Corrective Action Plans

Finding 1670 (2023-001)

Material Weakness 2023

MO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.400 § 200.401

Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the ...

Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The use of program funds for direct rental assistance under this program was concluded and the final disbursements made in early May 2021. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: The Commission hiring an Internal Compliance Manager and establishing an internal compliance department in May 2021 who engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. As program funds for direct rental assistance have been expended, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022, reviewed applications to identify potentially fraudulent applications during fiscal years 2022 and 2023 and expects to conclude its investigation of identified cases during fiscal year 2024. Contact Person: Steve Whitson, Director of Community Programs

View Audit 2908 Questioned Costs: $1

Finding 1621 (2023-001)

Significant Deficiency 2023

California Academy of Sciences

CA

Questioned Costs Allowable Costs / Cost Principles

The Accounting team will include a step in the monthly close process to reconcile the indirect cost rate utilized in the calculation of expense against the current negotiated indirect cost rate to ensure that indirect cost expenses are calculated and recorded using the appropriate rates.

View Audit 2868

Finding 1606 (2023-002)

Significant Deficiency 2023

Universidad Carlos Albizu, Inc.

PR

Questioned Costs Allowable Costs / Cost Principles

Finding No. 2023-002 Cost principles – overcharge of funds Condition Found During our audit procedures on the allowable activities and cost principles compliance requirements, we noted that on one (1) instance, a vendor invoiced $42,350, and the institution claimed $42,675 to the program for the s...

Finding No. 2023-002 Cost principles – overcharge of funds Condition Found During our audit procedures on the allowable activities and cost principles compliance requirements, we noted that on one (1) instance, a vendor invoiced $42,350, and the institution claimed $42,675 to the program for the same transaction. Corrective Action Plan Management accepts the finding and considers it an isolated case. We verified all the items claimed to HEERF and found this to be the only difference. The University requested and obtained an extension of this program. Thus, it is still open to process more transactions until the end of the year. The amount was promptly reimbursed to HEERF on September 13, 2023. Name(s) of the Contact Person(s) Responsible for Corrective Action Ramón L. Menéndez, Chief Financial Officer Anticipated Completion Date Completed on September 13, 2023.

View Audit 2832 Questioned Costs: $1

Finding 1584 (2023-002)

None 2023

North Greenville University

SC

Questioned Costs Allowable Costs / Cost Principles Eligibility

Need Analysis Planned Corrective Action: The financial aid staff has reporting available within PowerFAIDS to monitor and check for oversights related to need analysis. The team will review the reports to ensure that they are set up properly to identify such issues created by human error, as well a...

Need Analysis Planned Corrective Action: The financial aid staff has reporting available within PowerFAIDS to monitor and check for oversights related to need analysis. The team will review the reports to ensure that they are set up properly to identify such issues created by human error, as well as ensuring that these reports are being monitored more regularly. The team is also investigating what additional information can be added to the PowerFAIDS student financial aid portal to help students better understand the benefits of accepting a subsidized loan over an unsubsidized loan. Person Responsible for Corrective Action Plan: Cindi Patterson, Director for Financial Aid Anticipated Date of Completion: December 2023

View Audit 2823

Finding 1364 (2023-004)

Material Weakness 2023

Raccoon Consolidated School District 1

IL

Equipment & Real Property Management Questioned Costs Procurement, Suspension & Debarment

Condition: The District misallocated capital outlay expenses to a purchased service account, previously authorized improperly by the Illinois State Board of Education. Plan: The District will ensure that they are correctly coding expenditures. Anticipated Date of Completion: June 30, 2024. Name of C...

Condition: The District misallocated capital outlay expenses to a purchased service account, previously authorized improperly by the Illinois State Board of Education. Plan: The District will ensure that they are correctly coding expenditures. Anticipated Date of Completion: June 30, 2024. Name of Contact Person: Misty Johannes, Superintendent Management's Response: The District will ensure expenditures are coded correctly.

View Audit 2551

Finding 1267 (2023-001)

Significant Deficiency 2023

South Carthage Manor, Inc.

TN

Questioned Costs Allowable Costs / Cost Principles

Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.

View Audit 2391

Finding 1265 (2023-001)

Significant Deficiency 2023

Shenandoah Haven, Inc.

