Corrective Action Plans

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Finding/Issue #2025-002: Internal Controls over Fringe Benefit Cost Objectives The Corporation did not have formal process and policies to demonstrate adherence to the fringe benefits cost objectives of 2 CFR Section 200.431(d). It was recommended that the Corporation develop and incorporate interna...
Finding/Issue #2025-002: Internal Controls over Fringe Benefit Cost Objectives The Corporation did not have formal process and policies to demonstrate adherence to the fringe benefits cost objectives of 2 CFR Section 200.431(d). It was recommended that the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the fringe benefits cost objectives of 2 CFR Section 200.431(d). Management Response #2025-002: Due to the financial system and time keeping infrastructure, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Also, the current fringe cost rate and allocations is based on historical assumptions. Corrective Action Plan: • The finance team will work to ensure fringe costs are entered into the financial system based on actual costs paid by the Corporation for each employee. • The grants finance department will also create actual to budget reports in accordance with HRSA guidelines for fringe costs • The Finance Team will develop fringe costs reports to calculate, monitor and support the current rate. This will allow us to ensure the fringe cost allocation conforms to the current regulations. Management expects it to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO
Finding/Issue #2025-001: Internal Controls over Allowable Costs relating to Time and Effort While there is a time keeping system implemented to track daily hours worked by employees, the Corporation’s current internal control system does not allow for specific coding for time actually spent on each ...
Finding/Issue #2025-001: Internal Controls over Allowable Costs relating to Time and Effort While there is a time keeping system implemented to track daily hours worked by employees, the Corporation’s current internal control system does not allow for specific coding for time actually spent on each federally funded program that would support the amount charged to the Federal award. It was recommended that the Corporation develop and incorporate internal controls in order to track specific time spent on each Federal program. This can include, time and effort reports completed on a routine basis, such as monthly, and adjust program expenditures as needed to properly reflect actual work performed. Completed time and effort reports should be reviewed and verified management for accuracy. Management Response #2025-001: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations. Due to the influx of grants and staffing resources the Corporation was unable to maintain this process. Corrective Action Plan: Finance Management, Human Resources, and Payroll are collaborating to integrate time-tracking functionality into the current timekeeping system, enabling real-time tracking of time worked on grants. The rollout of this new process began in Q4 of FY25. Responsible Party: Tamara Barnes, CFO
Finding 2025-003: Activities Allowed or Unallowed U.S. Department of Housing and Urban Development , Passed through the City of Pittsburgh Assistance Listing Number 14.218 Questioned Costs: Unknown. The $1,000 billed in excess of the grant award and any additional unallowable costs that may have exi...
Finding 2025-003: Activities Allowed or Unallowed U.S. Department of Housing and Urban Development , Passed through the City of Pittsburgh Assistance Listing Number 14.218 Questioned Costs: Unknown. The $1,000 billed in excess of the grant award and any additional unallowable costs that may have existed if the fixed hourly billings exceeded NLSA’s actual allowable costs. The amount of any additional unallowable costs could not be determined. Condition: The URA did not have sufficient internal controls to ensure that reimbursement requests were reviewed for compliance with the executed grant agreement before approval or payment. During our review of the grant agreement between the URA and Neighborhood Legal Services Association (NLSA), we noted that grant proceeds were required to be used for eligible project costs, including the salaries, wages, and related costs of NLSA staff performing the legal services. However, based on our examination of the reimbursement requests, NLSA billed the URA using a fixed hourly fee for salaries rather than actual expenditures. The reimbursement requests totaled $321,000, while the total grant award was $320,000. Because NLSA did not bill based on actual expenditures, the URA could have overpaid NLSA for services provided under the grant agreement. Although this represents noncompliance with the terms of the grant agreement, based on the information available, the potential effect of the noncompliance was not material to the major program. Action: Due to an organization that couldn’t expend their allocated amount, funding was reallocated to other providers to meet the June spenddown date. Therefore, the overage was covered for NLSA.
FINDING 2025-020 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.i...
FINDING 2025-020 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Vendor Service Contracts: Standardized contract guidelines for all non-employee services. Contracts must specify exact rates, hours, duration, maximum billing limits, and include standard legal terms. Approval Hierarchy: Contracts under $50,000 can be preliminarily approved by the Superintendent and later presented to the Board. Contracts over $50,000 require a dedicated Board presentation and approval. Contract Procurement Rules: Enforced tiered purchasing thresholds—Micro Purchases (no quote), Small Purchases (3 quotes required), and Large Purchases (bid process). Change Orders: Requires formal documentation and approval. Any change order increasing project costs by 10% or more requires pre-approval from the School Board.
