Corrective Action Plans

Finding 370986 (2023-001)

Significant Deficiency 2023

IL

Allowable Costs / Cost Principles

Action taken in response to finding: The Organization will continue to monitor its systems and personnel records to ensure that payroll and fringe benefits fully comply with federal cost principles. The Organization has approximately 312 employees and approximately 20 different grants that require a...

Action taken in response to finding: The Organization will continue to monitor its systems and personnel records to ensure that payroll and fringe benefits fully comply with federal cost principles. The Organization has approximately 312 employees and approximately 20 different grants that require allocation updates any time there is a change on a PAN form. There are procedures in place for monitoring that the information in the PAN forms and vouchering system agree. Due to the volume of payroll related transactions, management will increase the number of payroll items that are tested on a quarterly basis. Name of the contact person responsible for corrective action: Carmen Ziegler, CFO Planned completion date for corrective action plan: March 31, 2024

View Audit 292608

Finding 370866 (2023-001)

Significant Deficiency 2023

Overlake Hospital Medical Center

WA

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

ALN No. 93.498, Provider Relief Fund; Award Year: Period 5: January 1, 2022 to June 30, 2022 Finding: Activities Allowed or Unallowed – The controls were not sufficient to ensure that depreciation expense for capital purchases were excluded when the capital expense was also submitted for program re...

ALN No. 93.498, Provider Relief Fund; Award Year: Period 5: January 1, 2022 to June 30, 2022 Finding: Activities Allowed or Unallowed – The controls were not sufficient to ensure that depreciation expense for capital purchases were excluded when the capital expense was also submitted for program reimbursement. Status: Corrective action in progress. Corrective Action: Internal controls will be strengthened in future periods to ensure that ledger details are appropriately filtered to exclude depreciation expense for costs already considered during the review of capital expenditures. The Director of Finance will review ledger details prior to submission to ensure only appropriate ledger accounts are included in requests for reimbursement. Person(s) Responsible for Implementing: Jia Paulucci, Director of Finance and Lindsey Soboloski, Controller Implementation Date: February 12, 2024

View Audit 292538

Finding 370849 (2023-002)

Significant Deficiency 2023

Miller Creek School District

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

We have reviewed the draft of our audit report and want to provide a formal answer to the audit finding #2023-002 related to Federal Compliance: Allowable costs/cos Principles - Time and Effort Reporting. In 2023-24 we are reinstating a process we had in place by which every employee partially paid ...

We have reviewed the draft of our audit report and want to provide a formal answer to the audit finding #2023-002 related to Federal Compliance: Allowable costs/cos Principles - Time and Effort Reporting. In 2023-24 we are reinstating a process we had in place by which every employee partially paid by a Federal Source was assigned a duty statement. The statement will describe: • Program Service • Program Code (Funding Source) • Description of Monthly or Yearly Activities • Hours Funded Each month the employee will fill out a timesheet logging their time based on the activities described in the duty statement. Time certifications will be reviewed monthly by the CBO and kept in a binder. If you have any questions about this response, please contact me directly.

View Audit 292507

Finding 370702 (2023-001)

Material Weakness 2023

Lamprey Health Care, Inc. and Friends of Lamprey Health Care, Inc.

NH

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: 2023-001 Condition: In a sample of three of nine cash draw downs from PMS, each of the three transactions tested were drawn in a proportion in excess of the Federal Percentage Share as required by the terms and conditions of the award. Individual(s) Responsible for Corrective Action: Eli...

Finding: 2023-001 Condition: In a sample of three of nine cash draw downs from PMS, each of the three transactions tested were drawn in a proportion in excess of the Federal Percentage Share as required by the terms and conditions of the award. Individual(s) Responsible for Corrective Action: Elidoro Primero, CFO Planned Corrective Action: Management will provide additional training to individuals for monitoring grant compliance, reinforcing the importance of grant provisions and implementing a system of processes and controls for tracking compliance with all specific grant terms and conditions. Management will also solicit guidance/best practice from designated HRSA grant management officer for voluntary correction action steps to resolve finding. Anticipated Completion Date: June 30, 2024

View Audit 292390

Finding 370652 (2023-001)

Significant Deficiency 2023

Loyalsock Township School District

PA

Allowable Costs / Cost Principles Cash Management § 200.431

The Staff Accountant, Kyle Winton, will ensure that the PSERS reimbursements are properly deducted from federal grant allocations by reconciling with the quarterly Act 29 Reimbursement report that identifies federally funded staff through the CSIU payroll module. The appropriate aide ratio from the ...

