Corrective Action Plans

Finding 528180 (2024-002)

Significant Deficiency 2024

Housing Authority of the City of Allentown

PA

Questioned Costs HUD Housing Programs Eligibility

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: No Significant Defi...

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 1,634 units. Of a sample size of twenty-nine (29) tenant files, the following was noted: • Verification of income was missing in 1 file • Lead based paint form was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: $8,500 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Julio Guridy, Executive Director, will be responsible to implement this corrective action by June 30, 2025.

View Audit 346230 Questioned Costs: $1

Finding 528161 (2024-003)

Material Weakness 2024

Metropolitan School District of Boone Township

IN

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

Finding 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelsey Rodriguez and Beverly Hindes Contact Phone Number: 574-229-2209 and 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective ...

Finding 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelsey Rodriguez and Beverly Hindes Contact Phone Number: 574-229-2209 and 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will ensure compliance with the Food Service Director (NIESC) Kelsey Rodriguez, with the student determination guidelines to receive free or reduced priced meals. The designee will review and sign off. Additionally, all documentation will be maintained. Anticipated Completion Date: March 31, 2025

View Audit 346211

Finding 528145 (2024-004)

Material Weakness 2024

Clay Community Schools

IN

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The school corporation had not designed or implemented a system of internal controls to ensure that the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) wer...

FINDING 2024-004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The school corporation had not designed or implemented a system of internal controls to ensure that the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared by the Director of Business Affairs without a documented oversight, review or approval process in place to prevent, or detect and correct, errors. It is recommended that the school corporation’s management establish internal controls to ensure compliance with the grant agreement and Reporting compliance requirement. Any and all future ESSER reports submitted in Jotform should document an oversight, review or approval process by someone other than the Director of Business Affairs. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When completing data reporting, as requested by the state, for federally funded emergency relief grant funding, the Director of Business Affairs will compile the data necessary to complete the reporting. The data will then be presented to the appropriate member of corporation management for review – data related to student enrollment, eligibility, or other information will be presented to the corporation Data Coordinator. Data related to employee positions, or other employment related data, will be presented to the Director of Human Resources. All other data, including but not limited to corporation financial data, will be presented to the Assistant Superintendent. Anticipated Completion Date: Immediately, upon next required data submission for Education Stabilization Fund reporting.

View Audit 346210

Finding 528141 (2024-003)

Material Weakness 2024

Clay Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests & Provisions – Supplement Not Supplant Summary of Finding: During the Audit period, there were three Title I applications. One of the three applicable grant year applications included information in the su...

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests & Provisions – Supplement Not Supplant Summary of Finding: During the Audit period, there were three Title I applications. One of the three applicable grant year applications included information in the supplement, not supplant section. The other two applications were blank for this section. Documentation of the calculations and per pupil expenditure comparisons were not provided for the audit. Additionally, the Indiana Department of Education (IDOE) monitors compliance with this requirement using Comparability Reports, which compare Full-Time Equivalent (FTE) staff positions for Title I schools to FTE staff positions for non-Title I schools within the school corporation. Although IDOE determined that FTE staff positions were comparable in the 2022, 2023, and 2024 Comparability reports, the school corporation was unable to provide supporting documentation for the FTE staff numbers reported to IDOE. It is recommended that the school corporation adopt and document an acceptable methodology to allocate State and local funds to schools. In addition, it is recommended the calculation of such methodology and any other supporting documentation be retained for audit. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Title I Grant Coordinator, currently Dr. Brady Scott, will monitor this requirement using Comparability reports, as an option considered by the Indiana Department of Education (IDOE). In doing so, the Grant Coordinator will complete a list of FTE staff positions for each Title I school, as well as non-Title I school according to the methodology designed for school corporations as communicated by the IDOE. The Grant Coordinator will confer with the corporation Payroll Specialist (currently Mary Mershon) to ensure accuracy of the data used to complete the reporting, and both the Grant Coordinator and the Director of Business Affairs will maintain a record of the data used to complete the report. Anticipated Completion Date: July 2025

View Audit 346210

Finding 528139 (2024-001)