FINDING 2025-019 Finding Subject: Education Stabilization Fund – Activities Allowed or Unallowed – Period of Performance Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in....
FINDING 2025-019 Finding Subject: Education Stabilization Fund – Activities Allowed or Unallowed – Period of Performance Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement Processing: Detailed expenditure and budget reports are reconciled by the Director of Federal Grants, signed by a supervisor, and reviewed by the CFO before submission. Contract & Data Retention: HR worked with Regional Data Services to update software archives to prevent lost administrative records. Grant Personnel Verification: Grant fiscal officers must review and sign Payroll Certification Reports to verify that employee charges are accurate. Payroll & Stipends: All employee compensation requires pre-approval by the School Board. Implemented a formal 10-step stipend approval workflow. Overtime Policy: Mandates supervisor pre-approval before overtime hours are worked. Pay Change Process INDIANA
FINDING 2025-017 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Allowable Cost/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12....
FINDING 2025-017 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Allowable Cost/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This grant was managed by a continued succession of people. The grant information was not centrally housed. Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. Succession Planning Policy: Added strict continuity protocols to the IC Manual, affirming that all data belongs to the corporation. Requirements include maintained system documentation, account deactivation within 24 hours of employee departure, and formal knowledge handoffs. Segregation of Duties: Updated policy to ensure no single individual manages any financial process (receivables, purchasing, or inventory) end-to-end. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.
FINDING 2025-016 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12...
FINDING 2025-016 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. Succession Planning Policy: Added strict continuity protocols to the IC Manual, affirming that all data belongs to the corporation. Requirements include maintained system documentation, account deactivation within 24 hours of employee departure, and formal knowledge handoffs. Segregation of Duties: Updated policy to ensure no single individual manages any financial process (receivables, purchasing, or inventory) end-to-end. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.
FINDING 2025-012 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Allowable Costs / Cost Principles Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in...
FINDING 2025-012 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Allowable Costs / Cost Principles Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Contract Retention: HR and Regional Data Services updated software archives to prevent loss of administrative records. Grant Personnel Verification: Grant fiscal officers must review and sign Payroll Certification Reports to confirm payroll accuracy for employees charged to the grant. Payroll & Overtime Controls: All employee compensation must receive prior School Board approval. Implemented a formal 10-step stipend approval workflow and mandated pre-approval for all overtime hours. Anticipated Completion Date: Completed by June 30, 2026
FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us, atah...
FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Data & HR Retention: Updated software stores and archives via Regional Data Services to prevent administrative record loss. Payroll & Compensation: Enforced required School Board pre-approval for all compensation. Instituted a formal 10-step stipend approval workflow and mandated supervisor pre-approval for all overtime hours. Supporting Documents: Human Resources is responsible for saving and maintaining all personnel requisitions and contracts. Overtime Policy: Mandates supervisor pre-approval before overtime hours are worked Anticipated Completion Date: Corrected 06/30/2026
CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us,...
CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026
FINDING 2025-004 Finding Subject: Child Nutrition Cluster –Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: James Lutaaya, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jlutaaya@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@s...
FINDING 2025-004 Finding Subject: Child Nutrition Cluster –Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: James Lutaaya, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jlutaaya@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. PAYROLL EXPENDITURES All compensation an employee receives must go before the School Board for approval prior to the pay. Approvals are retained in the form of Personnel Requisitions, Union Contracts, Board Personnel Approval. Pay Change Process: Stipend Approval Process: STEP ACTIVITY PRIMARY EMPLOYEE LEVEL REVIEWED BY NOTE 1 Create Employee Change Personnel Requisition (in Applicant Tracker or on paper) Employee's Supervisor School / Department Department Supervisor Be specific and fill in all fields. 2 Submit to the Department Supervisor for Review & Approval Employee's Supervisor School / Department Department Supervisor 3 Submit to Human Resources for Review & Approval Department Supervisor Central HR HR will review to ensure compliance with approved salary and job titles 4 Submit to Finance for Review & Approval HR Central Finance Finance will verify vacant positions exists and provide funding information. 5 Submit to Human Resources for Processing Finance Central HR HR will update the employee's information in financial / employee software 6 Verify Accuracy of Updates HR - 2nd employee Central n/a 7 Save a Copy of all Requisitions HR Central n/a 8 All pay changes are included in the Personnel Report that is submitted to the Board to obtain approval. HR Central School Board This includes position changes, job title changes, raises, transfers, etc. INDIANA STATE BOARD OF ACCOUNTS 88 OVERTIME APPROVAL POLICY All overtime hours must receive prior approval from a supervisor or manager before extra hours are worked. Employees are not permitted to work overtime without explicit approval, except in emergency situations where prior approval is not feasible. Failure to obtain approval may result in the overtime hours being unpaid or other disciplinary actions. To request overtime, employees must submit a request to their supervisor with a brief explanation of the need for additional hours. Approval will be granted based on workload requirements and budget considerations. Corrected Date: 06/30/2026 INTEGRITY • ACCOUNTABILITY • EMPOWERMENT ACADEMIC QUALITY | EQUITY, INCLUSION & JUSTICE | FINANCIAL SUSTAINABILITY | COMMUNITY PARTNERSHIPS 737 Beale Street • South Bend, Indiana 46616 • 574-393-6100 • sb.school
CORRECTIVE ACTION PLAN FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: James Lutaaya, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jlu...