The Staff Accountant, Kyle Winton, will ensure that the PSERS reimbursements are properly deducted from federal grant allocations by reconciling with the quarterly Act 29 Reimbursement report that identifies federally funded staff through the CSIU payroll module. The appropriate aide ratio from the Act 29 Employer Salary Report will be used to calculate the correct retirement amount based on the employees’ work history.

View Audit 292373

Finding 370633 (2023-002)

Significant Deficiency 2023

Tippecanoe Valley School Corporation

IN

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

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Correcti...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024

View Audit 292331

Finding 370541 (2023-002)

Significant Deficiency 2023

Octorara Area School District

PA

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

Federal Program COVID-19 - Education Stabilization Fund ALN 84.425; passed through the Pennsylvania Department of Education Condition/Cause We tested a sample of 8 nonpayroll invoices charged to the Education Stabilization Fund. For 1 out of the 8 invoices tested, the invoice was miscoded to the g...

Federal Program COVID-19 - Education Stabilization Fund ALN 84.425; passed through the Pennsylvania Department of Education Condition/Cause We tested a sample of 8 nonpayroll invoices charged to the Education Stabilization Fund. For 1 out of the 8 invoices tested, the invoice was miscoded to the grant and should have been charged to a different program. Controls at the District did not catch this miscoding prior to the audit. The Board of Directors approves all salaried positions that are funded by the Education Stabilization Fund. For one of the individuals charged to the program, the Board did not approve their position as a grant funded position. Instead, a different individual was approved but not charged to the grant. Controls at the District did not catch this miscoding prior to the audit; however, the individual charged to the grant was in a position that was allowable under the grant requirements. Recommendation We recommend the District review their internal controls over allowable activities and allowable costs charged to the Education Stabilization Fund to ensure they are designed and operating to detect coding errors that may result in noncompliance with grant requirements. Management Response Objective Address the identified issues related to the misallocation of costs and lapses in internal controls within the Education Stabilization Fund program. 1. Immediate Actions • Correct the miscoded invoice immediately, ensuring that the $2,613 erroneously charged to the Education Stabilization Fund is properly allocated to the correct program. • Conduct a thorough review of all nonpayroll invoices charged to the Education Stabilization Fund to identify and rectify any other miscoding errors. 2. Internal Controls Enhancement • Review and strengthen internal controls over allowable activities and costs within the Education Stabilization Fund program. • Implement a systematic process for verifying the appropriateness of each cost before it is charged to the grant, including a cross-check against grant agreements and Board approvals. 3. Board Approval Process • Establish a clear and documented process for obtaining Board approval for salaried positions funded by the Education Stabilization Fund. • Ensure that all individuals charged to the program have received explicit approval from the Board, and that the approval is well-documented. 4. Training and Awareness • Provide training to relevant staff involved in coding and approving expenses related to the Education Stabilization Fund. • Enhance awareness among employees about the importance of accurately coding expenses and obtaining proper approvals. 5. Review of All Salaried Positions • Conduct a comprehensive review of all salaried positions funded by the Education Stabilization Fund, ensuring that each position aligns with Board approvals and grant requirements. • Verify that individuals charged to the program have the necessary approvals and qualifications. 6. Documentation and Record-Keeping • Establish a centralized and well-maintained repository for all documentation related to Education Stabilization Fund expenditures. • Ensure that records of Board approvals, coding decisions, and supporting documentation for all expenses are readily accessible for audit purposes. 7. Periodic Internal Audits • Implement a schedule for periodic internal audits specifically focused on the Education Stabilization Fund program. • Conduct random checks and audits to verify the accuracy of coding and compliance with internal controls. 8. Reporting and Transparency • Develop a reporting mechanism to keep the Board of Directors and relevant stakeholders informed of expenditures under the Education Stabilization Fund. • Periodically report on the status of internal controls and any corrective actions taken. 9. Continuous Monitoring: • Establish a continuous monitoring process to detect and address any deviations from established internal controls promptly. • Implement real-time alerts or notifications for potential coding errors or deviations from approved positions. 10. External Review • Consider engaging external auditors to perform an independent review of the strengthened internal controls and corrective actions taken. • Seek recommendations for further improvements and best practices. By implementing these corrective actions, we aim to enhance internal controls, ensure compliance with grant requirements, and prevent the misallocation of funds within the Education Stabilization Fund program. Regular monitoring and a commitment to continuous improvement will be critical for sustained success.

