Corrective Action Plans

Finding 3168 (2023-002)

Significant Deficiency 2023

WY

Allowable Costs / Cost Principles § 200.303

2023-002 - Expenditure Controls - Significant Deficiency The District agrees that while significant progress has been made in this area, there is still work to do regarding the pre-authorization of purchases. The Business Manager has held meetings with each building and department individually to co...

2023-002 - Expenditure Controls - Significant Deficiency The District agrees that while significant progress has been made in this area, there is still work to do regarding the pre-authorization of purchases. The Business Manager has held meetings with each building and department individually to communicate proper procedures. She has also issued All Staff emails outlining these procedures and referencing board policy supporting these practices. Proper procurement procedure instructions are also available via video through a link on the Business Office Department page of the District website for reference. We recognize that proper training is imperative to compliance in all departments and the Business Office will continue to provide training throughout the year, with an emphasis in departments with new staff.

View Audit 5169

Finding 3132 (2023-003)

Significant Deficiency 2023

Delaware County Memorial Hospital D/b/a Regional Medical Center

IA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Management agrees with the finding. The Medical Center’s secondary review control will ensure allowable expenses are being claimed.

View Audit 5069

Finding 3119 (2023-002)

None 2023

Cherokee County School District

SC

Subrecipient Monitoring Allowable Costs / Cost Principles

Corrective Action: The Executive Director of Finance and Coordinator of Testing and Accountability & State/Federal Programs will do additional training on Title I plans and how to claim money. We will monitor the claims quarterly to track spending for each quarter to make sure we are meeting the pe...

Corrective Action: The Executive Director of Finance and Coordinator of Testing and Accountability & State/Federal Programs will do additional training on Title I plans and how to claim money. We will monitor the claims quarterly to track spending for each quarter to make sure we are meeting the percentages that are required by the state department. The Coordinator of Testing and Accountability & State/Federals will meet monthly with the Grants Accountant to monitor Title I.

View Audit 5045

Finding 3063 (2023-002)

Significant Deficiency 2023

Charter Institute at Erskine

SC

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430

The Institute has implemented procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements.

View Audit 5024

Finding 2748 (2023-002)

Significant Deficiency 2023

Boyne City Public Schools

MI

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

The District will require those personnel that are subject to federal award requirements to complete a personnel activity report (PAR) or semi-annual certification. The person responsible for the corrective action is Irene Byrne, the CFO. The anticipated completion date of the corrective action plan...

The District will require those personnel that are subject to federal award requirements to complete a personnel activity report (PAR) or semi-annual certification. The person responsible for the corrective action is Irene Byrne, the CFO. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is for the CFO to monitor federal employees and review the completed documents for all employees.

View Audit 4753

Finding 2740 (2023-001)

Significant Deficiency 2023

Reed City Area Public Schools

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.308

This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Ma...

This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Manager. The plan for monitoring adherence is the business manager will double check reports before submitting them to the State of Michigan.

View Audit 4709

Finding 2675 (2023-002)

None 2023

Lincoln County, Nebraska

NE

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

West Central NE Development District will need to collect reports from various offices (County Clerk & County Treasurer) to verify all expenditures and disbursements match and perform their own calculations.

View Audit 4513

Finding 2630 (2023-001)

Significant Deficiency 2023

Alight

MN

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

Views of Responsible Officials: As part of our investigation, we determined staff involved in the embezzlement colluded to circumvent Alight’s systems of internal controls at the directions of an Alight manager. In addition to taking the immediate actions listed above, including terminating the empl...

Views of Responsible Officials: As part of our investigation, we determined staff involved in the embezzlement colluded to circumvent Alight’s systems of internal controls at the directions of an Alight manager. In addition to taking the immediate actions listed above, including terminating the employment of staff involved, we also took the following actions:  We filed a police report, and are pursuing legal actions against the key actors involved in the malfeasance.  Alight’s executive leaders conducted policy, procedures and fraud notification training with the Thai staff including how to report suspected incidence of fraud.  Executive leaders and Thai leaders traveled to field offices to review operations and provide staff the opportunity to report issues. We believe these actions reinforce management’s zero tolerance to fraud and offer staff the knowledge and opportunity to report potential issues going forward.