CORRECTIVE ACTION PLAN FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: James Lutaaya, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jlutaaya@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: VENDOR CLAIMS Accounts payable is ensuring that all required documentation and approvals are completed prior to processing any and all payments. Including verifying that a board approved contract is in place, if applicable. This is in accordance with our IC Manual. The Director of Food & Nutrition (DFN) will review all invoices to ensure expense appropriateness and identify expenditures that cannot be included/paid. DFN will communicate with the vendor to ensure updates are made and a new invoice is created as applicable. DFN will sign the invoice to verify the charges are correct and can be paid. SBCSC terminated its contract with the Food Service Management Company effective June 30, 2026. Corrected Date: 06/30/2026
At the beginning of the final week of each pay period, an all-staff email is sent detailing the reporting deadlines for hours to be reported to supervisors and the hours to be reported (see attached). The deadline for supervisors to report their payroll reports to fiscal is also included in the emai...
At the beginning of the final week of each pay period, an all-staff email is sent detailing the reporting deadlines for hours to be reported to supervisors and the hours to be reported (see attached). The deadline for supervisors to report their payroll reports to fiscal is also included in the email. Typically, payroll is reported to the Auditor’s office on the Friday of the last week of the pay period. However, this reporting day may change due to holidays, vacations, or the fiscal administrator’s other work responsibilities. Starting with the pay period ending September 19, 2026, employees will report all overtime worked through the day before the payroll reporting deadline of the current pay period (i.e., Thursday if Friday is the reporting deadline) and all unpaid overtime owed from the previous pay period. Timesheets will be due to the Human Resources Administrator no later than Thursday following the end of the pay period. Overtime reported on the timesheets will be matched against the overtime on the payroll transmittal to verify it has been paid. Any unpaid overtime not reported in the next pay period will be added as compensatory time on the employee’s attendance record unless the Director and Fiscal Administrator, after review, approve overtime pay for older pay periods (two or more behind the current pay period).
duties and responsibilities performed by the Family Children First Council Coordinator. Due to the audit resolution from 2024 not being finalized with ODJFS until early 2026, the transfer of FCFC funds to the social services cost pool has not occurred for 2025. The transfer will be completed for 202...
duties and responsibilities performed by the Family Children First Council Coordinator. Due to the audit resolution from 2024 not being finalized with ODJFS until early 2026, the transfer of FCFC funds to the social services cost pool has not occurred for 2025. The transfer will be completed for 2025 and 2026. The ODJFS has approved the new job description.
2025-002 - Excess Drawdown of Federal Funds (Significant Deficiency and Other Matters) Federal Program Information: Type of Finding: Compliance Areas: Funding Agency: Title: FAL Number: Passthrough: Award Period: Significant Deficiency, Other Non-compliance Cash Management, Allowable Costs and Cost ...