View Audit 292221 Questioned Costs: $1

Finding 370527 (2023-001)

Significant Deficiency 2023

Colton Joint Unified School District

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the...

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the rationale behind charging a substitute to Title I. Additionally, backup documentation will be collected to bolster the support for the allowability of these activities. This proactive plan aims to maintain continuous compliance with Title I guidelines.

View Audit 292192 Questioned Costs: $1

Finding 370506 (2023-002)

Material Weakness 2023

Metropolitan School District of Decatur Township

IN

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

FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related t...

FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation completed reimbursement requests and submitted them online; however, there was no evidence of an oversight or review process to ensure that the reimbursement requests were for allowable activities, allowable costs, and within the period of performance. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures to ensure disbursement requests are printed out and a representative from the Business Department documents review of them for allowable activity before final submission. Anticipated Completion Date: March 1, 2024

View Audit 292091

Finding 370485 (2023-001)

None 2023

Moses H Cone Memorial Hospital Operating Corporation, Inc.

NC

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

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

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

View Audit 292044 Questioned Costs: $1

Finding 370465 (2023-004)

Significant Deficiency 2023

East Porter County School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

Finding 2023-004 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & H...

Finding 2023-004 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & HR will work with the Special Education Coop to ensure compliance with the Earmarking requirement. Anticipated Completion Date: February 2024

View Audit 292036

Finding 370427 (2023-001)

None 2023

Southwest District Health

ID

Allowable Costs / Cost Principles Cash Management

The District discovered fraud during the fiscal year shortly after the incidents had occurred. An individual working for the District recorded making home visits to patients in the Nurse Family Partnership (NFP) program when in fact, the visits were not made nor hade the employee tried to cancel or...

The District discovered fraud during the fiscal year shortly after the incidents had occurred. An individual working for the District recorded making home visits to patients in the Nurse Family Partnership (NFP) program when in fact, the visits were not made nor hade the employee tried to cancel or reschedule the visits with the patients. The incidents of fraud were discovered by the employee's supervisor during a review and follow up with patients assigned to the employee. The issue was immediately reported to the State and billing to the program ceased while an investigation was completed. The State reported the incident to their federal partners and the District has complied in a quick and timely manner with all requests from the State and federal partner. The incidents were also reported to Medicaid because some unverified visits had been billed to Medicaid, and Medicaid was fully reimbursed for all unverified visits. Additionally, the District has put in place additional layers of controls which are above normal industry standards to prevent this type of activity from occurring in the future.

View Audit 291996

Finding 370421 (2023-001)

Significant Deficiency 2023

Pacific University

OR

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring § 200.303 § 200.403

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The ap...

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The approval requirement will also be added to Pacific’s mandatory annual compliance training for supervisors.

View Audit 291993

Finding 370413 (2023-003)

Significant Deficiency 2023

Central Virginia Partnership for Economic Development

VA

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

Cost Allocations: The Organization concurs with the finding. The employee responsible for the change did not seek proper approval. The Organization will communicate the circumstances to the recipient of the federal awards so they may update their procedures as necessary.

View Audit 291991

Finding 370412 (2023-002)

Significant Deficiency 2023

Central Virginia Partnership for Economic Development

VA

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

Segregation of Duties: The Organization concurs with the findings. The Organization has determined it is staffed appropriately given the resources available and will continue to look for new opportunities to address these findings.

View Audit 291991

Finding 370365 (2023-010)

Material Weakness 2023

City of Detroit, Michigan

MI

Allowable Costs / Cost Principles Reporting Cash Management § 200.303 § 200.403

Finding Number: 2023‐010 Federal Program, Assistance Listing Number and Name: 14.218, Department of Housing and Urban Development, Community Development Block Grant/Entitlement Grants Cluster, Community Development Block Grant/Entitlement Grants (CDBG) 14.241, Department of Housing and Urban Develop...

