Corrective Action Plans

Finding 398994 (2023-001)

Material Weakness 2023

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Going forward we will ensure federally funded items are designated as such and are tracked separately. The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider r...

Going forward we will ensure federally funded items are designated as such and are tracked separately. The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy “unmet” need in would have been hard to meet even if the District hadn’t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC.

View Audit 307598 Questioned Costs: $1

Finding 398975 (2023-001)

Material Weakness 2023

Edmonds School District No. 15

WA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management

As communicated in the District’s response to the prior audit finding, the District does not concur with the SAO’s interpretation of unmet need in the 2021-2022 audit nor does it concur with the same finding for the audit of the 2022-2023 fiscal year. We believe all Chromebook purchases were allowab...

As communicated in the District’s response to the prior audit finding, the District does not concur with the SAO’s interpretation of unmet need in the 2021-2022 audit nor does it concur with the same finding for the audit of the 2022-2023 fiscal year. We believe all Chromebook purchases were allowable and devices were only provided to those with an unmet need. We concur with SAO that we did not retain adequate documentation indicating which staff and students received hotspots and appreciate that SAO noted that there was an urgent need to distribute hotspot internet services to students in order that they could participate in remote learning, and that this urgency and extenuating circumstances resulted in this situation. We recognize there was an error associated with vendor credits in the amount of $2,751.10 but did not claim reimbursement for the other credits totaling $8,898.90 as indicated in the audit finding. We will work to improve our process regarding credits on future invoices. The District will continue to work with the FCC to resolve this finding.

View Audit 307577 Questioned Costs: $1

Finding 398920 (2023-002)

Significant Deficiency 2023

Public Counsel

CA

Allowable Costs / Cost Principles Subrecipient Monitoring

Date: May 28, 2024 Cognizant or Oversight Agency: U.S. Department of the Treasury Public Counsel respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Armani...

Date: May 28, 2024 Cognizant or Oversight Agency: U.S. Department of the Treasury Public Counsel respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Armanino, LLP 11766 Wilshire Blvd. 9ᵗʰ Floor Los Angeles, CA 90025 Audit period: August 31, 2023 The finding from the August 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2023-002 The Uniform Guidance Cost principles require consistency in treatment of costs and, specifically, that compensation costs be consistent. In addition, the Uniform Guidance requires that there be a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and conform to the established accounting policies and practices of the Organization. Recommendation: Management should ensure that new processes reflect all compliance requirements, including the ability to produce evidence of the execution of relevant controls. Action Taken: We agree with the auditors' recommendations, and we have and will be taking the following actions within the current fiscal year: We have updated the payroll allocation methodology to ensure that we are making allocations for employees on a fully pro rata basis and that there is a validation process to ensure that 100% of an employee's time is appropriately allocated across Federal and non-Federal funding sources. The supporting documentation is saved in our shared network folders and attached to the journal entries within our financial system. For any future process or system changes, we will ensure that we have thoroughly assessed the impact of any change before we implement it and vet it in through our internal grant compliance team. We have already made changes to involve our Legal Data Manager to implement a reporting process to ensure that we have complete timeslips that reflect both employee and supervisor approvals for every pay period. We will maintain this approach in Legal Server, the Organization's case management and timekeeping system, and will attach these timeslips as support for each of our allocation entries. We will continue to assess our procedures and internal controls relevant to our Federal funding to ensure compliance with the requirements of Uniform Guidance. We will do a thorough review of our internal control system and update it as necessary to align with best practices as recipients of Federal funding. The Finance team will actively seek training related to Uniform Guidance and other Federal rules and requirements. We will share and discuss this information across departments to maintain organization-wide compliance. Name of responsible person: Steven Godoy VP, Finance & CFO Anticipated completion date: August 31, 2024 If the U.S. Department of Treasury has questions regarding this plan, please call Steven Godoy, VP, Finance & CFO at (213) 393-1055. Sincerely yours, Steven Godoy VP, Finance & CFO

View Audit 307522

Finding 398756 (2023-001)