2025-002 - Excess Drawdown of Federal Funds (Significant Deficiency and Other Matters) Federal Program Information: Type of Finding: Compliance Areas: Funding Agency: Title: FAL Number: Passthrough: Award Period: Significant Deficiency, Other Non-compliance Cash Management, Allowable Costs and Cost Reporting U.S. Department of Education Teacher Quality Partnership Grants 84.336S NIA 10/01/2024- 09/30/2025 Principles, and Criteria: Cash Management Although 2 CFR 200.305(b)(l ) permits the Foundation to draw down funds in advance, the entity utilizes a cost reimbursement approach for Federal funding. This practice ensures that funds are drawn only for immediate cash needs . 2 CFR 200.305(8)(1) Federal payment. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or projects costs and the proportionate share of any allowable indirect costs. Cost Principals and Reporting: The application of cost principles is governed by 2 CFR 200.400; specifically (b) the non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underly ing agreements, program objectives, and the terms and conditions of the Federal award. Condition: During our review of cash management procedures, we identified the following issue: • The Foundation drew down funds for the Teacher Quality Partnership Grants {TQP) prior to expenditures or when expenditures were not yet anticipated to be actu ally disbursed. o TQP Effective Educators grant - $771,222 o TQP Southwest grant - $572,672 Questioned Costs: None. The Foundation used all the funds drawn down according to the grant directives as it closed out the grant funds. All expenditures were in compliance with the stated objectives. Cause: During the beginning of the second Donald Trump administration, President Trump issued an executive order on January 20, 2025 that established the Department of Government Efficiency (DOGE). Individuals within the Employment and Training Administration (Budget and Management) of the DOL that administered our YouthBuild program and other similar programs encouraged the Foundation to draw down the funds on all grants as they believed the grants were going to be shut down soon by DOGE, but they wanted those entities that were already committed to staffing and programs to be able to complete the year. The Foundation did draw down funds in order to complete the commitments. Effect: The Foundation was not in compliance with 2 CFR200.305(b)(l) and 2 CFR200.400(b) by drawing down funds prior to actual expenditures. Auditor's Recommendation: We recommend that the Foundation not draw down funds prior to incurring actual expenditures or until expenditures are expected in the very near future. Grant program personnel do not have the authority to waive 2 CFR requirements or grant requirements, even in unusual situations like the DOGE occurrence. Responsible official's view: • Specific corrective action plan for the finding: Three Rivers Education Foundation's CEO, Dr. Linda J Coy will ensure that all drawdowns follow appropriate timeframes as required. TREF has already implemented this longstanding practice. The action described in this "Significant Deficiency" came about because of extenuating circumstances and advice provided from the federal government. We were assisted with disbursements by the Federal Program Officer for the TQP programs. • Timeline for completion of corrective action plan: The corrective plan has been implemented as per Dr. Linda J. Coy, CEO for Three Rivers Education Foundation as of September 29, 2026. • Employee positions(s) responsible for meeting the timeline: Dr. Linda J Coy, Executive Director and James L. Coy, Chief Financial Officer
Name of Contact Person Responsible for Corrective Action: Catherine Schaaf, Executive Director Corrective Action Planned ECO implemented Clockify in 2026 to document the amount of time staff work on activities associated with each funding stream and support the allocation of payroll and related cost...
Name of Contact Person Responsible for Corrective Action: Catherine Schaaf, Executive Director Corrective Action Planned ECO implemented Clockify in 2026 to document the amount of time staff work on activities associated with each funding stream and support the allocation of payroll and related costs based on actual work performed rather than predetermined or assigned percentages. Staff received training throughout 2026 on their funding allocations and use of the time-tracking system, including guidance for appropriately recording activities by funding stream. The HR & Finance Director will be responsible for administering the time-tracking and payroll allocation process and conducting periodic audits of time-tracking records to compare documented staff activity to payroll allocations. Any identified variances will be reviewed and allocations adjusted as appropriate. The Operations Director will monitor compliance with established time-tracking and payroll allocation procedures, and the Executive Director will provide overall oversight and ensure identified issues are addressed in a timely manner. Anticipated Completion Date December 31, 2026
Name of Contact Person Responsible for Corrective Action: Catherine Schaaf, Executive Director Corrective Action Planned ECO is currently reviewing and revising its Financial Procedures Manual to ensure written accounting and administrative policies and procedures reflect current operations and appl...