View Audit 4459

Finding 2537 (2023-001)

Significant Deficiency 2023

Epidaurus Dba Amity Foundation

AZ

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Epidaurus dba Amity Foundation respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: BeachFleischman PLLC 1985 E. River Road, Suite 201 Tucson, AZ 85718 Audit Period: Year ending June 30, 2023 The finding f...

Epidaurus dba Amity Foundation respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: BeachFleischman PLLC 1985 E. River Road, Suite 201 Tucson, AZ 85718 Audit Period: Year ending 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 - Major Federal Award Programs Audit 2023-001 Procurement Recommendation: We recommend the Organization implement changes to their procurement policies so they contain all the requirements of 2 CFR Part 200. Auditee response: Management is working on improving the documentation of their procurement policies, and will ensure any updated policies are in line with the requirements of 2 CFR Part 200. Management expects to have the policies updated by the end of December 2023. If you have any questions regarding this plan, please call Gloria Meridew, at 520-622-6489 or gmeridew@amityfdn.org.

View Audit 4324

Finding 2523 (2023-001)

Significant Deficiency 2023

Kent State University

OH

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.413 § 200.516

Upon learning of the possibility of frauduelent activity, the University began an internal audit review and all activity on the grant was stopped. Throughout the process, the University coordinated with the Ohio Department of Development. The internal audit procedures led to the determination that $...

Upon learning of the possibility of frauduelent activity, the University began an internal audit review and all activity on the grant was stopped. Throughout the process, the University coordinated with the Ohio Department of Development. The internal audit procedures led to the determination that $209,101 was incorrectly reported by the program advisor and was not detected by the program director. These funds were returned to the Ohio Department of Development on October 11, 2023. The program has been termianted and program income returned. The individuals involved with this program are no longer employees of the University. The University is in the process of seeking reimbursement from the former employee. An internal controls questionnaire was prepared and reviewed for the other Small Business Development Center (SBDC) program noting no areas of concern. The FY24 internal audit plan will include additional review of the remaining SBDC program as well as review of controls within the department which previously managed the program noted in the finding. In addition, training related to roles and responsibilities for supervisors/approvers will be provided in FY24 to emphasize the guidance provided in the grants manual. Contact person responsible for the corrective action: Mark Polatajko, Senior Vice President for Finance and Administration.

View Audit 4303 Questioned Costs: $1

Finding 2456 (2023-003)

Significant Deficiency 2023

Independent School District No. 001

MN

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

ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, 84.425W Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): No...

ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, 84.425W Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): Not applicable Award Period: July 1, 2022 - June 30, 2023 Type of Finding: • Significant Deficiency in internal control over compliance CORRECTIVE ACTION PLAN (CAP): Recommendation: We recommend the District Board approve the wage rate of all employees via contracts or separate, individual approval. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will ensure employees’ wage rates and salaries are approved by the District’s Board. Official Responsible for Ensuring CAP: Heather Hipp, Business Manager. Planned Completion Date for CAP: June 30, 2024.

View Audit 4233

Finding 2392 (2023-001)

Significant Deficiency 2023

Union County School District

SC

Questioned Costs Allowable Costs / Cost Principles

Client Response: The Finance Director has already met with many of the various program leaders within the District to ensure they understand and grasp the concept of indirect cost calculations. They have also shared with them the excluded expenditure listing again to re-emphasize the need to accur...

Client Response: The Finance Director has already met with many of the various program leaders within the District to ensure they understand and grasp the concept of indirect cost calculations. They have also shared with them the excluded expenditure listing again to re-emphasize the need to accurately budget for indirect cost. The District has also looked into the potential to reduce its reliance on indirect cost and increase its direct spending from grants. For the finding above, the Finance Director will serve as the primary contact person for district compliance effort. The District has an estimated completion date of November 2023 as the District has already corrected the finding and resolved any noncompliance, if any, moving forward related to the above listed finding.

View Audit 4087 Questioned Costs: $1

Finding 2379 (2023-002)

Significant Deficiency 2023

East China School District

MI

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

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval a...

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval and consideration during the grant planning process.

View Audit 4071

Finding 2375 (2023-002)

Material Weakness 2023

Special School District No. 6

MN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.405

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance and Ma...

