Corrective Action Plans

Finding 1166446 (2025-001)

Material Weakness 2025

Coos County Family Health Services, Inc.

ME

Allowable Costs / Cost Principles § 200.430

Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Alth...

Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Although the Organization calculated the capped allowable salaries for each employee, the allocations entered into the payroll system reflected full gross wages rather than the capped amounts, resulting in the excess salaries. Individual(s) Responsible for Corrective Action: Philip Kneer, CFO Brandon Gilbert, Corporate Compliance Officer / Co-Director of HR April Bledsoe, / Co-Director of HR Planned Corrective Action: Integrate automatic HRSA salary cap checks into payroll and HRIS systems. Create salary cap flags that prevent or warn when charges exceed allowable rates. Implement quarterly salary compliance audits comparing employee salaries to HRSA limits. Anticipated Completion Date: Update payroll system control within the HRIS/Payroll system by February 28, 2026 First quarterly salary compliance audit to be completed by February 26, 2026

View Audit 377456

Finding 1166336 (2025-001)

Material Weakness 2025

Aleutians East Borough School District

AK

Allowable Costs / Cost Principles § 200.303

Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documente...

Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documented in compliance with federal, state, and institutional regulations. This procedure ensures transparency, accuracy, and appropriate record retention. Reviews allocation documents; ensures proper coding. Scope: Applies to all employees whose salary or wages are distributed across two or more federal grants, cost centers, or funding sources. Responsibilities: Grant Manager/Project Director • Reviews and certifies accuracy of payroll allocations based on actual effort. • Completes Grant application according to determined allocations. • Verifies compliance with grant requirements/restrictions Business Manager • Reviews allocation documents; ensures proper coding • Verifies compliance with funding requirements/restrictions; maintains documentation for audit and retention Payroll Specialist • Processes approved changes to payroll distribution. * All approvals should be dated and signed (electronic or physical signature). Documentation and Retention: • File the following documents together: o Approved Payroll Allocation Form o Effort certification or time/effort report o Any related correspondence or justification memo. • Retain for at least 3 years after the final expenditure report for the relevant federal award, or longer if required by grantor. Periodic Review: • Conduct at least semi-annual reviews to confirm payroll allocations reflect actual work performed. • Adjust allocations as necessary and re-document approvals. Proposed Completion Date: This procedure was established in the first quarter of FY26. Full implementation of the procedure will be complete by end of FY26 Respectfully Submitted: Lisa Pearce 11/12/2025 ____________________________ __________________________ Lisa Pearce Date Business Manager

View Audit 377430

Finding 1166334 (2025-001)

Material Weakness 2025

Brac Usa, Inc.

NY

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that ...

Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that these assessments were not formalized or consistently documented in a standardized format, as required by 2 CFR § 200.332(c). To address this gap, BRAC USA will develop and implement written procedures and a standardized subrecipient risk assessment tool to be completed and filed prior to issuing Federal subawards. The tool will capture required criteria, including prior audit results, prior performance under similar awards, financial stability indicators, internal control considerations, and any recent staffing or systems changes. These procedures will be incorporated into BRAC USA’s Fiscal Policies and Procedures Manual. The results of each risk assessment will be used to tailor the level and nature of ongoing subrecipient monitoring, and records will be maintained in the grant file to evidence compliance with 2 CFR § 200.332(c). Planned Completion Date: April 30, 2026

View Audit 377413

Finding 1166293 (2025-001)

Material Weakness 2025

Maine School Administrative District No. 1

ME

Allowable Costs / Cost Principles Significant Deficiency § 200.303 § 200.430

Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk tha...

Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk that costs may be charged to the program in error. Root Cause Although program coding is built into the payroll system during employee setup, controls were not consistently documented or monitored, particularly for staff working across multiple funding sources and for private school Title I employees. A lack of secondary review allowed for one miscoding error and inconsistent position information between contracts and timesheets. Corrective Actions to Be Taken 1. Payroll Coding Review: Implement a second-level review process, led by the Business Manager, to verify all federal program payroll coding each pay period before submission. 2. Position Alignment: Require a monthly reconciliation of contracted positions against timesheet records to ensure consistency. 3. Private School Documentation: Effective immediately, require written wage documentation from private schools for all Title I-funded employees, with documents retained for audit purposes. 4. Update the written procedures related to federal and state funded payroll charges and provide refresher training for payroll and program staff by December 31, 2025. Responsible Officials - Business Manager – Oversight and monitoring of corrective actions - HR/Payroll Specialist – Implementation of payroll coding and reconciliation procedures - Title I Coordinator – Verification and retention of private school documentation Completion Date All corrective actions will be fully implemented by December 31, 2025. Monitoring and Sustainability The District will conduct quarterly internal reviews of Title I payroll activity, maintaining a monitoring log, requiring time and effort sheets and retaining documentation in the business office. Annual refresher training will be provided to ensure ongoing compliance with federal requirements. Views of Responsible Officials The District concurs that stronger documentation and monitoring are necessary. Program coding is established in the payroll system during employee setup, and controls exist to ensure proper allocation. The purpose of the timeclock system is to log hours. The issue arose due to insufficient secondary review rather than the absence of program coding. Immediate corrective measures have already been taken, and the District is committed to implementing the above actions to ensure full compliance with 2 CFR 200.303 and 2 CFR 200.430(g).