Material Weakness 2024

Clay Community Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary porti...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary portion of the Title I application, which is how Title I funding is determined. It is recommended that the school corporation’s management strengthen its system of internal controls to ensure that data in the Eligible School Summary section of the Title I application has been verified for accuracy to the corresponding period’s Pupil Enrollment (PE) report data. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Real time reporting will be compiled by the Data Management Specialist (currently Stephanie Jackson) and will be reviewed by the Title I Grant Coordinator (currently Dr. Brady Scott). Annual Financial reports will be compiled by the Director of Business Affairs (currently John Szabo), and prior to submission those reports will be reviewed by the Title I Grant Coordinator. Anticipated Completion Date: July 2025

View Audit 346210

Finding 528137 (2024-001)

Significant Deficiency 2024

Menomonie Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 346209

Finding 528134 (2024-002)

Significant Deficiency 2024

Williamsburg Area Improved Dwellings, Inc.

PA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

2024-002 Inadequate Documentation of the Components of Internal Control Corrective Action Plan WAID management will consider documenting its policies and procedures in the event duties need to be transitioned. Responsible Party: Michelle Ross, Manager: (814) 832-3212 Anticipated Completion Date: Jun...

2024-002 Inadequate Documentation of the Components of Internal Control Corrective Action Plan WAID management will consider documenting its policies and procedures in the event duties need to be transitioned. Responsible Party: Michelle Ross, Manager: (814) 832-3212 Anticipated Completion Date: June 30, 2025

View Audit 346200

Finding 528133 (2024-001)

Significant Deficiency 2024

Williamsburg Area Improved Dwellings, Inc.

PA

Internal Control / Segregation of Duties

2024-001 Segregation of Duties Corrective Action Plan Compensating controls are believed to be in place to effectively mitigate risks involved with cash disbursements. WAID will also consider compensating controls to effectively mitigate the risks surrounding cash receipts and cash management. These...

2024-001 Segregation of Duties Corrective Action Plan Compensating controls are believed to be in place to effectively mitigate risks involved with cash disbursements. WAID will also consider compensating controls to effectively mitigate the risks surrounding cash receipts and cash management. These controls will include: • The review and reconciliation of monthly cash receipts to the bank statements by a member of the Board. Responsible Party; Michelle Ross, Manager: (814) 832-3212 Anticipated Completion Date: Corrective Action Plan is in place but the mitigating control does not solve the segregation of duties issue. -

View Audit 346200

Finding 527045 (2024-001)

Significant Deficiency 2024

Shawano Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size.

View Audit 346137

Finding 527043 (2024-002)

Significant Deficiency 2024

Oak Ridge Housing Authority

TN

HUD Housing Programs Cash Management Significant Deficiency

2024-002 Utilities Allowance Calculation ORHA management is in agreement with this finding that multiple HUD Forms 50058 had utility allowances calculated not in accordance with HUD regulations. ORHA experienced a complete staff turnover in the Section 8/HCV department in 2023 and was without full s...

2024-002 Utilities Allowance Calculation ORHA management is in agreement with this finding that multiple HUD Forms 50058 had utility allowances calculated not in accordance with HUD regulations. ORHA experienced a complete staff turnover in the Section 8/HCV department in 2023 and was without full staff capacity for most of 2024. During that time frame it was determined that utility allowances were not entered correctly into the housing software. By September 30, 2025, and internal audit of all tenant files will be completed to review utility allowance calculations and correct if necessary. ORHA management commits to accurate utility allowance calculations moving forward. Housing Choice Voucher Director, Alistair Blair, will be responsible for ensuring the utility allowance review and corrections are made.

View Audit 346128

Finding 527042 (2024-001)

Significant Deficiency 2024

Oak Ridge Housing Authority

TN

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

2024-001 Housing Quality Standards Inspection/HQS Enforcement: ORHA management is in agreement with this finding. There were transitions in Housing Qaulity Standards to INSPIRE regulations and the appropriate regulations in place at the time were not followed. ORHA staff will recieve training in the...

2024-001 Housing Quality Standards Inspection/HQS Enforcement: ORHA management is in agreement with this finding. There were transitions in Housing Qaulity Standards to INSPIRE regulations and the appropriate regulations in place at the time were not followed. ORHA staff will recieve training in the new INSPIRE regulations to ensure that all life- threatening items are addressed with the 24-hr period. All training will be completed by the end of the first quarter of 2025. ORHA management commits to life-threatening items being addressed with the 24- hr period moving froward, Executive Director, Maria Catron, will be responsible for ensuring staff is up to date on current INSPIRE training.