TN

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.

View Audit 2390

Finding 1263 (2023-001)

Significant Deficiency 2023

Shenandoah Apartments, Inc.

TN

Questioned Costs Allowable Costs / Cost Principles

Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.

View Audit 2389

Finding 1235 (2023-001)

Significant Deficiency 2023

Crowhaven Apartments, Inc.

MO

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.302

Findings: Major Federal Program Audit Significant Deficiency Written Uniform Guidelines Policies and Procedures Recommendation: We recommend Crowhaven Apartments, Inc. draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Cor...

Findings: Major Federal Program Audit Significant Deficiency Written Uniform Guidelines Policies and Procedures Recommendation: We recommend Crowhaven Apartments, Inc. draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and are in process of developing and implementing the appropriate policies and procedures.

View Audit 2334

Finding 1229 (2023-001)

Significant Deficiency 2023

Southern States Energy Board

GA

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

The Southern States Energy Board respectfully submits the following corrective action plan to incorporate a revision to our FY2023 policies and procedures that would provide additional tracking for the FSRS reporting requirement for subawards. The single finding is identified and discussed below. ...

The Southern States Energy Board respectfully submits the following corrective action plan to incorporate a revision to our FY2023 policies and procedures that would provide additional tracking for the FSRS reporting requirement for subawards. The single finding is identified and discussed below. Finding-Federal Award Finding: 2023 – 001 Improve Controls over Transparency Act Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Federal Agency: U.S. Department of Energy Federal Program Name: Transportation of Transuranic Wastes to the Waste Isolation Pilot Plant Assistance Listing Number: 81.106 Federal Award Identification Number and Year: DE-EM0005215 - 2020 Award Period: 7/01/2020 – 6/30/2025 Budget Period: 07/01/2022-06/30/2023 Explanation of disagreement with audit finding: There is no disagreement with the isolated audit finding. Action taken in response to finding: Management developed a checklist for subaward amendments, prior to the receipt of the finding and upon identification that this report had been overlooked for Budget Period 3 for award DE-EM0005215-2020. Effective immediately, funds obligated to subawardees through subaward agreements, will be reported per the grant requirement to the FSRS and recognized in the FFATA Financial Reporting system. The project identified is a five-year project and the first two Budget Periods were submitted in a timely manner as per the project’s reporting requirements. Due to the nature of this award being incrementally funded, obligations to subawards are continuous throughout each budget period as funds are designated by the prime award. Therefore, the typical quarterly reporting system controls did not trigger management to complete this along with all the other financial and technical quarterly and annual submissions. Therefore, the FY2023 FSRS reporting requirement for this project was overlooked due to unusual timeliness of sub modifications and the workload of the accounting department. With the revised tracking/checklist for each subaward that includes modifications for incremental funding, this will no longer be an issue. Management would also like to note that all other reporting requirements were submitted on time and consistent with financial reporting requirements and that this was an isolated issue within Budget Period 3 for award DE-EM0005215-2020. Name of the contact person responsible for corrective action: Leigh Hawkins, Assistant Director of Business Operations, and Kathy Sammons, Director of Business Operations. Current Status: The planned completion date for corrective action plan is September 30, 2023. All submissions were completed prior to the final audit report completion. Therefore, management considers this issue fully corrected.

View Audit 2296

Finding 1180 (2023-005)

Significant Deficiency 2023

City of Scottsdale, Arizona

AZ

Special Tests & Provisions Questioned Costs Allowable Costs / Cost Principles

Update policies and procedures for NSPIRE Inspections to ensure any extensions for repairs are adequately documented within the participant’s files. (Paper and electronic)

View Audit 2251

Finding 1167 (2023-001)

Significant Deficiency 2023

Jamesville-Dewitt Central School District

NY

Allowable Costs / Cost Principles HUD Housing Programs

Views of Responsible Official and Planned Corrective Actions: The District agrees with this recommendation. Brian Bartlett, School Business Administrator has reviewed the requirement with the District’s Payroll Coordinator, District Treasurer and Deputy Treasurer to ensure that all staff paid out o...