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance and Material Noncompliance With Federal Allowable Costs Requirements Finding Summary 2 CFR § 200.405 specifies a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award in accordance with relative benefits received. This standard is met if: the cost is incurred specifically for the award, the cost can be distributed in proportions that may be approximated using reasonable methods, and if the cost is necessary to the overall operation of the District and is assignable in part to the federal award in accordance with the principles in 2 CFR 200 Subpart E – Cost Principles. During our audit, we noted that the District did not have adequate internal controls in place to ensure all salary costs charged to the federal special education cluster program met the standard for an allowable or allocable cost as defined by the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allowable costs standards, which resulted in a reportable instance of noncompliance. Corrective Action Plan Actions Planned – The District’s Finance Director, along with special education staff, will review all salaries and benefits being charged to the special education cluster in fiscal 2024 to ensure that adequate time and effort documentation will be maintained for all salaries charged to the program so only allowable costs are being claimed for federal reimbursement. The District will also review its policies and procedures relating to allowable costs for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – Brady Hoffman, Finance Director. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Brady Hoffman, Finance Director, will monitor implementation of the corrective action plan to ensure compliance with the Uniform Guidance in the future.

View Audit 4067 Questioned Costs: $1

Finding 2340 (2023-003)

Significant Deficiency 2023

Antelope County

NE

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

Antelope County will complete the annual expenditure report as required by ARPA Funding.

View Audit 4002

Finding 2326 (2023-002)

Significant Deficiency 2023

Marquette Area Public Schools

MI

Allowable Costs / Cost Principles Reporting § 200.430

The School District recognizes the issue identified during the audit and has made all necessary adjustments to ensure compliance with spending down the remaining ESSER III funding.

View Audit 3993

Finding 2325 (2023-003)

Significant Deficiency 2023

Holt County

NE

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

Holt County will create a spreadsheet that will track expenditures and obligations.

View Audit 3982

Finding 2247 (2023-002)

Significant Deficiency 2023

Ralls County R-II School District

MO

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.302

I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditur...

I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the district spreadsheets will include review by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple review and the addition of PO number and date of pay request this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched the grant funds obtained through reimbursement. The new procedure will begin immediately. Tara Lewis Superintendent

View Audit 3876

Finding 2230 (2023-006)

None 2023

Wayland Baptist University

TX

Questioned Costs Allowable Costs / Cost Principles Eligibility

Need Analysis and Loan Proration Planned Corrective Action: Executive Director will provide in-house training to all advising staff to ensure proper understanding of awarding, paying special attention to over award resolution. Several selection sets have been created in PowerFAIDS to aid in identif...

Need Analysis and Loan Proration Planned Corrective Action: Executive Director will provide in-house training to all advising staff to ensure proper understanding of awarding, paying special attention to over award resolution. Several selection sets have been created in PowerFAIDS to aid in identifying over awarded students and these will be run and monitored regularly. In June 2023, WBU hired a full-time staff member to serve as a Financial Aid Compliance Specialist in the Office of Financial Aid and this position is devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: October 31, 2023

View Audit 3804 Questioned Costs: $1

Finding 2213 (2023-004)

None 2023

Bethany Fellowship, Inc.

CO

Allowable Costs / Cost Principles Eligibility Matching / Level of Effort / Earmarking

Need Analysis Planned Corrective Action: We pull a report each term to verify that students have not been over or under awarded need-based aid or over or under awarded for their COA. We have added a step to our report that is specifically checking that subsidized eligibility has been maximized whe...

Need Analysis Planned Corrective Action: We pull a report each term to verify that students have not been over or under awarded need-based aid or over or under awarded for their COA. We have added a step to our report that is specifically checking that subsidized eligibility has been maximized when a student has both subsidized and unsubsidized loans. This is completed after students have accepted their aid so it will allow us to catch if a student accepted part of both types of loans and make the necessary correction. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23

View Audit 3792

Finding 2178 (2023-003)

None 2023

Arlington Baptist University

CO

Student Financial Aid Allowable Costs / Cost Principles

Lack of Documentation of Exit Counseling Planned Corrective Action: New student information system (Campus Café) is set to send automatic message when a student is set to Withdrawn. The email notifies them of their responsibility to complete the exit counseling along with the link to the website. ...