Material Weakness 2023

Lyle School District No. 406

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lyle School District No. 406 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Feder...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lyle School District No. 406 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Susan Carabin, Business Manager PO Box 368 Lyle, WA 98635 (509) 365-2191 Corrective action the auditee plans to take in response to the finding: Since learning of the requirement regarding payroll reports, the District immediately asked our contractor to build a shared file that contains the certified weekly payroll reports. We now download and document the reports once per week. Anticipated date to complete the corrective action: 3/28/2024

View Audit 307516

Finding 398726 (2023-003)

None 2023

City of Lowell

MA

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

Views of Responsibte Officials and Planned Corrective Actions: The School District will immediately begin collecting the time and effort documentation for the impacted grants for the current fiscal year (FY24) and into future periods as required. lf the Oversight Agency has questions regarding this ...

Views of Responsibte Officials and Planned Corrective Actions: The School District will immediately begin collecting the time and effort documentation for the impacted grants for the current fiscal year (FY24) and into future periods as required. lf the Oversight Agency has questions regarding this plan, please call Amanda Dupont, lnternal Auditor, at 978-674-2102

View Audit 307488

Finding 398686 (2023-001)

Material Weakness 2023

Montesano School District No. 66

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Montesano School District No. 66 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of F...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Montesano School District No. 66 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Sheila Baker, 502 E Spruce Avenue, Montesano, WA 98563, (360)249-3942 Corrective action the auditee plans to take in response to the finding: The district has recently participated in a training provided by the Department of Labor & Industries regarding prevailing wage requirements. In the coming months, the Superintendent and Business Manager will be creating a checklist for district use when we hire contractors to perform work for our district as well as a standard contract with language relating to prevailing wage requirements and source of funding. Under normal operations we do not hire contractors using federal funds and our ESSER funds have now been totally expended. Anticipated date to complete the corrective action: May 2024

View Audit 307436

Finding 398635 (2023-001)

Material Weakness 2023

Soap Lake School District No. 156

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding caption: The District did not have adequate controls for ensuring compliance with federal wage rate requirements. ...

Finding caption: The District did not have adequate controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Nikkie Maceda, External Business Manager, P.O. Box 1389, Soap Lake, WA 98851 (509) 223- 6941 Corrective action the auditee plans to take in response to the finding: For future federal prevailing wage projects, the district will review and update contracts to include language regarding Davis Bacon wages and contractor’s responsibility to file weekly certified payroll. The district will verify the filing of weekly certified payroll reports. Anticipated date to complete the corrective action: May 2024

View Audit 307408

Finding 398628 (2023-002)

Material Weakness 2023

Rochester Math and Science Academy

MN

Allowable Costs / Cost Principles § 200.303 § 200.403

Education Stabilization Fund – Assistance Listing No. 84.425 Recommendation: CLA recommends the School ensures it documents the underlying support for how allowable payroll expenditures were charged to the program along with approval of that determination. Explanation of disagreement with audit fi...

Education Stabilization Fund – Assistance Listing No. 84.425 Recommendation: CLA recommends the School ensures it documents the underlying support for how allowable payroll expenditures were charged to the program along with approval of that determination. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The School will ensure as they allocate wages to federal programs going forward they will specifically identify the underlying disbursements and document their approval of that allocation. Name of the contact person responsible for corrective action: Abdi Shekh Planned completion date for corrective action plan: June 30, 2024.

View Audit 307398

Finding 398607 (2023-003)

None 2023

Underwriters Laboratories Inc.

IL

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding Number: 2023-003 – Procurement/Full and open competition Anticipated Completion Date: April 2024 Responsible Contact Person: Jocelyn Lombardozzi Planned Corrective Action: In response to this finding, an analysis of 2023 labor charged to awards was conducted. The results of the analysis ...

