Corrective Action Plans

Finding 374524 (2023-001)

Significant Deficiency 2023

NC

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: The Medicaid Program Manager reviewed the verification process and the requirement to upload all information into NCFAST with the Medicaid staff. The formal case file review process will continue to monit...

Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: The Medicaid Program Manager reviewed the verification process and the requirement to upload all information into NCFAST with the Medicaid staff. The formal case file review process will continue to monitor this and other areas. Additional training will be offered if the case file reviews reveal deficiencies in this area. Proposed Completion Date: Immediately and ongoing.

View Audit 294242

Finding 374513 (2023-001)

Significant Deficiency 2023

Soka University of America

CA

Student Financial Aid Eligibility Reporting

Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified defic...

Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified deficiency in our enrollment reporting process, a thorough evaluation was conducted to rectify the issue and prevent its recurrence. We recognized that alterations in students' academic plans, prompted by the COVID-19 pandemic, led to delays in fulfilling mandatory graduation requirements such as study abroad requirements, resulting in delays in posting study abroad grades to the Soka transcript. Consequently, during end-of-term degree audits by the Office of the Registrar, students with pending study abroad grades or incomplete grades in their final term were inadvertently not updated to a withdrawn status, thereby failing to trigger updates to the National Student Clearinghouse and subsequently National Student Loan Data System (NSLDS). In collaboration with the Office of the Registrar, robust internal controls have been implemented to mitigate this issue going forward. Following the conclusion of each term, the Registrar will generate a comprehensive report listing all students who have applied for degree completion. This report will be annotated to identify students who have fulfilled all degree requirements, enabling their degrees to be conferred promptly. Additionally, students with incomplete grades will be flagged, and their status will be promptly changed to withdrawn. In both scenarios, enrollment status updates will be transmitted to the clearinghouse and subsequently NSLDS. The Registrar will inform the Office of Financial Aid of graduates and students with updated statuses for NSLDS reporting, and Financial Aid will request an ad hoc enrollment request on NSLDS. To ensure accuracy, a manual spot-checking process will be conducted in NSLDS on 20% of the updated student records in NSLDS. Upon notification of completed incomplete grades, the Registrar will promptly update transcripts, review degree requirements, and confer degrees where applicable. Following this update, the Registrar will manually update the clearinghouse and ask the Office of Financial Aid to request an Ad hoc enrollment report on NSLDS, ensuring timely and accurate reporting. This manual request will be verified on NSLDS after the ad hoc report has been run. Students failing to meet degree requirements due to failed coursework and are enrolled to return in subsequent terms will not be updated to withdrawn status unless they fail to return as scheduled. These measures aim to enhance the integrity and accuracy of our enrollment reporting process, ensuring compliance with regulatory requirements and minimizing the risk of future deficiencies. Anticipated Completion Date: February 2024 Scott Brandos Director of Financial Aid Soka University of America 949-480-4048

View Audit 294224

Finding 374490 (2023-001)

Significant Deficiency 2023

Gilbert Straub Plaza, INC

PA

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

United States Department of Housing and Urban Development Gilbert Straub Plaza, Inc., respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Maher Duessel, CPA's 503 Martindale Street, Suite 600 Pittsbur...

United States Department of Housing and Urban Development Gilbert Straub Plaza, Inc., respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Maher Duessel, CPA's 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: September 1, 2022 - August 31, 2023 The finding from the August 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT See Below FINDINGS— FEDERAL AWARD PROGRAMS AUDITS Finding 2023-001 Department of Housing and Urban Development Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects - Section 223(f)/207 ALN 14.155. Recommendation: The Property should have internal controls in place to review Form HUD-50059 to ensure all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated. Action taken: The property management company has revisited the internal controls with the on-site manager. The manager certifies that they will do diligence in the future to ensure that they follow these controls in calculating tenant rent and assistance payments. If the Department of Housing and Urban Development has questions regarding this plan, please call Dan Barbusio at 412-646-5193.