Name of Contact Person Responsible for Corrective Action: Catherine Schaaf, Executive Director Corrective Action Planned ECO is currently reviewing and revising its Financial Procedures Manual to ensure written accounting and administrative policies and procedures reflect current operations and applicable Federal requirements. The revised manual will clearly document financial procedures, internal controls, responsibilities, and methodologies for allocating indirect, shared, personnel, and other costs to applicable funding sources. The HR & Finance Director will be responsible for maintaining and implementing the Financial Procedures Manual, ensuring appropriate financial documentation is maintained, and communicating applicable procedures to staff. The Operations Director will monitor implementation of and compliance with established procedures and assist in identifying areas requiring corrective action. The Executive Director will provide overall oversight and ensure identified issues are addressed in a timely manner. ECO will periodically review and update the Financial Procedures Manual to ensure policies and procedures remain appropriate for current operations and applicable requirements. Changes to established financial procedures or allocation methodologies will be documented and approved prior to implementation. Anticipated Completion Date December 31, 2026
Finding 1238780 (2025-005)
Material Weakness 2025
Finding 2025-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles Summary of Finding: During the audit, it was identified that the County charged various drug court expenditures to the SLFRF award throughout the audit period. While certa...
Finding 2025-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles Summary of Finding: During the audit, it was identified that the County charged various drug court expenditures to the SLFRF award throughout the audit period. While certain drug court activities may align with eligible programs objectives, detailed testing determined that SLFRF funds were applied to costs that are not allowable under federal guidance governing the drug court program. These expenditures do not meet the federal eligibility or cost-allowability requirements established for SLFRF funds and therefore constitute unallowable charges to the grant. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: My office was not part of any discussions when Commissioners approved the Covid-19 project list. My team will work with the Federal Treasury to make sure what Drug Court costs are allowed under the Covid-19 grant. Anticipated Completion Date: August 2026
Name of the Contact Person Responsible for Corrective Action Jacqueline Guilfoyle, Corporate Controller Planned Corrective Action: In alignment with management's commitment to ensuring complete and accurate grant reporting, internal control procedures for grant expenditure reviews will be enhanced. ...
Name of the Contact Person Responsible for Corrective Action Jacqueline Guilfoyle, Corporate Controller Planned Corrective Action: In alignment with management's commitment to ensuring complete and accurate grant reporting, internal control procedures for grant expenditure reviews will be enhanced. To mitigate the risks associated with complex or commingled invoices, reviewers are now required to perform a detailed, line-item analysis of any invoice containing multiple service types or charges. For invoices that include both allowable and unallowable costs, the reviewer must document the specific segregation of these costs. This updated procedure will ensure that only the direct, incremental, and eligible costs are approved for reimbursement, thereby strengthening compliance with granting agency requirements. We will also repay FEMA for the amount claimed in error. Planned Completion Date: October 30, 2026
The Corporation agrees with the finding and the auditor's recommendations have been adopted. $12,747 was repaid back to the Corporation in March 2026 and $150 was repaid back in September 2026.
The Corporation agrees with the finding and the auditor's recommendations have been adopted. $12,747 was repaid back to the Corporation in March 2026 and $150 was repaid back in September 2026.
View of Responsible Officials and Planned Corrective Actions. Management agrees with and will implement corrective action. The following corrective actions will be implemented: strengthening budget monitoring by requiring monthly budget-to-actual reviews for all active grants; standardizing grant al...
View of Responsible Officials and Planned Corrective Actions. Management agrees with and will implement corrective action. The following corrective actions will be implemented: strengthening budget monitoring by requiring monthly budget-to-actual reviews for all active grants; standardizing grant allocation procedures through the development and documentation of formal cost allocation methodologies; enhancing review and approval processes by conducting quarterly internal audits of grant expenditures; and improving reconciliation practices by performing monthly reconciliations of each grant account, requiring sign-off by both finance and program managers, and investigating and resolving variances within 10 business days.
Management acknowledges the need to complete and document rent-reasonableness assessments before rental assistance is approved or provided and, when required by the Organization’s procedures, before lease execution. Management plans to implement a standardized checklist requiring staff to document t...
Management acknowledges the need to complete and document rent-reasonableness assessments before rental assistance is approved or provided and, when required by the Organization’s procedures, before lease execution. Management plans to implement a standardized checklist requiring staff to document the assessment date, the comparable-unit and applicable fair-market-rent review, and supervisory approval before assistance is finalized. Management also plans to provide refresher training on the timing, documentation, and review requirements for rent-reasonableness assessments.
Legal Services Corporation 09.744060 Basic Field Grant Grant Period: 1/1/2025 – 12/31/2025 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/24-9/30/25 and 10/1/25 – 9/30/26 Contract Number: 4055105; 4055106 Supreme Court of Texas Basic Civil Legal Ser...