Finding Number: 2023-003 – Procurement/Full and open competition Anticipated Completion Date: April 2024 Responsible Contact Person: Jocelyn Lombardozzi Planned Corrective Action: In response to this finding, an analysis of 2023 labor charged to awards was conducted. The results of the analysis revealed that a net amount of $35,238 more could have been charged to the awards which the Company will not pursue charging to the awards. An analysis of labor charged to awards active in the first quarter of 2024 has also been performed to ensure that active awards are being charged according to employee’s actual pay. As of April 1, 2024, the Company has transitioned to a new accounting system. This system is configured to require employees working on sponsored projects to utilize percentage of effort and effort certification functionality for tracking actual time and actual labor costs to awards. Budgeted labor rates are no longer being used as of April 1, 2024.

View Audit 307361 Questioned Costs: $1

Finding 398597 (2023-001)

Material Weakness 2023

Okanogan School District No. 105

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Okanogan School District No. 105 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal R...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Okanogan School District No. 105 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Klancy Allen, Director of Finance P.O. Box 592 Okanogan, WA 98840 (509) 422-3629 Corrective action the auditee plans to take in response to the finding: The District will implement internal control procedures around the monitoring of third party contract managers in order to facilitate adequate internal controls for ensuring compliance with the federal wage rate requirements in any contracts for future federally funded projects. Anticipated date to complete the corrective action: May 2024

View Audit 307342

Finding 398583 (2023-001)

Material Weakness 2023

Everett School District No. 2

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The district does not concur with the audit finding or the $3.5 million of questioned costs. According to FCC bulletin/order #6.16 states “the applicant is not required to perform a new unmet need survey at the time of submitting the request for reimbursement if the applicant already performed a sur...

The district does not concur with the audit finding or the $3.5 million of questioned costs. According to FCC bulletin/order #6.16 states “the applicant is not required to perform a new unmet need survey at the time of submitting the request for reimbursement if the applicant already performed a survey at the time of submitting the application.” The district believes the unmet need requirements have been met as outlined: Determining Need: • The district determined its need based on its inventory of devices supporting remote learning and did not have enough RAM to have district and learning platforms operating at the same time. • Students and staff need a District device for safety, installed software for instruction, technical support and equity as explained in above reasoning and attached mobile access for student laptop handbook. • The district conducted a survey that determined that over 6,500 students required devices. Between the survey and the lack of RAM, the district determined that over 12,000 devices were needed to support learning. In addition, the district has no intention of applying for other Emergency Connectivity Funds.

View Audit 307321 Questioned Costs: $1

Finding 398580 (2023-001)

Material Weakness 2023

Sunnyside School District No. 201

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district progr...

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district program director should receive weekly certified payroll reports to ensure compliance. On the next project that requires Prevailing Wage Rates, the District will make sure to receive weekly certified payroll reports to ensure compliance.

View Audit 307312

Finding 398566 (2023-001)

Material Weakness 2023

St. Clairsville - Richland City School District

OH

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

INVOICES: A copy of all invoices will be kept in the cafeteria. An employee of the District will review the invoices for allowable costs

View Audit 307295

Finding 398515 (2023-001)

Significant Deficiency 2023

City of Haverhill

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 10...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

View Audit 307261

Finding 398514 (2023-001)

Material Weakness 2023

Seattle School District No. 1

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attenti...

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attention until 10 months into the 22/23 audit period, leaving no time for discussion or changes in interpretation and process. The audit’s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that our internal controls were ineffective for demonstrating per location and per user limitations. Based on guidance from the Federal Communications Commission (excerpted below), the District contends we have spent all funds for allowable costs, that those costs were reasonable and necessary, and for students and staff with unmet needs. Districts were able to determine whether students and staff had unmet needs. For our district this meant addressing instances where students may have shared a home device with other siblings; student or staff devices were too old or slow to function properly when running multiple required applications; and / or student owned devices did not have the appropriate security in place to protect students during remote learning (especially from unauthorized websites). Home drives, where all educational digital resources were stored, couldn’t be accessed unless using a district issued device. Additionally, the district’s technical support could not access personally owned devices to provide for thousands of trouble tickets and support issues students faced during remote learning. Based on these factors, unmet need was defined broadly, but within allowed parameters and inventory records were kept, albeit, not perfectly. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by the health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. Seattle Public Schools followed guidance from the Federal Communications Commission outlined in a document titled: . “Emergency Connectivity Fund Common Misconceptions”, “Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus is eligible for Emergency Connectivity Fund Support.” Additionally, from the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: “We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.” And from question 51: “…we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students…with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.” Finally, SAO did not apply any reasonable measure to reduce questioned costs but did state they know that at least some of the equipment addressed unmet needs, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance. There are no corrective actions to take at this time as the funding source has been exhausted and the timeline has passed.