View Audit 294185

Finding 374429 (2023-002)

Material Weakness 2023

Lawrenceburg Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Findings: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Elig...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Findings: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The free and reduced-price applications were completed online by the applicants, and the information was automatically uploaded into the School Corporation's nutrition program software system. The software system then calculated the student's eligibility for free and reduced-price meals based on the parameters in the system. There was no documented oversight, review, or approval process to ensure the parameters in the system were correct and that the eligibility determination made complied with the requirements of the programs. The lack of internal controls was a systematic issue throughout the audit period. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director and Business Manager have added the verification of every 30th Free/Reduce application that is submitted during the school year to their monthly checklists. Beginning with the 2024-25 school year, the Food Service Director will enter the eligibility parameters into the school nutrition software. Once entered the Food Service Director will provide a copy of the prices entered into the system to be reviewed and approved by the Business Manager or Superintendent. Anticipated Completion Date: January 2024/July 2024

View Audit 294097

Finding 374407 (2023-003)

Significant Deficiency 2023

Sunshine Connections, Inc.

KS

Allowable Costs / Cost Principles Cash Management Eligibility

2023-003 – 10.558 – Child and Adult Care Food Program – Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Eligibility Condition Four providers received an improper amount for their meal reimbursement for the month tested. Recommendation Controls should be reviewed and updated t...

2023-003 – 10.558 – Child and Adult Care Food Program – Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Eligibility Condition Four providers received an improper amount for their meal reimbursement for the month tested. Recommendation Controls should be reviewed and updated to ensure that complete and accurate meal counts are submitted to the State for reimbursement. Comments on the Finding Given the Organization’s limited size, it is not always feasible to fully segregate the duties surrounding the meal claims processes. However, in order to mitigate errors, steps have been taken to implement checks within those processes. Action Taken Whenever possible, an employee other than the Director will prepare the claims. The Director of the Organization will later review the claims for accuracy and compare the claim numbers in both the Excel Spreadsheet and the Little Organizer Program to ensure their correctness.

View Audit 294026

Finding 374388 (2023-004)

Significant Deficiency 2023

Bethany College

KS

Questioned Costs Student Financial Aid Eligibility

Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enr...

Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing

View Audit 293985 Questioned Costs: $1

Finding 374343 (2023-001)

Significant Deficiency 2023

Lexington-Fayette Urban County Housing Authority

KY

HUD Housing Programs Subrecipient Monitoring Eligibility

Re: 2023-01 Audit Finding/Plan of Action The Lexington Housing Authority (LHA) proposes this corrective plan of action to address the late recertifications (13) and annual recertification (1) from the audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 25-29, 2023. ADDRESSING S...

Re: 2023-01 Audit Finding/Plan of Action The Lexington Housing Authority (LHA) proposes this corrective plan of action to address the late recertifications (13) and annual recertification (1) from the audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 25-29, 2023. ADDRESSING STAFFING Securing qualified candidates to fill Housing Management Specialist (HMS) positions throughout 2020, 2021 and 2022 was challenging for LHA. In some instances, positions were vacant for up to 12 months before they were filled. LHA will do the following to address staffing: • Seek to fill HMS positions within forty-five (45) days of the position going vacant. • Advertise to hire two full-time HMS positions for the two management teams with the most units in their management portfolio. • Continue to advertise open positions online, on social media and in the local newspaper. • Offer incentive bonus up to $1,500 to newly hired HMS, paying $750 to new hires after six month of employment and an additional $750 after 12 months of employment. • Over-time will be allowed on an as-needed basis to complete and process certifications. CERTIFICATION PROCEDURES Further, LHA housing management staff will adhere to the following procedures to facilitate timely completion of annual certifications. - HMS staff will continue utilize in-person interviews and mail (via USPS and email) to complete needed documentation for annual certifications. - All housing management staff may utilize electronic signature to attain required signatures when necessary. - The first day of each month housing managers will run the certification audit report to be shared with the Chief Operating Officer to monitor the status of in-progress and upcoming certifications. - July 1, 2023, LHA implemented quality control (QC) of public housing files to be conducted by a newly created compliance position. LHA' s compliance coordinator will complete 229 (25%) QC reviews of public housing files during FY2024 (July 1, 2023 - June 30, 2024). - At least once monthly on a rotating basis housing management staff from all offices will convene at a selected housing management office to complete and process certifications. This schedule will continue until all offices are up to date on certifications. LHA staff will apply these procedures as outlined to mitigate this finding to ensure compliance and proper documentation of future certifications. Contact Person: Andrea Wilson, Chief Operating Officer Anticipated Completion Date: June 30, 2024

