it relates to cash disbursements was not followed. Management is committed to following the internal control policy and has added two additional reviews of all checks issued for greater than the specified threshold to ensure that each check issue includes two authorized signatures. One is completed by the person circulating the checks for signature and the other is completed by the person finalizing the payment processing procedures. Anticipated Completion Date: September 17, 2024

View Audit 330148 Questioned Costs: $1

Finding 512298 (2024-008)

None 2024

Richland County Housing Authority

MT

Questioned Costs Allowable Costs / Cost Principles

Finding 2024-008: Allowable Costs Capital Funds 14.872 Noncompliance: AGREED Questioned Costs-$305,004 RCHA agrees that the five-year plan indicates what each annual grant will be spent on, and the annual budget must be modified upon the grant award to match the grant amount. Allowable costs mu...

Finding 2024-008: Allowable Costs Capital Funds 14.872 Noncompliance: AGREED Questioned Costs-$305,004 RCHA agrees that the five-year plan indicates what each annual grant will be spent on, and the annual budget must be modified upon the grant award to match the grant amount. Allowable costs must be included within the budget. Corrective Action: RCHA Administration will begin monitoring and assuring grant monies are only spent on budgeted items, and those monies are recorded appropriately. This action will begin immediately. Corrective Action: RCHA Administration will continue with education on this process and maintain policies and procedures regarding Capital Funds. This action will continue on a regular basis, including updates to HUD requirements. Corrective Action: RCHA Administration will continue working with HUD field office with regular communication and clarification of items regarding the five-year plan, capital funds utilization and modifications.

View Audit 330072 Questioned Costs: $1

Finding 511888 (2024-014)

Material Weakness 2024

Nevada System of Higher Education

NV

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will in...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will work with PIs to ensure there is properly documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. • How compliance and performance will be measured and documented for future audit, management and performance review: Effective immediately, UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility along with applicable Deans. DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. SA – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Future progress reports will require a review from a Director or higher supervisory approval prior to submission of reports to awarding sponsor/agency. • How compliance and performance will be measured and documented for future audit, management and performance review: Preparing department will provide either a signed version and/or email approval of progress report to the NSHE System Sponsored Programs to be filed with the award in Workday. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The NSHE System Sponsored Programs Director is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 511847 (2024-013)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Questioned Costs

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The UNLV Office of Sponsored Programs will collaborate with payroll and budget offices to develop a procedure to e...

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The UNLV Office of Sponsored Programs will collaborate with payroll and budget offices to develop a procedure to ensure costing allocations assigned by colleges/departments are within the period of performance. We expect this procedure to be vetted and implemented by spring 2025. • How compliance and performance will be measured and documented for future audit, management and performance review: UNLV OSP will monitor costing allocations and efficiently communicate to colleges/departments to identify allocations beyond the period of performance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsible for communicating the importance of enhanced review of accounts and payroll costing allocations to monitoring accounts. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596 Questioned Costs: $1

Finding 511807 (2024-022)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Questioned Costs

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will collaborate with the Controller’s Office to ensure expenditure postings are...

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will collaborate with the Controller’s Office to ensure expenditure postings are within the period of performance. This review and any applicable changes will go into effect by the end of the calendar year 2024. • How compliance and performance will be measured and documented for future audit, management and performance review: UNLV Office of Sponsored Programs will monitor expenditures within the period of performance and efficiently communicate to colleges/departments to identify transactions that are deemed unallowable. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596 Questioned Costs: $1

Finding 511787 (2024-021)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Questioned Costs

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV will review business processes related to routing and approval of expenditures under specific categories (i.e...

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV will review business processes related to routing and approval of expenditures under specific categories (i.e.: hosting, participant support, etc.) as it relates to grants. If the review dictates that business processes need to be revised, this will be completed by spring 2025 to incorporate any necessary changes. • How compliance and performance will be measured and documented for future audit, management and performance review: The Office of Sponsored Programs and the applicable departments will collaborate to ensure oversight of expenditures to determine allowability. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility, and will communicate regularly with the Deans and business managers. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596 Questioned Costs: $1

Finding 511764 (2024-018)

Material Weakness 2024

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Questioned Costs

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: All invoices will be reviewed and approved by a manager independent of the preparer. The manager’s review will incl...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: All invoices will be reviewed and approved by a manager independent of the preparer. The manager’s review will include verifying the accuracy of the invoice details, such as dates of the costs incurred, to ensure they fall within the period of performance. • How compliance and performance will be measured and documented for future audit, management and performance review: The manager's independent review and approval of each invoice, including verification of cost dates, will be tracked within the system’s business process history. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596 Questioned Costs: $1

Finding 511747 (2024-017)

Significant Deficiency 2024

Nevada System of Higher Education

NV

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

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: While there were no specific instances noted regarding eligibility issues, the UNLV Office of Sponsored Programs r...