View Audit 307259 Questioned Costs: $1

Finding 398503 (2023-009)

Significant Deficiency 2023

Penasco Independent School District

NM

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

Recommendation We recommend that the District follow the guidance in NM PED’s PSAB Supplement 13, Purchasing. Management Response Corrective Action: We will work with the District staff to plan and obtain purchase orders before receiving items and/or placing orders. Due Date of Completion: June...

Recommendation We recommend that the District follow the guidance in NM PED’s PSAB Supplement 13, Purchasing. Management Response Corrective Action: We will work with the District staff to plan and obtain purchase orders before receiving items and/or placing orders. Due Date of Completion: June 30, 2024 Responsible Party(ies): Business Manager

View Audit 307246

Finding 398496 (2023-001)

Material Weakness 2023

Pomona Valley Hospital Medical Center

CA

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Period of Performance

Finding 2023-001 – Internal Control Deficiency Over Activities Allowed or Unallowed and Activities Allowed/Allowable Costs Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentia...

Finding 2023-001 – Internal Control Deficiency Over Activities Allowed or Unallowed and Activities Allowed/Allowable Costs Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Award Period of Performance: January 20, 2020 – May 11, 2023 Finding: Management did not consistently retain documentation evidencing the performance of controls to ensure allowable COVID-19 expenses were charged to the program. Corrective Action Plan: All of these deficiencies were related to the selections being more than 36 months old, which is past the current documentation retention policy of PVHMC for non-controlled substances and non-patient records. In order to ensure that documentation is retained for future audits, all FEMA related documentation that is still retained will be kept indefinitely to ensure compliance in future years. Person Responsible: Juli Hester, Chief Financial Officer Estimated Completion Date: May 31, 2024

View Audit 307226

Finding 398480 (2023-003)

Significant Deficiency 2023

Anchorage Community Mental Health Services, Inc.

AK

Allowable Costs / Cost Principles Significant Deficiency § 200.403

Finding 2023-003: 2023-003 - Significant Deficiency in Internal Control over Compliance and Noncompliance – Allowable Costs/Cost Principles Contact: Michael Bailey, Chief Financial Officer Corrective Action Plan: The Accounting department at Alaska Behavioral Health has stabilized staffing in accoun...

Finding 2023-003: 2023-003 - Significant Deficiency in Internal Control over Compliance and Noncompliance – Allowable Costs/Cost Principles Contact: Michael Bailey, Chief Financial Officer Corrective Action Plan: The Accounting department at Alaska Behavioral Health has stabilized staffing in accounting personnel, including the replacement of the Chief Financial Officer. Prior to submission of financial reports, the CFO will review and verify that personnel related expenditures are supported by payroll allocation records, and other direct expenditures have adequate documentation associated with the allowable expenditure. Proposed Completion Date: 06/30/2024

View Audit 307202

Finding 398460 (2023-001)