View Audit 293932

Finding 374286 (2023-002)

Material Weakness 2023

Delphi Community School Corporation

IN

School Nutrition Programs Eligibility Material Weakness § 200.303

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Verification of Free and Reduced Price Lunch Applications Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with requirements related to the grant agreement and S...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Verification of Free and Reduced Price Lunch Applications Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with requirements related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will review the applications, the other will do a second review. The Food Service Director and Assistant sign each application that is verified to ensure all information is accurate and the eligibility status is correct in Skyward. If additional verification information is provided, it will be documented and recorded in the binder with the applications. Anticipated Completion Date: August 2024

View Audit 293921

Finding 374281 (2023-003)

Material Weakness 2023

Delphi Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Eligibility compliance requirements. The failure to establish an effective inter...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Eligibility compliance requirements. The failure to establish an effective internal control system places the School Corporation at risk of noncompliance with the grant agreement and the Eligibility compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and the Eligibility compliance requirements listed above. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will enter online and paper applications, the other will review the entries compared to the applications, and both will sign off the applications. An additional selection will be added in Skyward to document which type of classification. A legend for the codes will be kept in the front of the binder where the applications are kept for reference. Anticipated Completion Date: August 2024

View Audit 293921

Finding 374269 (2023-001)

Significant Deficiency 2023

Kalihi-Palama Health Center (hale Ho'ola Hou)

HI

Special Tests & Provisions Subrecipient Monitoring Eligibility

Finding 2023-001 Special Tests and Provisions - Sliding Fee Scale Recommendation Kalihi-Palama Health should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated, and patients receive the correct sliding fee discount. Action Taken: We implemented...

Finding 2023-001 Special Tests and Provisions - Sliding Fee Scale Recommendation Kalihi-Palama Health should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated, and patients receive the correct sliding fee discount. Action Taken: We implemented a new EHR system AthenaOne and it includes a sliding fee scale calculation tool. By March 18, 2024 we will have completed doing all of the testing and training of all current Patient Services/Front Desk staff. Effective April 1 2024, we will implement the following changes to ensure clients are appropriately charged according to the sliding fee scale: • Update recurring sliding fee scale employee training sessions to quarterly. • Update training process documentation and reference materials for sliding fee scale. • Implement monthly review and spot check procedures to ensure compliance with the sliding fee scale requirements and guidelines. Based on the results of the reviews and spot checks, individualized training will be provided staff. • Onboarding new Patient Services/Front Desk staff will be based on the updated training and reference materials. Should you need additional information or have questions, you can reach me at ekintu@kphc.org or (808) 791-6315. Emmuel Kintu, D. Mgt, MBA Chief Executive Office & Executive Director

View Audit 293873

Finding 372633 (2023-005)

Significant Deficiency 2023

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Eligibility

The Section 8 Program will improve its internal controls and monitoring procedures to assure the correction of income included in the 50058-Family Report. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 293712

Finding 372621 (2023-006)

Significant Deficiency 2023

Agate Housing and Services, Inc.

MN

Special Tests & Provisions Eligibility HUD Housing Programs

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for do...

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for documenting the determination and approvals in the case files. Completion date – Management and the Board of Directors implemented the above as of 2/28/2024

View Audit 293672

Finding 372380 (2023-003)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Eligibility

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly de...