Finding Number: 2023‐010 Federal Program, Assistance Listing Number and Name: 14.218, Department of Housing and Urban Development, Community Development Block Grant/Entitlement Grants Cluster, Community Development Block Grant/Entitlement Grants (CDBG) 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) 14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead) Condition: Original Finding Description: The City duplicated costs charged to certain grants. Contact Person Responsible for Corrective Action: Regina Greear (ODFS) and Cynthia Saxton (OGA) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional training that includes a review of its journal entry controls and approval processes to ensure journal entries are posted accurately and no duplicates costs.

View Audit 291959

Finding 370321 (2023-003)

Significant Deficiency 2023

Natrona County, Wyoming

WY

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

2023-003 Cash Management Program Health Care for the Homeless Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal...

2023-003 Cash Management Program Health Care for the Homeless Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. o All fiscal transactions are entered into Sage, and all backup is uploaded at the time of requested transaction. o This is then sent to the Approver, who then reviews for reasonable, allocable and allowable costs. o Payment requests cannot be submitted and forwarded electronically if the backup is not uploaded and the requestor electronically initials that they did so. Approvers are assigned in work flows and transactions are reviewed by Supervisor, Fiscal Department personal o Reimbursement requests are reviewed at program level, compliance officer level and fiscal and presented to Executive Director to review with backup before submitted for reimbursement. Sage houses all backup receipts etc. o All journal entries have time stamps in software and identify who/when the entry occurred and a field is provided to explain the “why”, with reference(s). • Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight. • Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes: o Internal controls o Allowable compensation and employee benefits o Cost allocation methods o Governing body financial responsibilities o Budgeting o Financial reporting o Financial management systems o Documentation and record retention o Financial policies and procedures o Allowable costs • All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations. Proposed Completion Date June 30, 2024

View Audit 291948

Finding 370320 (2023-002)

Material Weakness 2023

Natrona County, Wyoming

WY

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

2023-002 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Community Services Block Grant Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan As of July 1, 2023 the following behaviors and standards were implemented: • CAPNC moved from an archa...

2023-002 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Community Services Block Grant Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan As of July 1, 2023 the following behaviors and standards were implemented: • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight. • Payroll services were outsourced to ADP payroll services in order to provide real time features and accountability for time. This allows recording of time more accurate, reliable and allocable. Payroll records are reviewed and time studies are being performed for all staff to ensure allocation methodology, once selected is appropriate, consistent and in alignment with staff performance. o Time entry occurs electronically in real time; hourly employees are assigned a schedule, and salaried staff are monitored o Time cards are electronically submitted and approved electronically to ensure time is recorded as it occurs. o Time off records are also submitted for approval electronically and leave is approved based on County personnel guidance. • Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes: o Internal controls o Allowable compensation and employee benefits o Cost allocation methods o Governing body financial responsibilities o Budgeting o Financial reporting o Financial management systems o Documentation and record retention o Financial policies and procedures o Allowable costs • All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations. Proposed Completion Date June 30, 2024

View Audit 291948 Questioned Costs: $1

Finding 370319 (2023-001)

Material Weakness 2023

Natrona County, Wyoming

WY

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

2023-001 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Emergency Rental Assistance Program Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provide...

2023-001 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Emergency Rental Assistance Program Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight. • Payroll services were outsourced to ADP payroll services in order to provide real time features and accountability for time. This allows recording of time more accurate, reliable and allocable. Payroll records are reviewed and time studies are being performed for all staff to ensure allocation methodology, once selected is appropriate, consistent and in alignment with staff performance. o Time entry occurs electronically in real time; hourly employees are assigned a schedule, and salaried staff are monitored o Time cards are electronically submitted and approved electronically to ensure time is recorded as it occurs. o Time off records are also submitted for approval electronically and leave is approved based on County personnel guidance. • Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes: o Internal controls o Allowable compensation and employee benefits o Cost allocation methods o Governing body financial responsibilities o Budgeting o Financial reporting o Financial management systems o Documentation and record retention o Financial policies and procedures o Allowable costs • All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations. Proposed Completion Date June 30, 2024

View Audit 291948 Questioned Costs: $1

Finding 370251 (2023-003)

Significant Deficiency 2023

Association House of Chicago

IL

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person respons...

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370242 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Richmond

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.514

2023-001 ALN 14.850 Public and Indian Housing – Allowable Costs/Cost Principles Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority requires all checks to be signed by the Executive Director as pr...

