Corrective Action Plans

Finding 1177697 (2024-001)

Material Weakness 2024

GA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.318 § 200.320 § 200.403

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with...

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained.

View Audit 391130

Finding 1177674 (2024-012)

Material Weakness 2024

Southeast New Mexico College

NM

Allowable Costs / Cost Principles § 200.303 § 200.430

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on Au...

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager

View Audit 391086

Finding 1177673 (2024-011)

Material Weakness 2024

Southeast New Mexico College

NM

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency § 200.302 § 200.305

Recommendation We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs Management Response Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit repo...

Recommendation We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs Management Response Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy Development • The institution will develop comprehensive written policies and procedures to address compliance requirements related to 2 CFR 200, Subparts D and E of the Uniform Guidance and approved by institutional leadership by July 31, 2025. Policy Review and Approval • Draft policies will be reviewed by VP of Business and Finance and approved by institutional leadership by August 31, 2025. Training • Relevant personnel will be trained on the new policies and procedures to ensure consistent understanding and compliance. Implementation • The institution will fully implement the new procedures by August 31, 2025, and will ensure all departments involved with federal awards are following them. Ongoing Review: • Policies and procedures will be reviewed annually, and updates will be made as necessary to ensure continued compliance with federal regulations. Date of Completion: August 31, 2025 Responsible Parties Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Director of Finance, Restricted Funds Manager

View Audit 391086

Finding 1177643 (2024-007)

Material Weakness 2024

Jackson County

OH

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Period of Performance § 200.403

The Sheriff’s Office has separated from the person who oversaw these grants. New procedures have been implemented, and the Chief Deputy is now involved in overseeing these grants as well.

View Audit 391060

Finding 1177046 (2024-007)

Material Weakness 2024

County of Delta

MI

Allowable Costs / Cost Principles Cash Management Procurement, Suspension & Debarment § 200.303

2024-007: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) ...

2024-007: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: County management will develop written policies and procedures for grants. Contact person responsible for corrective action: Emily DeSalvo, County Administrator Anticipated Completion Date: March 2026

View Audit 390939

Finding 1177043 (2024-006)

Material Weakness 2024

County of Delta

MI

Reporting Allowable Costs / Cost Principles § 200.303 § 200.502 § 200.510

2024-006: Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a non-federal entity to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the...

2024-006: Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a non-federal entity to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a) and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Planned Corrective Action: County management will develop a closing process to ensure all federal expenditures are identified, recorded, and reconciled on the SEFA. Contact person responsible for corrective action: Emily DeSalvo, County Administrator Anticipated Completion Date: March 2026

View Audit 390939

Finding 1177009 (2024-005)

Material Weakness 2024

City of Compton

CA

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

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2026. Planned ...

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2026. Planned Implementation Date: December 2026 Responsible Person(s): City Manager

View Audit 390871

Finding 1177005 (2024-002)

Material Weakness 2024

Smithfield Housing Authority

RI

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

Smithfield Housing Authority invoices are now reviewed by the Executive Director prior to approval and payment. Supervisory review has been strengthened to ensure compliance with federal cost principles. In addition, monthly reviews of program expenditures for our regular board meetings, including t...

Smithfield Housing Authority invoices are now reviewed by the Executive Director prior to approval and payment. Supervisory review has been strengthened to ensure compliance with federal cost principles. In addition, monthly reviews of program expenditures for our regular board meetings, including the Housing Voucher Cluster, are already in place. This helps to verify accuracy and appropriate allocation of costs.

View Audit 390862

Finding 1176871 (2024-001)

Material Weakness 2024

Lifespan Corporation and Affiliates

RI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan Year Ended September 30, 2024 Finding 2024-001 AL Numbers: 97.036 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Correction Action: We will identify and quantify the total amount of the labor cost overstatement. We will report our results to t...

Corrective Action Plan Year Ended September 30, 2024 Finding 2024-001 AL Numbers: 97.036 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Correction Action: We will identify and quantify the total amount of the labor cost overstatement. We will report our results to the granting agency and work with them to resolve the questioned costs by May 31, 2026. To prevent recurrence, management will revise our review control of project applications to reconcile the calculation file to invoice support to verify accuracy. Contacts: Stephen Almonte, VP of Finance and Corporate Controller Salmonte3@brownhealth.org Mark Adelman, Director Public Policy and Federal Advocacy Madelman@brownhealth.org Planned Completion Date: May 31, 2026

View Audit 390719

Finding 1176616 (2024-002)

Material Weakness 2024

Kankakee County Community Services

IL

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

Finding 2024-002 Grant Budget Management Corrective Action Plan: Kankakee County Community Services, Inc. has implemented a comprehensive system to manage its grant budgets efficiently. Following the restructuring of its fiscal department and the engagement of an accounting firm, the organization es...