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly determined. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: For student #5, there was a Pell awarding error where the student was under awarded Pell by $172. The school made the correction to the award and disbursed the additional Pell. For student #16, student was over awarded Pell Grant for $1723 due to incorrect refunds made while adjusting for changes in the student's schedule. The school has refunded the $1723 over award back to the fund source. For student #24, the student was initially awarded correctly, but withdrew during their 2nd term. Due to incorrect Pell Recalculation on the R2T4, the school refunded too much Pell grant, and the student was under awarded by $458. The school has disbursed the additional Pell so the student is now paid correctly. For student #27, the student was over awarded Pell by $350 due to in error in Pell Recalculation based on the student's schedule. The school has refunded the over award to the fund source. For student #43, the student was under awarded by $22 due to an error in Pell Recalculation based on the student's schedule. The school has disbursed the additional Pell grant funds to correct the error. Starting with the Fall 2023 semester the school has implemented a new student information system (SIS), Colleague. The school has also partnered with a third-party servicer, Financial Aid Services (FAS), to assist with packaging. The new SIS automatically adjusts Pell grant whenever there is a change to a student's schedule during the term through the school's census date for each term and module. The system will schedule a refund for any over awards and increase the Pell award for any that may have been under awarded. Since this is no longer reviewed solely by the financial aid office, this is expected to reduce the number of errors in Pell awarding. In addition to the system adjustments, the school's third-party servicer, FAS, will review packaging for any students with changes to the number of registered credits during the term to ensure the system is making adjustments properly and the students are correctly packaged. Name(s) of the contact person{s) responsible for corrective action: Financial Aid Director, Holly Hardnett and third-party servicer, FAS, representative Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training for Pell Recalculations in Colleague July 2023. • Registration/schedule changes for term reviewed by FAS at least weekly.

View Audit 293636 Questioned Costs: $1

Finding 372299 (2023-002)

Significant Deficiency 2023

Rockhurst University

MO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescrib...

Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: John Sircy, Interim CFO Anticipated Completion Date: June 2024

View Audit 293605

Finding 372294 (2023-001)

None 2023

North Dade Senior Citizens Housing Developement Corporation, Inc., Rsi

FL

HUD Housing Programs Eligibility Reporting

Oversight Agency for Audit, North Dade Senior Citizens Housing Development Corporation, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite ...

Oversight Agency for Audit, North Dade Senior Citizens Housing Development Corporation, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: July 1, 2022 through June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2023-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should implement procedures to ensure initial tenant income through EIV system and third-party documentation are verified in a timely manner, annual unit inspections are performed, and all required tenant documentation is complete and accurate. Action Taken: Monthly reminders are being sent to all managers to run their EIV reports for the month. In addition, random files are being reviewed by compliance to ensure EIV reports are pulled, unit inspections performed, and required documentation is complete and accurate.

View Audit 293594

Finding 372283 (2023-001)

None 2023

Greater Pittsburgh Community Food Bank

PA

Subrecipient Monitoring Procurement, Suspension & Debarment Eligibility

During the Fiscal 2023 financial statement audit, Schneider Downs communicated the following finding from their Uniform Guidance procedures: The Food Bank did not obtain and or retain agency monitoring forms for 15 out of our sample of 25. Our response to the finding was: COVID-19 risk mitigation st...

During the Fiscal 2023 financial statement audit, Schneider Downs communicated the following finding from their Uniform Guidance procedures: The Food Bank did not obtain and or retain agency monitoring forms for 15 out of our sample of 25. Our response to the finding was: COVID-19 risk mitigation strategies employed by our Food bank and our partner agencies restricted our ability to directly monitor partner sites. The team responsible for monitoring and compliance also experienced staffing inconsistencies that have since been rectified; the team is now able to monitor at full capacity. Moving forward, new tools and processes for scheduling and tracking agency monitoring will provide better real-time insight into our progress and compliance. Finally, agencies are expected to renew their agreement with our Food Bank at 2024 calendar year-end, which will reassert our monitoring requirements to all partner agencies in our network. Update as of February 23, 2024 The Food Bank has taken the following actions: • The annual contract renewal process has been initiated, including reassertion of our monitoring requirements. • Additional compliance staff have started the regular monitoring process. • A system has been put in place to provide compliance progress updates to the Controller.

View Audit 293573

Finding 372228 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Galveston, Texas

TX

HUD Housing Programs Eligibility Significant Deficiency

Housing Choice Vouchers - CFDA No. 14.871 - Eligibility Recommendation: The Authority should implement processes to ensure that all documentation is received and that the correct inputs are being accurately reported on the HUD-50058. Explanation of disagreement with audit finding: There is no disa...