Material Weakness 2023

Mount Vernon School District No. 320

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services ...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services Supervisor 124 E. Lawrence Street, Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: Concern: The district failed to maintain sufficient documentation proving that the equipment provided to students matched their actual unmet needs. Reimbursement was sought based on estimated unmet needs rather than documented, actual unmet needs. Response: The Mount Vernon School District mandates that students use districtassigned devices for remote learning. According to grant training provided to the district, if students are required to use district-owned devices for remote learning, Chromebooks could be distributed to any student who did not have a district-assigned device that meets hardware standards. The standards used to assess the hardware included Chromebooks that were older than four years, unable to support the necessary software and digital learning tools, and devices at their end-of-life stage, meaning they no longer received automatic updates from Google. We assessed our inventory and supplied new Chromebooks to students based on our understanding of their needs. Chromebooks were only provided to students who lacked a device that met our hardware standards. Resolution: During this audit, the district learned that its understanding was inaccurate. However, we are confident our need exceeded our request. In May 2020, Page 71Office of the Washington State Auditor sao.wa.gov as directed by OSPI, the district conducted a survey which revealed that only 38% of our families had access to a device at home suitable for online learning. Given our students in poverty population was 4,365 during the 2022-23 school year, the 1,869 devices for which funding was requested only partially met our overall device needs. This audit has improved our understanding of the requirements related to verifying unmet needs. Moving forward, we will directly contact families and collect signatures to confirm their needs. These records will be attached to student profiles within our asset management system (Destiny) before ECF funded Chromebooks are assigned to them. Concern: Inventory records were incomplete, missing the names of 273 students assigned laptops funded by the ECF, thus failing to fully meet FCC documentation requirements. Response: The district acknowledges challenges related to student device assignment. Staff reductions and changes in our inventory and check-out processes necessitate updates and training, which is ongoing. We are committed to ensuring accurate and timely updates to our records. Resolution: A list of inventory discrepancies has been distributed, and action is being taken to update our records. To strengthen our existing systems, we will implement additional biannual training sessions with our inventory managers. These trainings will cover best practices for record keeping and emphasize the importance of maintaining accurate inventory records. We will conduct monthly audits of our records, and correction requests will be sent to individual sites to promptly address any information inaccuracies. Concern: MVSD lacked documentation to show that it only provided one device per student or location, leading to possible over-issuance of equipment. Response: While the district acknowledges the need to improve its student assignment inventory within Destiny, we have confirmed that only one device is assigned per student through the use of our additional inventory system (Google Workspace). Resolution: The district will enhance its inventory practices and explore additional redundancies to ensure effective contingencies if future data issues arise. Anticipated date to complete the corrective action: ● Unmet Needs Documentation: May 31, 2024 ● Inventory Update: June 20th, 2024 ● Staff Training: June 20th, 2024 (Ongoing)

View Audit 307176 Questioned Costs: $1

Finding 398453 (2023-001)

Material Weakness 2023

Driscoll Children's Hospital and Subsidiaries

TX

Allowable Costs / Cost Principles

Federal Agencies: U.S. Department of Homeland Security Assistance Listing No.: 97.036 COVID-19 Disaster Grants – Public Assistance Award Period of Performance: March 25, 2020 to July 01, 2022 Corrective Action Planned: Management agrees that evidence of our internal determination that certain expen...

Federal Agencies: U.S. Department of Homeland Security Assistance Listing No.: 97.036 COVID-19 Disaster Grants – Public Assistance Award Period of Performance: March 25, 2020 to July 01, 2022 Corrective Action Planned: Management agrees that evidence of our internal determination that certain expenses incurred for the Medline Spot Buy program was not fully documented. The Medline Spot Buy program was used as a guarantee of delivery of Personal Protection Equipment (PPE) which was in short supply during the initial stages of the Covid pandemic. These purchases were subsequently charged to the FEMA COVID grant, reviewed, and properly reimbursed to Driscoll through that grant by FEMA. Although evidence of review was not retained for the purchases through this program, management believes that adequate review was conducted in the decision to charge these costs to the grant. As it relates to the Medline Spot Buy program, Driscoll Children’s Hospital took part in the program to ensure that the Hospital was adequately stocked with necessary PPE during the COVID pandemic. This program allowed for rapid purchasing and delivery of PPE. Orders were submitted for the program by uploading a spreadsheet to Medline. This ordering process resulted in these purchases bypassing the normal purchase order approval structure. These expenses were correctly charged to the FEMA grant and their appropriateness is not in question. We have reviewed our processes related to the retention of evidence of expense review to improve audit evidence should this program ever be awarded in future periods. We will keep minutes of meetings documenting committee approval for these invoices and/or other documentation that clearly shows our internal review and decision tree. Responsible party: Steve King, CFO Implementation Date: Procedures were reviewed along with the finalization of the FY23 Uniform Guidance audit in May 2024.