Finding 2024-002 Grant Budget Management Corrective Action Plan: Kankakee County Community Services, Inc. has implemented a comprehensive system to manage its grant budgets efficiently. Following the restructuring of its fiscal department and the engagement of an accounting firm, the organization established a robust, holistic process for overseeing all grant-related finances. Central to this approach is a budget monitoring calendar, which outlines key dates for report submissions, budget deadlines, and grant renewal periods. This calendar is accessible to all managers, fiscal staff, and the executive team, ensuring everyone remains informed of critical timelines. The Executive Director conducts weekly meetings with the senior leadership team to review ongoing tasks and discuss budget updates. During these meetings, the consultant CFO presents detailed reports on both required actions and the expenditures for each program. Person(s) Responsible: Mr. Anibal Vega Timing for Implementation: 3/1/2026

View Audit 390449

Finding 1176612 (2024-002)

Material Weakness 2024

Clare|matrix

CA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness

Responsible Official's Response: In addition to our response to Finding 2024-001, we have hired a new Director of Human Resources as of December 2023. Most of the issues regarding record retention revolve around HR documentation. As such our new Director will have a significant impact on this proces...

Responsible Official's Response: In addition to our response to Finding 2024-001, we have hired a new Director of Human Resources as of December 2023. Most of the issues regarding record retention revolve around HR documentation. As such our new Director will have a significant impact on this process going forward more so in FY 24-25 rather than FY 23-24. We have taken steps to insure the Human Resources records are audit ready and we have implemented our own internal review process to insure record readiness.

View Audit 390433

Finding 1176453 (2024-003)

Material Weakness 2024

Every Woman's Place

MI

Allowable Costs / Cost Principles Equipment & Real Property Management § 200.302 § 200.313 § 200.318 § 200.403

Every Woman's Place has fully implemented corrective action to address the induirect cost calculation and reporting issues identified in this exception. The Agency has formally adopted a signle direct allocation methodlogy, consistent with it FY2021 cost allocation plan, and has discontinued the use...

Every Woman's Place has fully implemented corrective action to address the induirect cost calculation and reporting issues identified in this exception. The Agency has formally adopted a signle direct allocation methodlogy, consistent with it FY2021 cost allocation plan, and has discontinued the use of de minimis or alternative indirect cost methodlogies. The cost allocation policy has been updated to clearly define the approved allocation medthod, allocation bases (included square footage, FTE, and usage where applicable), and the treatment of administrative and shred costs. This methodology is applied conssitently across allo programs and funding sources to ensure equitable distribution and compliance with 2 CFR 200 requirements. In addition, the Agency now requires annual board-approved certification of the cost allocation methodlogy. Allocation calculation are documented using standardized worksheets and reviewed as part of the monthly and quarterly financial review process to ensure accuracy and consistency prior to financial reporting and FSR submission. The procedures are documented in the Agency's Fiscal and Cost Allocation procedures manual and are fully operational

View Audit 390265

Finding 1176452 (2024-002)

Material Weakness 2024

Every Woman's Place

MI

Equipment & Real Property Management Procurement, Suspension & Debarment Allowable Costs / Cost Principles

We are workiing to review the current process and procedures manual and plan to have the fully updated by March 1st, 2026. All policies and procedures will be implemented at that time and will ensure that they meet state and federal accounting standards.

View Audit 390265

Finding 1176399 (2024-005)

Material Weakness 2024

Big Brothers Big Sisters of Metro Atlanta, Inc.

GA

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

2024-005: Coronavirus State and Local Recovery Funds - Assistance Listing Number 21.027; Pass-through from State of Geogia Office of the Governor and Dekalb County; Grant Period: Year Ended December 31, 2024 Planned Corrective Action Description of Corrective Action: 1. BBBSMA Accounting will set up...

2024-005: Coronavirus State and Local Recovery Funds - Assistance Listing Number 21.027; Pass-through from State of Geogia Office of the Governor and Dekalb County; Grant Period: Year Ended December 31, 2024 Planned Corrective Action Description of Corrective Action: 1. BBBSMA Accounting will set up a monthly validation process that is signed off by the CFO that the grant payroll allocation is reconciled to the time sheets for each grant billing. Overall Completion Target Date: [03/31/2026] How Effectiveness Will Be Monitored: 1. Monthly validation of grant payroll to timesheets should be signed off by 20th workday after every month and scanned into the accounting grant file on the system. Responsible Person: CFO/VP Finance and CEO in lieu of CFO.