View Audit 346128

Finding 527036 (2024-001)

Significant Deficiency 2024

Postville Community School District

IA

Internal Control / Segregation of Duties

Internal control deficiencies: See Finding 2024-001 Recommendation: The District should review the operating procedures of the District offices to obtain the maximum internal control possible under the circumstances utilizing currently available staff. While we do recognize that the District is n...

Internal control deficiencies: See Finding 2024-001 Recommendation: The District should review the operating procedures of the District offices to obtain the maximum internal control possible under the circumstances utilizing currently available staff. While we do recognize that the District is not large enough to permit a segregation of duties for effective internal controls, we believe it is important the Board be aware that this condition does exist. Action Taken: Management is cognizant of this limitation and will implement additional procedures where possible.

View Audit 346119

Finding 527035 (2024-001)

Significant Deficiency 2024

Mount Mansfield Unified Union School District

VT

Allowable Costs / Cost Principles School Nutrition Programs Internal Control / Segregation of Duties § 200.303 § 200.430

MMUUSD Preliminary Corrective Action Plan (Concerning Finding 2024‐001; Activities Allowed and Allowable Costs) Contact Person Responsible for Corrective Action: Nicole Fortier, Director of Finance and Operations Corrective Action: During our audit there was one instance identified where MMUUSD over...

MMUUSD Preliminary Corrective Action Plan (Concerning Finding 2024‐001; Activities Allowed and Allowable Costs) Contact Person Responsible for Corrective Action: Nicole Fortier, Director of Finance and Operations Corrective Action: During our audit there was one instance identified where MMUUSD overpaid an employee under the Food Service program at a rate of pay different than the stated rate for a Food Service Substitute. To be more specific, the Food Service substitute rate was transposed and the employee was paid $16.62 ($0.10 more) instead of the stated substitute rate of $16.52. The first step in our corrective action plan was a review with our Senior Payroll Specialist of the error, and to reiterate the importance of verifying the correct hourly rate being input for our substitutes. This step has already been completed. Additionally, we are in the process of implementing a more thorough payroll review process, which will include a preliminary review by Christal Clark, Accountant in the Business Office. Given that the payment of substitutes is such a manual process and we cannot utilize our employee timesheet software for paying them, we will also perform periodic reviews of all substitute payments to verify that the rate of pay is in line with the Sub Pay agreement for that respective Fiscal Year. If any discrepancies are noted, the employees will be made whole ASAP. We are currently performing periodic reviews of all substitute payments to verify the correct rate of pay is being used as of January 2025. We are in the process still of developing a payroll review process that works for us and is efficient. With Christal Clark being more involved in the payroll process on a biweekly basis, we are assessing whether this should be a post‐payroll review or mid‐payroll review. Anticipated Completion Date: 07/01/2025

View Audit 346118

Finding 526997 (2024-001)

Significant Deficiency 2024

Positively Third Street Housing Development Fun Co., Inc.

NY

HUD Housing Programs Student Financial Aid Cash Management

Project Legal Name: Positively Third Street HDFC HUD Project No.: 012-EE287 Audit Firm: CohnReznick LLLP Period covered by the audit: July 1, 2023 through June 30, 2024 Corrective Action Plan prepared by: Name: Matthew LoCurto Position: CFO Telephone Number: 212-453-5257 The following is a recommend...

Project Legal Name: Positively Third Street HDFC HUD Project No.: 012-EE287 Audit Firm: CohnReznick LLLP Period covered by the audit: July 1, 2023 through June 30, 2024 Corrective Action Plan prepared by: Name: Matthew LoCurto Position: CFO Telephone Number: 212-453-5257 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-1 a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation put forth by the auditors Action(s) Taken or Planned The $93,461 of residual receipts noted in the 2023 audit and cited as a finding in the 2024 report was deposited into the residual receipt account on January 10, 2025. Our new Controller has established procedures to ensure that that the proceeds stemming from the retroactive budget based rent increase are used for their intended purpose prior to the end of the fiscal year that they are received. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations N/A

View Audit 346099

Finding 526986 (2024-001)

Significant Deficiency 2024

Realife Cooperative of New Ulm

MN

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 346074

Finding 526983 (2024-001)

Significant Deficiency 2024

Community Health and Wellness Center of Greater Torrington, Inc.