View Audit 377389

Finding 1166242 (2025-001)

Material Weakness 2025

Shepherd Public School District

MI

Allowable Costs / Cost Principles § 200.402

Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district ...

Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district could have avoided the issues that led up to this finding. That being said, the district will implement a process that allows for improved planning for expenditures and an improved monitoring of the approved budget. Through proper planning, the "last-minute" spending would be avoidable. In addition to improving the planning process, the district has implemented monthly meetings between the Director of Business Services and the Federal Programs Director. The focus of these meetings will be to complete a monthly review of planned expenses, recorded expenses, the general ledger budget within our accounting system and the budget approved in Nexsys. This monthly review, will allow the district to ensure that expenditures are classified and recorded properly. This also allows for spending to align with the approved budgets for all federal grants. This process is in addition to the approval process that is in place within the district's accounting sysem, Munis. All expenses are approved by building administrators, central office, the Business Director and then, finally, the Shepherd Board of Education as the final approval. The planned monthly meeting process for the monthly review of our federal grants will have the most impact on continued improvement of the district's internal control process.

View Audit 377272

Finding 1166148 (2025-002)

Material Weakness 2025

Yukon Flats School District

AK

Allowable Costs / Cost Principles § 200.400

Finding 2025-002 Lack of Internal Controls over Activities Allowed and or Unallowed and Allowable Costs/Activities – Cash Disbursements Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD will modify the written credit card policy that details rules for using the c...

Finding 2025-002 Lack of Internal Controls over Activities Allowed and or Unallowed and Allowable Costs/Activities – Cash Disbursements Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD will modify the written credit card policy that details rules for using the card, which includes employees taking responsibility for the use of the credit card and for the safekeeping of the credit card. Credit cards will be limited to the Superintendent, BOE President and the Academic Director. The cardholder will follow the general purchasing processes that begin with approval to purchase. Procedures for reporting credit card use with monthly reconciliations with receipts will be shared with cardholders. DocuSign will be used for electronic signature approval. Proposed Completion Date: Implemented July 1, 2025.

View Audit 377057

Finding 1165860 (2025-001)

Material Weakness 2025

Neighborhood Housing Services of Chicago, Inc. and Related Entities

IL

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which...

Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency. Contact person responsible for corrective action: Tom Sakos, Chief Financial Officer, and Jenny Cuitiva, Accounting Manager Anticipated Completion Date: May 1, 2025 for implementing controls and November 30, 2025 for communicating with the granting agency.

View Audit 376751

Finding 1165832 (2025-003)

Material Weakness 2025

Independent School District No. 361

MN

Allowable Costs / Cost Principles Cash Management Reporting

Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics...

Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics reports are reviewed before submission. Name of the contact person responsible for corrective action: Lauren Syrup, Business Manager Planned completion date for corrective action plan: June 30, 2026

View Audit 376704

Finding 1165814 (2025-002)

Material Weakness 2025

Ocean View School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services s...

Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.

View Audit 376684

Finding 1165813 (2025-001)

Material Weakness 2025

Ocean View School District

CA

Allowable Costs / Cost Principles Subrecipient Monitoring

Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring...

Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring that Title I funding was fully restored and not negatively impacted. Preventive Measure to Avoid Recurrence: Budget Code Verification Process • Fiscal Services has implemented an additional review step for all extra duty or abnormal pay requests. Before processing, HR and Payroll staff must verify the program code against the employee’s funding source in the financial system. Responsible Parties: • Director of Fiscal Services – Oversight of corrective action and monitoring. • Payroll Supervisor & HR Coordinator – Verification of funding sources before processing extra pay. • Site Administrators – Correct budget coding on memoranda. Completion Date: • Immediate correction was made prior to FY 2024-25 year-end close (August 19, 2025).

View Audit 376684

Finding 1165810 (2025-003)

Material Weakness 2025

Baraga Area Schools

MI

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring

2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant ...