Lack of Documentation of Exit Counseling Planned Corrective Action: New student information system (Campus Café) is set to send automatic message when a student is set to Withdrawn. The email notifies them of their responsibility to complete the exit counseling along with the link to the website. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.

View Audit 3747

Finding 2135 (2023-001)

Significant Deficiency 2023

Real Escape From the Sex Trade

WA

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

Finding 2023-001 – Allowable Costs and Allowable Activities – Significant Deficiency Condition and Context: As part of our tests of internal controls over compliance, we selected a sample of forty (40) non-payroll disbursement transactions to test controls of disbursement costs charged to the major ...

Finding 2023-001 – Allowable Costs and Allowable Activities – Significant Deficiency Condition and Context: As part of our tests of internal controls over compliance, we selected a sample of forty (40) non-payroll disbursement transactions to test controls of disbursement costs charged to the major program. The items selected in this sample were also used as a dual-purpose test for purposes of testing compliance. In our control sample, we noted there was no evidence of management approval prior to the purchase for one (1) of the forty (40) transactions tested. In this instance, the payment was made via ACH but no documentation to evidence the approval was maintained other than reliance on the bank’s automated system which will not execute an ACH without double approval. Corrective Action Plan: Management will implement a new accounting software that enable approvals within the system. Responsible Division/Office and Individual: Finance Director – Sophia Duus Estimated Completion Date: 12/31/2023

View Audit 3715

Finding 2032 (2023-002)

Significant Deficiency 2023

Catholic Charities of the Diocese of Palm Beach County, Inc.

FL

Questioned Costs Allowable Costs / Cost Principles Cash Management

2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreemen...

2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A second staff person has completed the Department of Justice Grants Financial Management Training and is now qualified to work on the federal grants. This will allow the agency to have someone other than that the person creating the reimbursement material to request the reimbursement. This adds an additional layer of control over the amount requested for reimbursement. Name(s) of the contact person(s) responsible for corrective action: Peter Hermann Planned completion date for corrective action plan: November 6, 2023

View Audit 3565 Questioned Costs: $1

Finding 1791 (2023-003)

None 2023

Anderson University and Subsidiaries

IN

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles

Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually ...

Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually after a student has been packaged. The assumption of the Financial Aid Office was that this was automatically adjusting as it had done in the previous system used. The Senior Associate Director reached out to PowerFAIDS to get an understanding of when manual calculations need to be done to a student’s need-based aid. In light of this new information, the Financial Aid Office will adjust their practice going forward. When additional aid is awarded going forward, need based aid will be manually adjusted so that students are not over awarded in need-based aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: Students who were over awarded in Federal Direct Subsidized Loans were corrected on COD effective 08/17/2023.

View Audit 3116 Questioned Costs: $1

Finding 1740 (2023-002)

Material Weakness 2023

The School District of the City of Harper Woods

MI

Questioned Costs Allowable Costs / Cost Principles § 200.403

The School District of the City of Harper Woods submits the following corrective action plans concerning findings on the schedule of findings and questioned costs: 2023-001-Audit Adjustments-Material Weakness Corrective Action The District's Chief Financial Team in coordination with the financial co...

The School District of the City of Harper Woods submits the following corrective action plans concerning findings on the schedule of findings and questioned costs: 2023-001-Audit Adjustments-Material Weakness Corrective Action The District's Chief Financial Team in coordination with the financial consultants will ensure that accounting records are completed timely and review and correct the 147c payment accruals for proper reporting in the following fiscal years. This correction will be completed by 6/30/24. 2023-002 -Material Weakness & Material Noncompliance-Allowable Costs/Cost Principles related to Title 1, Part A -Grants to Local Education Agencies, Assistance Listing Number 84-010A, Award Number 231530 and the Education Stabilization Fund, Assistance Listing Number 84.426D, Award Number 213712 Corrective Action The District's Chief Financial Team in coordination with the financial consultants and grant consultants to simplify the grant budgets so that it is easier to stay within each grant function. Also, a review will be made to ensure that the district is within budget in each grant function. This correction will be completed by 6/30/24.

View Audit 3016 Questioned Costs: $1

Corrective Action Plans

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