Legal Services Corporation 09.744060 Basic Field Grant Grant Period: 1/1/2025 – 12/31/2025 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/24-9/30/25 and 10/1/25 – 9/30/26 Contract Number: 4055105; 4055106 Supreme Court of Texas Basic Civil Legal Services Program Grant Period: 9/1/2023 – 8/31/2026 Contract Number: 26030 2025-001 Internal Controls over Compliance - Allowable Activities and Costs – Payroll (Significant Deficiency) Recommendation: We recommend the Organization review its timekeeping policies and procedures to ensure time sheets are retained for all payroll transactions to support the allocation of compensation between cost objectives and that these are provided timely to the Director of Finance to reconcile the allocation of personnel costs charged on the time sheets to the budget estimates used to bill grantors. This should be done in conjunction with monthly or quarterly billings (or other determined regular interval), at fiscal year-end, and at the end of the grant year (if different from the Organization’s fiscal year). Corrective Action: • AVDA will revise and formally approve its written timekeeping and payroll-allocation procedures. Every employee whose compensation is charged in whole or in part to a grant must submit a complete and accurate timesheet for each pay period. • Timesheets will reflect actual activity and identify the appropriate program, grant, or cost objective. Budget estimates will not serve as final support for payroll charges unless permitted by the applicable award and reconciled to actual activity. • Each employee and the employee's supervisor will approve the timesheet by the established deadline. Finance will maintain an exception log for late, missing, incomplete, or corrected timesheets and will follow up before grant billing or reimbursement requests are finalized. • The Finance Department will complete and retain a payroll-compliance checklist for each pay period. Payroll costs lacking required support or approval will not be charged to a grant and will remain charged to unrestricted funds unless and until adequate documentation is obtained and reviewed. • The Director of Finance will update employee pay rates and grant allocations promptly after each compensation, funding, or assignment change. Finance will verify current pay rates before grant billing and will document the review. • At least monthly, the Director of Finance will reconcile payroll-allocation records to the payroll register and general ledger. The reconciliation will confirm that employee allocations do not exceed 100 percent, rates agree with actual payroll, charges are supported by approved timesheets, and charges do not exceed applicable grant budgets. • A reviewer who did not prepare the reconciliation will document review and approval. The CEO will document review of organizational payroll. Payroll information relating to the CEO will be reviewed under the Board-approved process for executive compensation and payroll oversight. • Management will provide and document training for employees, supervisors, and Finance personnel regarding timekeeping, payroll allocation, allowable-cost requirements, approvals, and record retention. • AVDA will maintain timesheets, approvals, payroll registers, reconciliations, exception logs, and supporting allocation records in a centralized electronic location consistent with federal and grant-specific retention requirements. Responsible Parties: - Lisa Mikosh, Director of Finance - Marcello Gonzalez, Bookkeeper - Maisha Colter, CEO Date to be Corrected: December 31, 2026
Housing Voucher Cluster - Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority completes HQS inspections on an annual basis and implements a control to ensure compliance with annual HQS inspection requirements. Explanation of disagreement with audit finding: T...
Housing Voucher Cluster - Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority completes HQS inspections on an annual basis and implements a control to ensure compliance with annual HQS inspection requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC has reviewed its inspection procedures and implemented enhanced controls to ensure required inspections are scheduled, completed, documented, and monitored on an annual basis. HAKC is utilizing inspection tracking reports to identify units approaching or exceeding their required inspection dates. Inspection staff and supervisors are responsible for monitoring outstanding inspections and taking corrective action when an inspection is approaching its due date or becomes delinquent. Additional controls include: • Monitoring inspection due dates through recurring inspection reports; • Supervisory review of outstanding and delinquent inspections; • Tracking of inspection scheduling and completion; • Management review of inspection reports to identify overdue inspections; • Escalation of inspection deficiencies requiring corrective action; and • Staff training regarding annual inspection requirements and applicable HCV inspection procedures. HAKC will continue to perform periodic management reviews of inspection activity to ensure annual inspection requirements are being met and to identify potential delays before they become compliance deficiencies. Name(s) of the contact person(s) responsible for corrective action: Director of HCV, Assistant Directors of HCV, HCV staff, and HCV Inspection Manager. Planned completion date for corrective action plan: 12/31/2026
The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and is in the process of hiring a new Executive Director who will implement the required safeguards and ensur...
The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and is in the process of hiring a new Executive Director who will implement the required safeguards and ensure that the Authority follows its internal control over compliance processes and procedures related to the Public and Indian Housing Program to remedy the aforementioned deficiencies. Dexter Brady, Interim Executive Director, is the responsible official and this will be completed by December 31, 2026.
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