2023-001 ALN 14.850 Public and Indian Housing – Allowable Costs/Cost Principles Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority requires all checks to be signed by the Executive Director as primary signer or Financial Operations manager / Director of Finance as secondary signer as well as chairman of Board in emergency role if primary or secondary is unavailable, all of whom are approved as a bank signatory. All checks under $10,000 require one signature from primary check signer (Executive Director / President-CEO) and All non-recurring monthly expenses over $10,000 require two signatures for approval consisting of any combination Executive Director as primary signer or Financial Operations manager / Director of Finance as secondary signer, or as chairman of Board in emergency role if primary or secondary is unavailable. Person Responsible for Correction of Finding: Mr. Keon Jackson, Executive Director Projected Completion Date: June 30, 2024

View Audit 291840

Finding 370198 (2023-001)

Significant Deficiency 2023

Multicultural Learning Center

CA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.514

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported ful...

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported full allocations per fund, in error during 2023 by the Center’s back-office service providers without review from Center’s management. Upon the Center’s communication with the CDE, the CDE has notified that “according to the U.S. Department of Education for ESSER Annual Reporting, there will be an opportunity to correct the Year 3 report that was submitted in March of 2023. The U.S. Department of Education requires that we submit Year 4 data to them first. This data will be collected in March of 2024. At that time, the LEA should report to the best of their ability, based on the previously reported expenditures. Depending on the previous amount reported, this may mean the LEA is not yet able to fully report applicable expenditures. This will be corrected later. Following the initial Year 4 submission, the U.S. Department of Education will allow for a Year 3 correction period. At this time, the LEA will be able to correct the Year 3 report. Finally, there will be a Year 4 correction period. This correction period will be based on any changes reported during the Year 3 correction period, to allow for a final true up of Year 4 reporting based on actual expenditures.” Therefore, the correction will be made in March of 2024. In the future, the Center’s back-office service providers will be utilizing a stricter rule for cross-checking reports, and will send reports (quarterly and annual) to the Center for a third review before submitting. The Center will also make the correction in March of 2024 per the CDE’s and U.S. Department of Education direction.

View Audit 291776

Finding 370195 (2023-005)

Significant Deficiency 2023

Phoenix Elementary School District No. 1

AZ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

The District will review its internal control procedures over federal programs to ensure purchase orders and maintained to support the authorization of purchases before the goods or services are purchased.

View Audit 291755

Finding 370186 (2023-006)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

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

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lo...

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lost revenue was based on average credit hours per semester prior to COVID-19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID-19 resulting in an understated amount of lost revenue from the intended methodology. Responsible Individuals: Tami Lansing, Controller Corrective Action Plan: The calculation underwent a review, yet the error eluded detection during the review. In any future COVID-19 lost revenue calculations, we will exercise more detailed scrutiny. The University was constrained by a predetermined threshold for lost revenue, and we had already surpassed that limit. The miscalculation, had it not been overlooked, would have only inflated that amount. It is important to note that the University intentionally approached lost revenue calculations with a conservative basis. Anticipated Completion Date: August 10, 2023

View Audit 291731

Finding 370133 (2023-001)

Significant Deficiency 2023

West Babylon Union Free School District

NY

Allowable Costs / Cost Principles Cash Management Significant Deficiency § 200.430

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) A...

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing No. 84.425U Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries, wages and other forms of compensation must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs), timesheets, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District inadvertently charged resource officers payroll costs to a federal grant, however, it was determined that these payroll costs were not budgeted in the federal grant and should not have been charged to the federal grant. Planned Corrective Action: The District implemented a new summer program utilizing federal grant funds approved by the NYSED. The District charged resource officers payroll costs that occurred during the scheduled approved summer program, however it was determined that these payroll costs were not budgeted in the federal grant, per the FS-10. Since the grant funding period of this grant is still open, the District contacted NYSED to determine the necessary course of action to rectify this matter. It was determined that the District will prepare and submit an FS-10A amending the original FS-10, to include the resource officer’s payroll costs in the grant as it relates to the approved summer program. In addition, the District will review its internal review procedures to ensure that payroll costs charged to federal grants are supported by the proper documentation for each employee and are allowable per the approved budget of the federal grant. The FS-10A will be prepared and filed prior to the June 30, 2024 by the Assistant Superintendent for Curriculum. Responsible Contact Person: Denise Gillis Assistant Superintendent for Finance & Operations West Babylon Union Free School District 200 Old Farmingdale Road West Babylon, NY 11704 Anticipated Completion Date: June 30, 2024

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