Views of Responsible Official and Planned Corrective Actions: The District agrees with this recommendation. Brian Bartlett, School Business Administrator has reviewed the requirement with the District’s Payroll Coordinator, District Treasurer and Deputy Treasurer to ensure that all staff paid out of Federal grants are accompanied with the appropriate certification form or PAR. The District will review staff currently being funded through any Federal grant during 2023-24 is completing a certification form, which will be filed with the applicable grant going forward. This will be the responsibility of the District Treasurer and this change will be completed by June 30, 2024.

View Audit 2233

Finding 1140 (2023-001)

Significant Deficiency 2023

Goshen Central School District

NY

Allowable Costs / Cost Principles § 200.430

The District will implement a system of internal controls to ensure that all certifications are completed timley. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee.

View Audit 2173

Finding 1131 (2023-003)

Material Weakness 2023

Ecorse Public Schools

MI

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Finding 2023-003, 2022-001 - Material Weakness in Internal Control over Financial Reporting - Payroll Documentation and Reconciliation Corrective Action Plan: The district has changed payroll staff and placed additional internal controls to ensure that adequate rates are being processed and individ...

Finding 2023-003, 2022-001 - Material Weakness in Internal Control over Financial Reporting - Payroll Documentation and Reconciliation Corrective Action Plan: The district has changed payroll staff and placed additional internal controls to ensure that adequate rates are being processed and individuals are being paid at contractual amounts that are properly documented. The CFO completed that process during the audit.

View Audit 2150

Finding 1001 (2023-002)

None 2023

School District, City of Flint

MI

Allowable Costs / Cost Principles Questioned Costs

The newly contracted Accountant for Shared Business Services fully understands the requirements and rules related to the federal ESSER dollars and reporting requirements of the Final Expenditure Report and has already ensured that newly submitted FER’s under her direction do not exceed 10% of the ap...

The newly contracted Accountant for Shared Business Services fully understands the requirements and rules related to the federal ESSER dollars and reporting requirements of the Final Expenditure Report and has already ensured that newly submitted FER’s under her direction do not exceed 10% of the approved budget. She will continue to monitor all grants and their required reporting moving forward.

View Audit 1901 Questioned Costs: $1

Finding 915 (2023-001)

Significant Deficiency 2023

Breckenridge Community Schools

MI

Allowable Costs / Cost Principles § 200.402

The Business Manager will review all grant agreements to gain a thorough understanding of allowable costs and then establish and modify or amend grant budgets appropriately to assure that only allowable costs are charged to federal grants. The Superintendent will review all federal budget amendment...

The Business Manager will review all grant agreements to gain a thorough understanding of allowable costs and then establish and modify or amend grant budgets appropriately to assure that only allowable costs are charged to federal grants. The Superintendent will review all federal budget amendments. We will put this into effect immediately going forward in all future grant agreements.

View Audit 1694

Finding 906 (2023-003)

Significant Deficiency 2023

Litchfield Community Unit School District No. 12

IL

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

2023-003 Condition: The District submitted an expenditure to the Illinois State Board of Education in excess of the budget. Recommendation: The District should ensure that the expenditure reports filed with the Illinois State Board of Education are in accordance with the items included in the bu...

2023-003 Condition: The District submitted an expenditure to the Illinois State Board of Education in excess of the budget. Recommendation: The District should ensure that the expenditure reports filed with the Illinois State Board of Education are in accordance with the items included in the budget. Management Response: The District will take the necessary steps to ensure the expenditures fall within the budget line items. If necessary, the District will amend the budget to avoid over expending a line item in the original budget. Anticipated Date of Completion: June 30, 2024

View Audit 1684 Questioned Costs: $1

Finding 898 (2023-001)

Significant Deficiency 2023

Ashley Community Schools

MI

Questioned Costs Allowable Costs / Cost Principles § 200.430

Ashley Community Schools will immediately implement procedures to ensure documentation of distribution of salaries and wages is regularly completed, reviewed, authorized and maintained. The direct supervisor of all staff providing services under federal awards will ensure documentation is compiled, ...

Ashley Community Schools will immediately implement procedures to ensure documentation of distribution of salaries and wages is regularly completed, reviewed, authorized and maintained. The direct supervisor of all staff providing services under federal awards will ensure documentation is compiled, reviewed and authorized no less than quarterly. Original documentation will be maintained by the direct supervisor and copies of fully executed documentation will be shared with the superintendent’s office for storage for a minimum of five years.