View Audit 390235

Finding 1176398 (2024-004)

Material Weakness 2024

Big Brothers Big Sisters of Metro Atlanta, Inc.

GA

Allowable Costs / Cost Principles § 200.302

2024-004: Lack of Written Procedures for Determining Allowability of Costs Federal Program: All federal programs Planned Corrective Action Description of Corrective Action: 1. Accounting Policy Manual for Federal Government Grant Practice and Internal Controls will be reviewed and updated to ensure ...

2024-004: Lack of Written Procedures for Determining Allowability of Costs Federal Program: All federal programs Planned Corrective Action Description of Corrective Action: 1. Accounting Policy Manual for Federal Government Grant Practice and Internal Controls will be reviewed and updated to ensure that the section on Allowable Costs is up to date. a. The manual should have procedures with clearly designed responsibilities, documentation requirements, and approval processes to ensure all costs charged to federal programs are allowable, allocable and reasonable. 2. Accounting Staff and Management will be trained on Federal Grant Allowable Costs. Overall Completion Target Date: [06/30/2026] How Effectiveness Will Be Monitored: 1. Accounting Policy Manual for Federal Government Grant Practice and Internal Controls with updates to ‘allowable costs’ will be reviewed and updated by June 30, 2026 and will be presented to the BBBSMA Finance Committee. 2. Accounting Staff will be trained on Federal Grant Allowable Costs by June 30,2026 and will send an email to the CEO that describing the training completed. Responsible Person: CFO/ VP Finance and CEO in lieu of the CFO

View Audit 390235

Finding 1176211 (2024-001)

Material Weakness 2024

Hancock County Board of Education

GA

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.302 § 200.303 § 200.403 § 200.415 § 200.430

FA 2024-001 Improve Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Principle...

FA 2024-001 Improve Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Principles Reporting Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund S425D210012 (Year: 2021), S425U210012 (Year: 2021) $819,799.49 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Hancock County School District has updated the policies and procedures to ensure that these coding errors do not occur in the future. The updates included but are not limited to: The District has corrected the coding in the general ledger for FY 26 and has implemented additional coding cross-checks to ensure alignment with the approved Con App. The function/object coding has been corrected in the FY 26 budget crosswalk, and coding protocols have been reinforced. Personnel coding has been corrected, and a verification procedure is now in place at the point of hiring and funding assignment. The Federal Program department will meet with the Finance Department to review funding codes prior to submission. Estimated Completion Date: June 30, 2026 Contact Person: Matthias Jones, Finance Director Telephone: 706-444-5775 ext. 125 Email: mjones@hancock.k12.ga.us

View Audit 390080

Finding 1176188 (2024-002)

Material Weakness 2024

Westerly Area Rest Meals (warm) INC

RI

Allowable Costs / Cost Principles § 200.430

2024-002 Payroll Costs Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Training has been provided and currently the payroll allocations are matched to weekly payroll reports from outside payroll company. Allocations of vacation and sick time are done according to a...

2024-002 Payroll Costs Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Training has been provided and currently the payroll allocations are matched to weekly payroll reports from outside payroll company. Allocations of vacation and sick time are done according to actual payroll reports and entered into accounting software based on true numbers instead of tracked on a spreadsheet. Completion Date – June 30, 2025 Root Cause – Outdated procedures in place.

View Audit 389999

Finding 1176187 (2024-001)

Material Weakness 2024

Westerly Area Rest Meals (warm) INC

RI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.403

2024-001 Supporting Documentation and Approval of Disbursements Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Since that time, the organization has developed an invoice and payment process. This ensures proper disbursement and approval processes and supporting do...

2024-001 Supporting Documentation and Approval of Disbursements Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Since that time, the organization has developed an invoice and payment process. This ensures proper disbursement and approval processes and supporting documentation are obtained for expenses incurred. We will ensure that the expenses for the grants are reviewed monthly and will make the correct adjustments on a timely basis to ensure that the funds are approved and paid in accordance with the grant documents. Completion Date – June 30, 2025 Root Cause – New program procedures were not in place

View Audit 389999

Finding 1175894 (2024-003)

Material Weakness 2024

Folsom Cordova Community Partnership

CA

Allowable Costs / Cost Principles

Response: The organization agrees with the finding. The organization has implemented a method to ensure prepaid insurance is appropriately adjusted and insurance costs are accurately recorded and allocated to grants.

View Audit 389865

Finding 1175862 (2024-002)

Material Weakness 2024

TOWN OF OWEGO

NY

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.112 § 200.317 § 200.326

The Town Supervisor will provide an updated policy to be approved by the Town Board in 2025.