Housing Choice Vouchers - CFDA No. 14.871 - Eligibility Recommendation: The Authority should implement processes to ensure that all documentation is received and that the correct inputs are being accurately reported on the HUD-50058. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The errors found where: Income was miscalculated. GHA'S staff will continue to have refresher trainings to ensure that all documentation is correct and properly reported on the HUD-50058 Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: Ongoing

View Audit 293526

Finding 372066 (2023-005)

Significant Deficiency 2023

City of East Prairie, Missouri

MO

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.403 § 200.403(F)

CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTH...

CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / THE CITY OF EAST PRAIRIE RECEIVED ARPA FUNDS THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE REMOVAL OF ASBESTOS AND DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY IN AUGUST AND SEPTEMBER, 2022. IN DECEMBER OF THE SAME YEAR, THE CITY RECEIVED WAS AWARDED AND ARPA GRANT AND FUNDS THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION FOR THE SAME PROJECT. THIS WAS A DUPLICATION OF ARPA FUNDS DUE TO THE CITY NOT BEING FULLY AWARE OF THE COST STANDARDS OF UNIFORM GUIDANCE AND A MISCOMMUNICATION REGARDING ELIGIBILITY OF COSTS. / THE CITY OF EAST PRAIRIE HAS CONTACTED MISSISSIPPI COUNTY AND WILL BE RECEIVING AUTHORIZATION FROM THE MISSISSIPPI COUNTY COMMISSION TO RE-ALLOCATE THOSE FUNDS FOR THE SAME PUBLIC HEALTH FACILITY PROJECT. WE ARE ALSO DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL CONFORMING TO UNIFORM GUIDANCE.

View Audit 293337 Questioned Costs: $1

Finding 371990 (2023-007)

Significant Deficiency 2023

Garrett-Evangelical Theological Seminary

IL

Student Financial Aid Eligibility Subrecipient Monitoring

Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. ...

Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. The Satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the Registrar and Financial Aid Director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the Financial Aid Director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar financial aid account. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 06/01/2024

View Audit 293235

Finding 371933 (2023-001)

Significant Deficiency 2023

Saint Joseph's Tower, INC

IN

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157)  Section 8 Housing Assistance Payments Program (ALN# 14.195) Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in, move out, and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024

View Audit 293201

Finding 371928 (2023-001)

Significant Deficiency 2023

East Detroit Area Non-Profit Housing Corporation

MI

Allowable Costs / Cost Principles Eligibility HUD Housing Programs

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of a sample of 6 tenant files, it was noted: 1. Two out of six instances where an EIV was not run for a tenant file within 90 days of move in; 2. One out of six instances where the incorrect tenant income was used to calculate the tenant assistance payment; 3. One out of six instances where a tenant moved out and the requested overages were not adjusted for the correct time period; In addition, procedures were not in place to document the applicants, admissions, and removals to and from the tenant waitlist. Effect. As a result of this condition, certain tenant files did not contain all required supporting documentation. In addition, employees did not follow HUD guideline procedures, and/or did not properly calculate the tenant subsidy in HUD Form 50059. While there were no significant differences in the amount of subsidies allowed compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. A tenant waitlist will be created and maintained. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024

View Audit 293198

Finding 371918 (2023-005)

Material Weakness 2023

City of Albuquerque

NM

Reporting Subrecipient Monitoring Eligibility § 200.302 § 200.303

The City agrees with the finding. The Treasury Portal automatically fills in the amounts for revenue loss for 2022 with amounts reported in 2020. The Treasury portal has many flaws that would cause errors in reporting. In addition, the portal has changed every quarter, which makes it challenging to ...

The City agrees with the finding. The Treasury Portal automatically fills in the amounts for revenue loss for 2022 with amounts reported in 2020. The Treasury portal has many flaws that would cause errors in reporting. In addition, the portal has changed every quarter, which makes it challenging to report accurately. The City will implement controls to ensure that a second review is completed prior to certification of the report. Additionally, the Grant Administrator will work with department staff responsible for reporting and ensure that each report's supporting documentation is complete and ties to underlying subrecipient reports, the general ledger and grantor reports. All supporting documentation, along with a copy of the submitted report, will be stored in a central location to ensure that they are available for subsequent reviews and audits. This will be completed by June 30, 2024.