2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant is received, the School District will print the grant documents and review them with the necessary employees to ensure they are aware of the allowable and unallowable costs. Additionally, all invoices will be reviewed by the Food Service Director prior to being submitted to the business office for payment. Responsible Party(ies): • Food Service Head Cook Anticipated Completion Date: December 31, 2025

View Audit 376652

Finding 1165807 (2025-002)

Material Weakness 2025

Second Harvest Heartland

MN

Allowable Costs / Cost Principles Cash Management Significant Deficiency § 200.303

Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Reviewing Source Data: o The individual reviewing the documentation is different than...

Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Reviewing Source Data: o The individual reviewing the documentation is different than the individual who prepares the documentation. o When reviewing the documentation to be used when submitting reimbursement requests to the state, the reviewer will be required to compare this documentation to the organization’s ERP system. This is the official source of record for all reimbursement requests. Anticipated Completion Date: This process was fully implemented at the beginning of November 2025.

View Audit 376643

Finding 1165792 (2025-003)

Material Weakness 2025

DISCOVERY CENTER GREAT LAKES

MI

Allowable Costs / Cost Principles

Management understands the deficiency in internal controls related to tracking of grant expenditures. The Center will develop a formal process for tracking grant expenditures by each individual grant.

View Audit 376589

Finding 1165725 (2025-006)

Material Weakness 2025

Iditarod Area School District

AK

Allowable Costs / Cost Principles Significant Deficiency § 200.400

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action form...

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action forms and required documentation for changes to payroll details. Corrective Action Plan: • Clarify roles and responsibilities regarding payroll processing. • Establish a review process of all payroll transactions and documentation. Proposed Completion Date: Fall of 2025.

View Audit 376486

Finding 1165704 (2025-001)

Material Weakness 2025

Comstock Public Schools

MI

Eligibility Allowable Costs / Cost Principles Significant Deficiency

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to fede...

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to federal grants including the Regional Assistance Grant. The Finance Director will ensure this during the invoice approval process. Finance Director and Assistant Superintendent meet monthly to discuss federal grants which includes the Regional Assistance Grant. Part of this meeting is to discuss known expenditures for federal grants so far this year to ensure they are properly coded and expended. Finance Director will run a general ledger analysis every two months to compare posted grant expenditures to approved grant budgets. Expenditures in question will be discussed at monthly meetings. Any determined to be incorrect will be moved to non-grant accounts via journal entry most likely prepared by Finance Director and approved by Associate Accountant. Contact person responsible for corrective action: RJ Wiersema and Jill Ansel Anticipated Completion Date: 12/31/2025

View Audit 376434

Finding 1165676 (2025-003)

Material Weakness 2025

The School District of Kansas City, Missouri

MO

Allowable Costs / Cost Principles Reporting § 200.431

Identifying Number: 2005-003 Audit Finding: The District must demonstrate that costs incurred are allowable and internal controls are in place to record hours worked and required educational credentials for staffing levels. Hours per timesheet did not reconcile to hours per payroll system for servic...

Identifying Number: 2005-003 Audit Finding: The District must demonstrate that costs incurred are allowable and internal controls are in place to record hours worked and required educational credentials for staffing levels. Hours per timesheet did not reconcile to hours per payroll system for services rendered for four samples and one sample did not hold the required educator credentials for their staffing level. Corrective Actions Taken or Planned (Timesheets): The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that hours paid agree with time reported by June 30, 2026. a. Training – The District has fully implemented an electronic time keeping system for hourly employees. Training has been provided to all hourly staff, and supervisors responsible to review and approve time reported. Person responsible for implementation: Erin Thompson, Chief Finance Officer b. SOP: Business & Finance will continue training of employees and supervisors who review and approve time worked. Person responsible for implementation: Erin Thompson, Chief Finance Officer c. MonitoringLeadership will periodically meet with the Department Director to verify compliance. Person responsible for implementation: Dr. Latanya Franklin Chief Academic & Accountability Officer d. Reporting: On a district-wide basis, the Payroll Department will provide to management when adherence to procedures is not followed. Person responsible for implementation: Erin Thompson, Chief Finance Officer Corrective Actions Taken or Planned (Credentials): The District agrees with the funding. The District will implement and strengthen the following internal controls to ensure staff have the required educational credentials. a. SOP: Human Resources maintain a central repository documenting certification-related notifications Person responsible for implementation: Micah Enders, Executive Director Human Recourses b. Monitoring: On a quarterly basis, reviews will be conducted to track and update certification status. Person responsible for implementation: Micah Enders, Executive Director Human Recourses c. Reporting: As part of the quarterly monitoring, a quarterly compliance report will be submitted to management. Person responsible for implementation: Micah Enders, Executive Director Human Recourses

View Audit 376372

Finding 1165643 (2025-002)

Material Weakness 2025

Dundee Community Schools

MI

Allowable Costs / Cost Principles School Nutrition Programs

2025-002 – Allowable Costs/Cost Principles – Payroll Charges Auditor Description of Condition and Effect. During our testing of personnel timecards, we noted one instance where the amounts charged to the grant were understated. The wage rate per the employee's personnel file did not agree to the rat...