View Audit 389834

Finding 1175845 (2024-002)

Material Weakness 2024

Estill County Fiscal Court

KY

Equipment & Real Property Management Allowable Costs / Cost Principles § 200.303 § 200.313

Claims are submitted to fiscal court for approval for payment. Checks are processed the following day. With the CSEPP program some payments are dependent on advance payments being received. Master inventory is maintained at state level. Local inventory is being updated and will be completed by 12/31...

Claims are submitted to fiscal court for approval for payment. Checks are processed the following day. With the CSEPP program some payments are dependent on advance payments being received. Master inventory is maintained at state level. Local inventory is being updated and will be completed by 12/31/2025.

View Audit 389822

Finding 1175552 (2024-007)

Material Weakness 2024

Assabet Valley Regional Technical High School

MA

Period of Performance Allowable Costs / Cost Principles

Finding 2024-007 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: During our test of control...

Finding 2024-007 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that there was an expenditure charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Unallowable costs for this period was $52,426. Effect: Assabet Valley RTHS was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned cost charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $52,426. Cause: Grant should have been amended. Identification as a Repeat Finding: 2023-003 Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Maria Silva Estimated Completion Date: 2024 Action Taken: Grant has since been corrected and funds where moved to the correct account in our general ledger. Assabet staff is aware that leases cannot be past or before a grants end/start date.

View Audit 389346

Finding 1175551 (2024-005)

Material Weakness 2024

Assabet Valley Regional Technical High School

MA

Allowable Costs / Cost Principles

Finding 2024-005 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over co...

Finding 2024-005 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Special Education Cluster for expenses that are unallowable costs. Criteria: Costs charged to the major programs should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our test of expenditures and review of the general ledger against the Special Education Cluster as it is related to compliance it was noted that the FY 23 Special Education PL94-142 grant had two invoices charged to the grant for promotional items (mugs, shirts, totes, jackets, etc.…) to the budget line as classroom supplies. The FY 2024 Special Education IEP 274 grant had an expense whose supporting documentation was a quote as the invoice was not received. Effect: Assabet Valley RTHS was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: Questioned costs for one of the invoices charged to the FY 23 Special Education PL94-142 was for 72 porcelain mugs was $292.46. Questioned costs for the other invoice charged to the FY 23 Special Education PL94-142 grant was for shirts, totes, jackets, apron, and windbreakers was $1,320.99. Questioned costs for the FY 2024 Special Education IEP 274 grant whose supporting documentation was a quote was $7,950.00. Cause: I glanced at the invoice quickly not paying attention as I normally would due to it was the end of the year and we were closing out the grant, also our former sped director had approved the purchase. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: All requests for purchases will be double/triple checked. Before paying an invoice items will be checked again that they match the grant requested requirements and laws.

View Audit 389346

Finding 1175550 (2024-004)

Material Weakness 2024

Assabet Valley Regional Technical High School

MA

Allowable Costs / Cost Principles Period of Performance

Finding 2024-004 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assuranc...

Finding 2024-004 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: 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. Management of the School is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the program, the employees tested were for pay periods outside the period of performance and were found to not have time and effort certifications for the pay periods tested. Cause: We did not have a full-time payroll staff member or a grant manager. Context: During our test of payroll transactions charged to the Special Education Cluster it was noted that Payroll transactions were charged to the FY 24 Special Education PL94-142 grant were for services prior to the grant start date of 8/28/23 in the amount of $24,196.32. Additionally, the same payroll transactions were not supported with Time and Effort certifications for payroll charged to the FY 24 Special Education PL94-142. Effect or Potential Effect: Due to the material weakness and noncompliance in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: This is not a repeat finding. Questioned Costs: Total questioned costs for the payroll charged to the grant that was outside the period of performance and not supported with Time and Effort certifications totaled $24,196.32. Recommendation: The Assabet Valley Regional Technical High School should improve the internal controls over Allowable Costs by ensuring employee’s payroll charged to the federal grant is within the period of performance and supported with Time and Effort certifications. Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Also at the same time we had no trained payroll staff to verify the salaries where paid out of the correct account line. We are double checking that the staff is paid correctly and not before a grant begins or ends. Also all staff will have signed a time and effort sheet for any pay periods they are paid out of grants.

View Audit 389346

Finding 1175337 (2024-002)

Material Weakness 2024

Connecticut Veterans Legal Center, Inc.

CT

Allowable Costs / Cost Principles

The Center is implementing processes for employees to maintain timesheets, indicating which programs they worked on, and including a supervisor review of the timesheets.

View Audit 389043

Corrective Action Plans

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