View Audit 293176

Finding 371615 (2023-001)

Significant Deficiency 2023

Claremont Unified School District

CA

Eligibility HUD Housing Programs School Nutrition Programs

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutritio...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023

View Audit 293142

Finding 371568 (2023-044)

Material Weakness 2023

State of West Virginia

WV

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

ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 For the one payment out of 40 whereby the provider requested and was paid for 13 non-traditional days although records indicated that only 11 of the days...

ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 For the one payment out of 40 whereby the provider requested and was paid for 13 non-traditional days although records indicated that only 11 of the days were non-traditional, the West Virginia Department of Health and Human Resources, Bureau for Family Assistance (BFA), agrees that the condition resulted in an overpayment of $12.00. The BFA Case Manager entered 13 non-traditional days in the Family and Children Tracking System (FACTS), but the record indicated that only 11 days were non-traditional days. Per WV Child Care Policy and Procedures: 8.3.1. Worker Error Improper payments due to worker error are defined as payments that should not have been made, or that were made in an incorrect amount due to worker error in determining and verifying eligibility, and/or calculation and input of information into the Family and Children’s Tracking System (FACTS). Incorrect amounts include overpayments, underpayments and inappropriate denials of payment. 8.3.1.1. Examples of worker error: A. The child care regulatory specialist enables the “accreditation” box, allowing the provider to receive an extra $4 per day, when the provider has not achieved accreditation, and is not entitled to the enhanced rate. B. The case manager enters an incorrect number of days when entering information from the payment form into FACTS. C. The case manager enters more time on the child care assessment than the client’s work or school schedule supports. D. The case manager fails to verify income, school enrollment, or special needs status. 8.3.1.2. Repayment of an improper payment due to CCR&R worker error is not mandatory regardless of the amount. The BFA Division of Early Care and Education employs Child Care Policy Specialists who visit contracted Resource and Referral Agencies to monitor and audit both electronic and hard records. Training and coaching also takes place during these visits. These visits continued throughout the reporting period. The BFA will evaluate the effectiveness of the current training programs for the use of the FACTS system (and subsequently for the West Virginia People's Access to Help (PATH) system) for CCDF payments. Furthermore, the BFA will follow established policies and procedures to ensure client information is appropriately obtained and maintained and that all data is input accurately. For the payment whereby the $3.00 daily supplement was not included in the calculation or paid, although the documentation in the eligibility system indicated that the child was covered under a CPS Safety Plan, this was not in fact a CPS Safety Plan case. The CPS Safety Plan was being used as a temporary means to address an executive order regarding COVID-19 and grant eligibility to essential workers who would otherwise not have qualified for the child care subsidy assistance due to their monthly income being above the Federal Poverty Level but below 85% of the State Median Income. The payment in question was in March 2023. Via a case assessment on November 1, 2023, this case [and other similar cases] were approved in the eligibility system as formalized Policy Exceptions rather than being selected as part of a CPS Safety Plan.

View Audit 293105 Questioned Costs: $1

Finding 371560 (2023-053)

Material Weakness 2023

State of West Virginia

WV

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303

ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.659 The issues identified in the finding were due to a broad number of child welfare workers having access to select “Non-Recurring Adoption Expense” (NRAE) when issuing a demand payment throu...

ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.659 The issues identified in the finding were due to a broad number of child welfare workers having access to select “Non-Recurring Adoption Expense” (NRAE) when issuing a demand payment through the eligibility system, causing the incorrect funding to be used. Two of the payments identified were manually entered to replace lost payments. The initial payments covered multiple children, but the replacement payment only identified one child’s name. For the Adoption Program, the DHHR phased in a new information technology system for determining eligibility, making payments, maintaining documentation, etc. during the State Fiscal Year 2023. The name of the new system is PATH (People & Access to Help). The PATH system replaced the Family and Children & Tracking System (FACTS). The PATH system will have additional controls and levels of review as compared with the FACTS system. For example, as specific to this finding, the ability to select NRAE when issuing a demand through PATH has been localized to adoption subsidy unit staff within the central office of the DHHR Bureau for Social Services.

View Audit 293105 Questioned Costs: $1

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