View Audit 1663 Questioned Costs: $1

Finding 858 (2023-003)

Significant Deficiency 2023

Westwood Community School District

MI

Questioned Costs Allowable Costs / Cost Principles

The District concurs with the finding. The District will implement procedures to ensure compliance requirements of the program.

View Audit 1639

Finding 706 (2023-001)

Significant Deficiency 2023

Bicentennial Apartments, Inc.

WY

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency

Management’s Response: Cable rates paid by tenants were increased recently to help cover more of the costs. We have contacted the carrier for a copy of the current contract, upon receipt we are going to opt out of the contract per the provisions of said contract. When reviewing a different contract ...

Management’s Response: Cable rates paid by tenants were increased recently to help cover more of the costs. We have contacted the carrier for a copy of the current contract, upon receipt we are going to opt out of the contract per the provisions of said contract. When reviewing a different contract (same provider) with another project it states that we will have to give a 90-day notice prior to the expiration of the then-current term. If this is the case, it will be May 20th, 2024, to terminate on July 20th 2024.

View Audit 1355

Finding 687 (2023-001)

Significant Deficiency 2023

Chittenango Central School District

NY

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

During a desktop monitoring review with the New York State Department of Education, the District was made aware of the requirement to maintain the required time certification forms. Steps have been taken to capture all required signatures on payroll charged to the related grants. Projected completio...

During a desktop monitoring review with the New York State Department of Education, the District was made aware of the requirement to maintain the required time certification forms. Steps have been taken to capture all required signatures on payroll charged to the related grants. Projected completion date is estimated to be January 31, 2024.

View Audit 1321

Finding 642 (2023-002)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

Subrecipient Monitoring Cash Management Allowable Costs / Cost Principles § 200.303 § 200.305

Identifying Number: 2023-002 Finding: For one out of two subrecipient payments tested, the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Corrective Action Planned: The College will update its subrecipient invoice payment procedure to establish st...

Identifying Number: 2023-002 Finding: For one out of two subrecipient payments tested, the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Corrective Action Planned: The College will update its subrecipient invoice payment procedure to establish stronger internal controls related to tracking subrecipient invoice approval routing. The College will ask each subrecipient to include the Manager of Grants Accounting and Compliance on any requests for reimbursements. If a subrecipient’s invoice meets Moraine Valley’s criteria for performance and fiscal compliance, the Manager of Grants Accounting and Compliance will monitor the approval process to make sure it is properly approved by the grant’s Principal Investigator, the Director of Resource Development, and the Manager of Grants Accounting and Compliance. This additional monitoring will help ensure all subrecipient invoices are paid within 30 days of receipt. If the invoice does not meet the College’s criteria including all proper supporting documentation, the invoice will be returned to the subrecipient for corrections. Anticipated Completion Date: June 30, 2024 Responsible Person: Darren Howard, Manager of Grants Accounting and Compliance Howardd46@morainevalley.edu

View Audit 1222

Finding 573 (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 1118

Finding 544 (2023-001)

None 2023

Tawas Area Schools

MI

Questioned Costs Allowable Costs / Cost Principles

The District understands the issue and will reclassify the excess expenses charged to the ESSER grant and include/incur other allowable expenses in those charged to the grant.

View Audit 1068 Questioned Costs: $1

Finding 425 (2023-001)

Significant Deficiency 2023

Shands Jacksonville Medical Center, INC

FL

Allowable Costs / Cost Principles Cash Management Eligibility

Views of responsible officials and planned corrective actions: The Financial and Data Analytics Director conducts spot testing of each bi-weekly payroll expenditure report received from Human Resources for eligible PRF reporting. Evidence of testing is retained. Responsible Officials: Dean C. Cocchi...

Views of responsible officials and planned corrective actions: The Financial and Data Analytics Director conducts spot testing of each bi-weekly payroll expenditure report received from Human Resources for eligible PRF reporting. Evidence of testing is retained. Responsible Officials: Dean C. Cocchi, Vice President and CFO Completion Date: March 31, 2022

View Audit 896

Corrective Action Plans

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