View Audit 307140

Finding 398452 (2023-001)

Significant Deficiency 2023

Northeast Texas Public Health District

TX

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

The Northeast Texas Public Health District (NET Health) will take steps to ensure overall effective grant monitoring and to increase communications between NET Health Grant Managers and the Chief Financial Officer and Chief Executive Officer. The NET Health Leadership Team will discuss any issues du...

The Northeast Texas Public Health District (NET Health) will take steps to ensure overall effective grant monitoring and to increase communications between NET Health Grant Managers and the Chief Financial Officer and Chief Executive Officer. The NET Health Leadership Team will discuss any issues during our weekly Leadership Team meetings to ensure compliance. These weekly meetings will address costs expended within the grant parameters and ensure grant funds will be more evenly expended during the year as appropriate. NET Heatlh will continue to develop effective methods of grant oversight as it finds weaknesses in its processes. To ensure compliance with the period of performance requirements, NET Health will change its processes effectively immediately. Going forward checks will only be prepared, dated, signed, and mailed to vendors after work is completed or items are received. There will be enhanced internal controls by establishing procedures to monitor and ensure timely payment of accrued expenditures, such as regularly accounting for any outstanding checks and actively communicating with vendors on performance requirements. In addition, we will enhance communication and coordination among relevant departments to expedite the payment process while maintaining compliance with grant regulations. George T. Roberts, CEO, and Lawanda Owens, CFO, are the persons responsible for this action plan going forward. NET Health is expected to have this action plan implemented by May 1, 2024.

View Audit 307138 Questioned Costs: $1

Finding 398433 (2023-006)

Significant Deficiency 2023

Women's Foundation for the State of Arizona

AZ

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

At this time, the Foundation can confirm all employees have rate of pay documentation in their employee files. The Foundation is working to adopt stronger policies around contractors engaged with the organization with oversight to contractors’ pay provided by the staffed CEO.

View Audit 307125

Finding 398423 (2023-001)

Significant Deficiency 2023

Town of Franklin

MA

Allowable Costs / Cost Principles Significant Deficiency

Christopher M. Sandini, Sr. Director of Finance / Comptroller Phone: (508) 553-4864 E-mail: csandini@franklinma.gov Thursday, April 11, 2024 RE: 2023-001 Improvement Time and Effort Documentation Planned Corrective Action Plan For each employee being charged to a Federal Grant, time and effort docum...

Christopher M. Sandini, Sr. Director of Finance / Comptroller Phone: (508) 553-4864 E-mail: csandini@franklinma.gov Thursday, April 11, 2024 RE: 2023-001 Improvement Time and Effort Documentation Planned Corrective Action Plan For each employee being charged to a Federal Grant, time and effort documentation for that employee will be maintained that shows their name, school, position, percentage (FTE) charged to the grant, the grant name, the school year and the grant period. It will be signed by both the employee and their supervisor. Anticipated Completion Date: 4/11/24 Sincerely, Christopher M. Sandini, Sr. Director of Finance / Comptroller

View Audit 307116

Finding 398413 (2023-001)

Significant Deficiency 2023

Wahkiakum School District No. 200

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum School District No. 200 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code o...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum School District No. 200 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate controls for ensuring compliance with federal requirements for allowable costs and cost principles Name, address, and telephone of District contact person: Sue Ellyson, Business Manager P.O. Box 398 Cathlamet, WA 98612 (360) 795-3971 Corrective action the auditee plans to take in response to the finding: The District will be more prompt in requesting refunds. Anticipated date to complete the corrective action: The refund was requested 3/1/24 and received 3/15/24.

View Audit 307112 Questioned Costs: $1

Finding 398402 (2023-001)

Material Weakness 2023

South Kitsap School District No. 402

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Andrea Cooper 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Andrea Cooper 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective action the auditee plans to take in response to the finding: The District was compliant with federal wage rates and will ensure that all public works projects funded with federal funds have appropriate contract language included in order to comply with all federal wage rate requirements. Anticipated date to complete the corrective action: Immediately.

View Audit 307099

Corrective Action Plans

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