CT

Special Tests & Provisions Subrecipient Monitoring Eligibility

FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCIES Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center P...

FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCIES Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Grants for New and Expanded Services Under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 2024.001 Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. 1 Action Taken Education will be provided for the staff who complete the applications, this will include a quiz to measure the staff's knowledge of the process and mathematical calculations. Management has developed a tool called "How to Calculate Household Income for Processing Financial Assistance Applications" which includes step by step instructions for calculating household income. Prevention strategies have been implemented to prevent future occurrences of adverse events, which include monthly audits of the calculation of annual income for a minimum of 10% of the total number of patients who have completed a financial assistance application are being performed. The manager of the population health department will report audit results quarterly at the continuous quality improvement (CQI) committee meeting. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Joanne Borduas, CEO at (860) 387-0425

View Audit 346063

Finding 526969 (2024-002)

Significant Deficiency 2024

School City of Mishawaka

IN

School Nutrition Programs Eligibility Significant Deficiency § 200.303

FINDING 2024-002 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Food Service Director will print out the Direct Certification report and ...

FINDING 2024-002 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Food Service Director will print out the Direct Certification report and review for its accuracy. She will then provide the report to the Food Service Director for her review. After both individuals have reviewed the reports that were produced, they both will sign and date the reports to provide the documentation that the information was reviewed and verified. Anticipated Completion Date: This new process will begin at month end of February 2025.

View Audit 346062

Finding 526963 (2024-001)

Significant Deficiency 2024

School City of Mishawaka

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.332 § 200.403

FINDING 2024-001 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The amount transferred during the time period of July 1, 2024-December 31, 2024 will be...

FINDING 2024-001 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The amount transferred during the time period of July 1, 2024-December 31, 2024 will be transferred back to Fund 0800. This transfer will be done once the Form 9 for period 2 of 2024 is complete and the month of December is closed. An indirect cost rate for Fiscal Year 2026 has been applied for and this rate will be used to capture these costs from Fund 800 if approved beginning 7.1.2025. Anticipated Completion Date: The fund transfer back to Fund 0800 will occur by March 31, 2025. The claiming of the indirect cost rate will begin 7.31.2025 dependent upon the approval of the corporation’s indirect cost rate application.

View Audit 346062 Questioned Costs: $1

Finding 526954 (2024-003)

Material Weakness 2024

North Spencer County School Corporation

IN

Procurement, Suspension & Debarment School Nutrition Programs Internal Control / Segregation of Duties § 200.303

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not established internal controls over the suspension and debarment compliance requirement, specifically contracts with vendors that do not include the suspension and debarmen...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not established internal controls over the suspension and debarment compliance requirement, specifically contracts with vendors that do not include the suspension and debarment clause with the contract. Contact Person Responsible for Corrective Action: Jennifer Lindsey, School Lunch Director Contact Phone Number and Email Address: (812) 937-2400, jlindsey@nspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For contracts with vendors that do not include the suspension and debarment clause with the contract, the Food Service Director will provide documentation that she verified the vendor was not suspended or debarred to the Corporation Treasurer or governance for review/approval. Anticipated Completion Date: July 2025

View Audit 346048

Finding 526946 (2024-002)

Material Weakness 2024

Community School Corporation of Southern Hancock County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Sarah Gizzi, Business Manager Contact Phone Number and Email Address: (317) 861-4463 x1014, sgizzi@newpal.k12.in.us Condition and Context: An effective internal con...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Sarah Gizzi, Business Manager Contact Phone Number and Email Address: (317) 861-4463 x1014, sgizzi@newpal.k12.in.us Condition and Context: An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements: Reporting The School Corporation had not designed, nor implemented, a system of internal controls to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were prepared by the Deputy Treasurer and the Grant Administrator, then reviewed and approved by the Business Manager; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors was performed during the audit period. This resulted in errors on the ESSER I Year 3 from the original submission in April 2023 not being detected and corrected until July 2024. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The federal award reporting procedures and internal controls of New Palestine Community Schools have been improved to ensure all reporting documents will have a multistep review process to include a reviewer separate from the preparer. The reports will also have multiple signers documenting proper review of the information being reported, ensuring accuracy and compliance. Anticipated Completion Date: These procedures have been implemented effective immediately, March 3, 2025, and will be reflected on all future reports.