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: While there were no specific instances noted regarding eligibility issues, the UNLV Office of Sponsored Programs recognizes the importance of documentation through the COSO internal control framework and will ensure the controls are continued, effective immediately. UNLV OSP will continue to enhance the documentation for the administrative management of programs to review and determine eligibility of participants per the requirements of the project, and those employees will be reminded of the importance of evidencing their reviews. • How compliance and performance will be measured and documented for future audit, management and performance review: Verification of eligibility will continue to be performed as required, with enhanced documentation. If escalation is needed, the employee will seek guidance from a supervisor and properly document. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: UNLV Office of Sponsored Programs Executive Director will be responsible for communicating the importance of enhanced documentation to the designated employees responsible for eligibility. UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Staff, independent of the preparer, will review and log each eligibility determination. • How compliance and performance will be measured and documented for future audit, management and performance review: A log will be maintained listing the review date and reviewer name for each determination. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Program Director, who is a Head Start Program Principal Investigator (PI), is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 511719 (2024-015)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

WNC – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Western Nevada College will require that all grant invoices, effective with the October 2024 billing cycle, require...

WNC – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Western Nevada College will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation (such as email approval, Workday approval or hard copy signature) will be compiled for each grant invoice to provide evidence that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 510795 (2024-007)

Significant Deficiency 2024

Nevada System of Higher Education

NV

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

DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With th...

DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered, including the proper application of the indirect cost rate as outlined in the grant agreement. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. WNC – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Western Nevada College will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 509796 (2024-002)

Material Weakness 2024

Detroit Public Schools Community District

MI

Allowable Costs / Cost Principles § 200.300 § 200.403

Condition: The School District's controls did not prevent or detect and correct, in a timely manner, costs charged to the grant that were more than the related invoices. Planned Corrective Action: The Grant Accounting team will develop a standard operating procedure on review and approval of journal...

Condition: The School District's controls did not prevent or detect and correct, in a timely manner, costs charged to the grant that were more than the related invoices. Planned Corrective Action: The Grant Accounting team will develop a standard operating procedure on review and approval of journal entries. The Grant Account Team will provide training to Grant Compliance staff members on the defined process. Grant Compliance Senior Director and Assistant Director will be responsible for ensuring journal requests are submitted following the outlined operating procedure. Grant Accounting staff members will review submitted materials to ensure no invoice is overcharged and then process journal request. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: 3/1/2025

View Audit 329556

Finding 509702 (2024-006)

Material Weakness 2024

Madison-Carver Academy

MI

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. ...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

View Audit 329351

Finding 509690 (2024-006)

Material Weakness 2024

Cornerstone Jefferson-Douglass Academy

MI

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303

Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for ...

Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson

View Audit 329348

Finding 508330 (2024-004)

Significant Deficiency 2024

Northeast (webutuck) Central School District

NY

Allowable Costs / Cost Principles HUD Housing Programs Questioned Costs

Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages o...

Condition: The District did not comply with the required standards of Support of Salaries and Wages, because employees who time was charged to federal grants during fiscal year PAR, were completed for May and June before the time had occurred. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certification or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee’s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy that specific requirement of this and other appendices under 2 CFR Part 225, and that the total compensation for the individual employees: (3) is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3)). Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly or semi-annual certifications and that the time allocation on the grant is reported accurately. Corrective Action: A comprehensive tracking plan has been implemented to ensure the costs objectives associated with each employee for each period is tracked and PAR is returned for the corresponding period. Corrective Action Implemented by: The Corrective Action will be implemented by Robert Farrier, School Business Administrator in conjunction with Treasurer Kelly Kilmer. Corrective Action Implementation Date: This corrective action plan has already been implemented on 9/15/24.

View Audit 328890

Corrective Action Plans

Filters