2025-002 – Allowable Costs/Cost Principles – Payroll Charges Auditor Description of Condition and Effect. During our testing of personnel timecards, we noted one instance where the amounts charged to the grant were understated. The wage rate per the employee's personnel file did not agree to the rate used to pay the employee, which resulted in an underpayment to the employee which was subsequently corrected. In another instance, we noted that the District charged payroll expenditures to the food service fund that were related to a different grant. This resulted in an overstatement of costs charged to the child nutrition program. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the District review the process for accumulating and summarizing time to minimize the likelihood of errors in the process. Responsible Person: Kimberly Worden, Business Manager Corrective Action. While the identified payroll errors were very small, to address these issues, the District will implement updated review procedures to ensure accuracy of wage rates and proper grant allocation. Specifically, payroll staff will verify that employee wage rates used for grant charges agree to the rates documented in personnel files prior to processing payments. Additionally, the District will establish a secondary review process to confirm that payroll expenditures are charged to the correct grant or program before posting. Training will be provided to all payroll and grant management personnel on proper coding and documentation requirements. Anticipated Completion Date: June 30, 2026

View Audit 376310

Finding 1165637 (2025-001)

Material Weakness 2025

Dundee Community Schools

MI

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

2025-001 – Suspension and Debarment Auditor Description of Condition and Effect. For the four vendors selected for testing, the District was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services. As ...

2025-001 – Suspension and Debarment Auditor Description of Condition and Effect. For the four vendors selected for testing, the District was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services. As a result of this condition, the District was exposed to an increased risk that disbursements of federal awards could be made to vendors or subrecipients suspended or debarred by the federal government. Auditor Recommendation. We recommend that the District review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. Responsible Person: Kimberly Worden, Business Manager Corrective Action. The District will implement a process to ensure that, for any covered procurement or nonprocurement transaction, documentation is maintained confirming suspension and debarment verification was completed prior to executing the transaction. Anticipated Completion Date: June 30, 2026

View Audit 376310

Finding 1165624 (2025-005)

Material Weakness 2025

Columbus School District

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Co...

2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Completion Date – The District intends to work towards resolving this finding for the following year.

View Audit 376290

Finding 1165468 (2025-003)

Material Weakness 2025

Clintondale Community Schools

MI

Allowable Costs / Cost Principles Subrecipient Monitoring

see corrective action plan

View Audit 376196

Finding 1165456 (2025-001)

Material Weakness 2025

Aldine Independent School District

TX

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.302 § 200.303

Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of E...

Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.

View Audit 376161

Finding 1165424 (2025-002)

Material Weakness 2025

Berrien Regional Education Service Agency

MI

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.430

Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will im...

Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will implement a process to ensure that a reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed. Contact person responsible for corrective action: Emily Herbert, Director of Business and Finance Anticipated Completion Date: June 30, 2026

View Audit 376127

Finding 1165399 (2025-001)

Material Weakness 2025

Valparaiso Community Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-001 Information on the federal program: Subject: Special Education Cluster (IDEA) – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173X Fed...

FINDING 2025-001 Information on the federal program: Subject: Special Education Cluster (IDEA) – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-046-PN01, 22611-046-ARP, 22619-046-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Earmarking Audit Findings: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and earmarking compliance requirement. Context: The School Corporation is a member of the Porter County Education Services (Cooperative). During fiscal year 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-046-PN01, 22611-046-ARP, and 22619-046-ARP grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. As such, we were unable to identify if the minimum amount per each applicable member schools’ grant award was expended and properly reported to IDOE, as required. The lack of internal controls was isolated to the 22611-046-PN01, 22611-046-ARP, and 22619-046-ARP grant awards which were fully expended during fiscal year 2024. These three grant awards had minimum earmarking requirements for the Non-Public Proportionate Share of $39,016, $9,471, and $533, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative has implemented additional internal controls which includes the following: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Management of the School Corporation will also implement an internal control to monitor the School Corporation’s non-public proportionate share requirements and request supporting documentation from the Cooperative to verify the minimum earmarking requirements are being met. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Jim Holifield, Chief Financial Officer, will oversee the corrective action plan to monitor the Cooperative on an ongoing basis.

View Audit 376029

Finding 1165378 (2025-002)

Material Weakness 2025

Ecorse Public Schools

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments...

Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments to discuss budget performance and funding compliance.

View Audit 375991

Finding 1165309 (2025-001)

Material Weakness 2025

Romoland School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue ...

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.

View Audit 375893

Corrective Action Plans

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