View Audit 346044

Finding 526903 (2024-002)

Material Weakness 2024

Clark-Pleasant Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.303

FINDING 2024-002 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions Summary of Finding: Three employees did not have a signed agreement on file to indicate required training was received over Special Tests and Provisions compliance requirement, Assessment Sy...

FINDING 2024-002 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions Summary of Finding: Three employees did not have a signed agreement on file to indicate required training was received over Special Tests and Provisions compliance requirement, Assessment System Security. Contact Person Responsible for Corrective Action: Brian Lovell Contact Phone Number and Email Address: 317-535-7579; blovell@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The corporation test coordinator will work with our Director of Operations to review these expectations and test security for all appropriate staff. Anticipated Completion Date: March 14, 2025

View Audit 346022

Finding 526895 (2024-003)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection repor...

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection reports were completely and accurately submitted. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number and Email Address: 812-866-6244 (o), 812-599-0627 (c), jwatson@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-003 includes, but is not limited to, the following: 􀁸 Beginning immediately, the grant coordinator will prepare the reports for any future ESSER reports. 􀁸 The reports prepared will be shared with Assistant Treasurer 1 for the initial review. Assistant Treasurer 1 will complete his/her review, adding comments and suggestions as needed. 􀁸 If corrections to the report are required: o Assistant Treasurer 1 and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with the grant coordinator. o The Grant Coordinator will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer reviews have been completed and indicates as such via eSignatures. 􀁸 Anticipated Completion Date: March 1, 2025􀀃

View Audit 345996

Finding 526891 (2024-002)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

School Nutrition Programs Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the S...

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the Special Tests and Provisions-Non-Profit School Food Service Accounts compliance requirement. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Katie King, Food Services Director Contact Phone Number and Email Address: 812-866-6254, kking@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-002 includes, but is not limited to, the following: 􀁸 Beginning immediately, Assistant Treasurer 1 will prepare a DocuSign envelope monthly with the following financial reports to be reviewed: o Appropriation Report o Expenditure Report o Revenue Report o Fund Detail Report o Fund Report 􀁸 The DocuSign Envelope will be routed to the Food Services Director, for the initial review. 􀁸 The Food Service Director will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 The DocuSign Envelope will then be routed to Assistant Treasurer 2 for an additional review. 􀁸 Assistant Treasurer 2 will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 If corrections to the report are required: o The Food Service Director and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with Assistant Treasurer 1. o Assistant Treasurer 1 will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer 2 reviews have been completed and indicates as such via eSignatures. 􀁸 After the above steps have been taken, the report will be submitted 􀁸 The Grant Coordinator indicates its completion by eSignature in the appropriate location. INDIANA STATE BOARD OF ACCOUNTS 33 􀀃 􀀃 Anticipated Completion Date: March 1, 2025

View Audit 345996

Finding 526878 (2024-003)

Significant Deficiency 2024

Sweet Briar Institute

VA

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Individual/s Responsible for Corrective Action Plan: Wanda Spradley, Director of Financial Aid Corrective Action Plan: The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 6...

Individual/s Responsible for Corrective Action Plan: Wanda Spradley, Director of Financial Aid Corrective Action Plan: The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56). The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified. The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid. Anticipated Completion Date: February 28, 2025

View Audit 345973

Finding 526877 (2024-002)

Significant Deficiency 2024

Sweet Briar Institute

VA

Internal Control / Segregation of Duties Special Tests & Provisions

Individual/s Responsible for Corrective Action Plan: Jaraka Waite, Human Resources Corrective Action Plan: The Institute agrees with the finding. Moving forward, when Student Employment payment information is entered into our Human Resource information system, the Institute will continuously che...

Individual/s Responsible for Corrective Action Plan: Jaraka Waite, Human Resources Corrective Action Plan: The Institute agrees with the finding. Moving forward, when Student Employment payment information is entered into our Human Resource information system, the Institute will continuously check timecards to ensure that the wages match the number of hours students work. Furthermore, the Institute will stay in communication with student supervisors to ensure they are approving timecards before payroll is processed. Anticipated Completion Date: May 31, 2025

View Audit 345973

Corrective Action Plans

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