Corrective Action Plans

Finding 547043 (2024-005)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

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

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413

Finding 547042 (2024-004)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

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

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413

Finding 547041 (2024-003)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

Questioned Costs Internal Control / Segregation of Duties Eligibility

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413 Questioned Costs: $1

Finding 547034 (2024-005)

Material Weakness 2024

Mount Vernon Community School Corporation

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and ex...

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

View Audit 351407

Finding 547016 (2024-001)

Significant Deficiency 2024

City of Beverly

MA

Allowable Costs / Cost Principles Reporting Significant Deficiency

Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting por...

Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting portal by the Finance Director. Any variances or adjustments that are necessary from the Trial balance will be clearly documented for reconciliation and confirmed by the City Auditor as accurate. Upon confirmation, the Finance Director will submit the report. Planned Implementation Date of Corrective Action: Quarter 1, 2025 report (due by April 30th, 2025) Person Responsible for Corrective Action: City Auditor Finance Director

View Audit 351403

Finding 547015 (2024-002)

Significant Deficiency 2024

Weavers Way Community Fund Inc.

PA

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

To address the increase in the Organization’s activities under this program, the Certified Management Accountant of Weavers Way Community Fund, Inc. will send a performance report to the Department of Housing and Urban Development.

View Audit 351400

Finding 547013 (2024-001)

Material Weakness 2024

Marvell School District

AR

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

Reference number: 2024-001 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR part 200, subpart E Corrective Action: The Superintendent Prong Tran, Director of Finance, Scott McRae and Operations Manager Vicki Jones will closely review all coding and ensure that all emplo...

Reference number: 2024-001 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR part 200, subpart E Corrective Action: The Superintendent Prong Tran, Director of Finance, Scott McRae and Operations Manager Vicki Jones will closely review all coding and ensure that all employees are coded correctly according to funds, salary schedules and the correct calendars. Contact Person: Scott McCrae and Vicki Jones Anticipated Completion Date: June 30, 2025

View Audit 351398 Questioned Costs: $1

Finding 547010 (2024-003)

Significant Deficiency 2024

Independent School District No. 601

MN

Internal Control / Segregation of Duties

2024-003 Finding 1. Correcting Plan The District will file each employee’s approved wage rate in their respective personnel file. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent,...

2024-003 Finding 1. Correcting Plan The District will file each employee’s approved wage rate in their respective personnel file. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent, Todd Selk, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP The District will implement November 1, 2024 5. Plan to Monitor Completion of CAP The superintendent will monitor completion of the CAP.

View Audit 351392

Finding 547006 (2024-006)

Material Weakness 2024

West Noble School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: W...

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Operations Officer will prepare the reports and have the Curriculum Director review for accuracy. Anticipated Completion Date: July 1, 2026

View Audit 351382

Finding 546996 (2024-004)

Material Weakness 2024

West Noble School Corporation

IN

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

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the fin...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review the directly certified student list from the state and verify that is correctly entered into the school’s software. The Chief Financial Officer will review the list from the state and review the list that is inputted into the school’s software to ensure accuracy. Anticipated Completion Date: September 30, 2025

View Audit 351382

Finding 546984 (2024-001)

Significant Deficiency 2024

Northern Tier Community Action CORP

PA

Eligibility Internal Control / Segregation of Duties

Northern Tier Community Action Corporation concurs with the audit finding. The Organization did not maintain all client information in accordance with the requirements set forth by the grantor Agency. The Weatherization Department of the Organization had employee turnover in the 2023/2024 Fiscal Y...

Northern Tier Community Action Corporation concurs with the audit finding. The Organization did not maintain all client information in accordance with the requirements set forth by the grantor Agency. The Weatherization Department of the Organization had employee turnover in the 2023/2024 Fiscal Year including the Director of Weatherization, which caused a disruption in maintain client files. The Organization has reviewed the current system for maintaining files and identified any gaps in compliance with the grantor Agency requirement. The Organization then developed and implemented controls for maintaining client files that align with the grantor Agency’s requirements and provided training to all relevant personnel. This will ensure that the Organization is in compliance with all guidelines set forth by the grantor Agency. Northern Tier Community Action Corporation has implemented the above controls as of the report date.

View Audit 351363

Finding 546982 (2024-004)

Significant Deficiency 2024

Municipality of Catano

PR

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accorda...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2024-004 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: March 2025 Responsible persons: • Person responsible for the implementation: Mrs. Erika J. Acevedo, Program Accountant • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

View Audit 351358

Finding 546980 (2024-003)

Significant Deficiency 2024

Municipality of Catano

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.1

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accorda...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2024-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: March 2025 Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

View Audit 351358

Finding 546978 (2024-005)

Significant Deficiency 2024

City of Newton, Massachusetts

MA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing a...

Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented immediately.

View Audit 351352

Finding 546975 (2024-002)

Material Weakness 2024

City of Newton, Massachusetts

MA

Questioned Costs Cash Management Reporting

Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the...

Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the meal count data from Mosaic, the point-of-sale software, directly into the DESE portal. That upload is done by the Business Operations Analyst and then approved by the Director of Business Operations, which removes substantial exposure for human error during data entry and creates two levels of review prior to approval and submission. The other five discrepancies between the source counts and what was submitted for the DESE claim was to address identified human error in advance to ensure that the monthly claim was accurate. For the September 2023 error, Newton has submitted a Claim Adjustment Form to DESE to provide guidance for the necessary action steps. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: The internal controls to reduce data entry errors have been implemented and are consistently being used. DESE will provide guidance for the Claim Adjustment Request to address the September 2023 error, which Newton will then implement.

View Audit 351352 Questioned Costs: $1

Finding 546972 (2024-006)

Material Weakness 2024

Farrell Area School District

PA

Internal Control / Segregation of Duties Material Weakness Reporting

Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a...

Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a centralized, documented review process for all federal expenditure tracking. To address turnover-related gaps and avoid data inconsistency: o Internally prepared spreadsheets will be reconciled monthly and locked once reviewed o All federal award-related spreadsheets will be reviewed by a staff member other than the preparer o Changes to prior-year data will require approval and documentation o A documented checklist will be used for month-end reconciliations. Additionally, the Business Manager will oversee staff training on federal compliance requirements related to documentation and review processes.

View Audit 351351

Finding 546967 (2024-005)

Material Weakness 2024

Farrell Area School District

PA

Material Weakness Reporting School Nutrition Programs § 200.502 § 200.510

Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and...

Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) in compliance with 2 CFR 200.51 0(a). These procedures will: o Identify all sources of federal revenue o We have added the assigned federal funding source codes to our district budget operation in CSIU, which will now allow us to track these expenditures back to our internally controlled spreadsheets as verification of expenditures. o Track expenditures using dedicated account codes in the general ledger o Assign responsibility for monthly reconciliation and schedule preparation o Include a secondary review of the SEFA by someone other than the preparer The Business Office will undergo training on SEFA requirements and reconciliation practices. These changes will ensure complete and accurate reporting of federal expenditures for all future reporting periods.

View Audit 351351

Finding 546963 (2024-003)

Material Weakness 2024

Whitko Community School Corporation

IN

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

FINDING 2024-003 Finding Subject: Title I Grants to Local Education Agencies - Special Tests and Provisions - Assessment System Contact Person Responsible for Corrective Action: Caleb Logan, Corporation Testing Coordinator Contact Phone Number and Email Address: (260) 367-3677 caleb.logan@whitko.org...

FINDING 2024-003 Finding Subject: Title I Grants to Local Education Agencies - Special Tests and Provisions - Assessment System Contact Person Responsible for Corrective Action: Caleb Logan, Corporation Testing Coordinator Contact Phone Number and Email Address: (260) 367-3677 caleb.logan@whitko.org . Views of Responsible Official: We concur with this finding. Summary of Finding: School Corporation is required to obtain and store the completed Indiana Testing Security and Integrity Agreements for the entire staff. The School Corporation Testing Coordinator is responsible to gather all completed forms from each building for all staff and to store them. The Corporation Testing Coordinator during this audit period was a former employee of the School Corporation. The files of the Indiana Testing Security and Integrity Agreements were unable to be located from the former Testing Coordinator’s files (electronic or printed). The School Corporation had a process with the distribution, completion, and storage of the Indiana Testing Security and Integrity Agreements. However, there was ineffective internal controls and additional oversight in place to prevent these files from being recovered. Description of Corrective Action Plan: At the Beginning of each school year, the Testing Coordinator will distribute the Indiana Testing Security and Integrity Agreements to all staff through each Building Administrator. Employee completed agreements will be returned to the Building Administrator. Each Building Administrator will store these agreements for their building, and in turn will provide a copy to the School Corporation Testing Coordinator. The Testing Coordinator will verify that all staff have completed the agreement with a staff check sheet. The Corporation Testing Coordinator will follow up with any employee who has not completed an agreement. Staff hired during the school year are required to complete the agreement as well. The Testing Coordinator has both a hard paper copy as well as a scanned pdf file saved for all the completed agreements. At the end of the school year, the hard copy of all employees along with the check sheet will be stored in the central office secured storage room. Anticipated Completion Date: Immediately

View Audit 351347

Finding 546955 (2024-007)

Significant Deficiency 2024

City of Sheridan, Wyoming

WY

Reporting Internal Control / Segregation of Duties § 200.303 § 200.327

Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: Due to personnel changes, obtaining authorization to access the reporting site proved to be a challenging and time-consuming process. To prevent similar issues in the future, a cross-training pr...

Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: Due to personnel changes, obtaining authorization to access the reporting site proved to be a challenging and time-consuming process. To prevent similar issues in the future, a cross-training program and centralized task list are being developed to ensure multiple staff members are familiar with all tasks and have backup access to logins when available. Proposed Completion Date: June 30, 2025

View Audit 351336

Finding 546954 (2024-002)

Significant Deficiency 2024

Furman University

SC

Questioned Costs Student Financial Aid Significant Deficiency

Federal Eligibility Recommendation: We recommend that during the financial aid package review, additional procedures are put in place to ensure that student awards are appropriately calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action...

Federal Eligibility Recommendation: We recommend that during the financial aid package review, additional procedures are put in place to ensure that student awards are appropriately calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The employee who committed the errors is no longer employed by Furman University. Based on federal regulations, citied in “Correcting Direct Subsidized Loan or Direct Unsubsidized Loan awarding errors” in Volume 8, Chapter 3 of the FSA Handbook: “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” Furman University will continue to conduct regular training sessions for all financial aid counselors. These sessions focus on the latest federal and state regulations, including updates to Title IV guidelines, eligibility criteria, and documentation requirements. This ongoing training is crucial for maintaining our counselors' knowledge and effectiveness in managing financial aid processes. Furman University will perform an internal audit sample each month in conjunction with the completion of monthly reconciliations to ensure compliance with subsidized loans. Furthermore, all financial aid counselors are required to complete the “FSA Coach” training, an online resource provided by Federal Student Aid. This tool enhances their understanding of federal guidelines and best practices. To ensure future compliance, the Director of Financial Aid will conduct periodic internal audits. These audits will include a review of student files, application processes, and disbursement procedures to verify adherence to regulatory requirements. Additionally, the Director of Financial Aid will collaborate with a PowerFaids software consultant to explore the feasibility of generating specific reports that can monitor potential over awards of need-based aid. This proactive approach will help us identify and address any discrepancies promptly. Name(s) of the contact person(s) responsible for corrective action: Andrea Byrd Planned completion date for corrective action plan: 12/01/2024

View Audit 351333 Questioned Costs: $1

Finding 546953 (2024-001)

Significant Deficiency 2024

Furman University

SC

Student Financial Aid Reporting Significant Deficiency

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit findin...

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Furman University added additional enrollment reporting dates in April and July to address the identified over 60-day gap. Specifically, we have incorporated two new reporting dates in April 2025 and July 2025. These dates are now part of our reporting schedule for the 2024-25 academic year and will continue to be included in the transmission schedule moving forward. Additionally, the University Registrar will provide the Senior Associate Director of Financial Aid with the annual enrollment reporting dates at the beginning of each academic year to ensure ongoing compliance. Name(s) of the contact person(s) responsible for corrective action: James Patton and Melissa Barnette Planned completion date for corrective action plan: 08/26/2024

View Audit 351333

Finding 546938 (2024-001)

None 2024

Sociedad Para Asistencia Legal De Puerto Rico, Inc.

PR

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but ar...

Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but are not expenditures incurred by the Organization. Views of Responsible Officials and Corrective Actions Justification: The organization acknowledges that four (4) out of twenty-four (24) bi-weekly reports for ALN 21.027 were submitted late. The report due September 1, 2023, was submitted on September 6, 2023. This delay was due to an unintentional error involving a mismatch of dates, as explained in an email to the grantor on the same day as the submission. The grantor acknowledged receipt of the report. Furthermore, the organization maintains continuous communication with the grantor to validate eligible expenses. The grantor has not verbalized any major discrepancies related to late submissions in the monthly stakeholder meetings due to our continuous communication with the grantor. While the organization recognizes the late submission, it asserts that the delay was minor and promptly addressed. Root Cause Analysis and Immediate Corrective Actions: • Objective: Identify underlying causes of late submissions and report errors. o Conduct interviews with staff involved in reporting processes. o Review workflow for report preparation, approval, and submission. o Analyze gaps in understanding compliance requirements (e.g., misclassification of FICA/Medicare retentions). Corrective Actions: The organization has taken steps to improve internal controls and prevent future late submissions. To address and prevent the issues identified in Finding No. 2024-001, the following corrective actions are the following: Establish Formalized Oversight and Monitoring: ● Implement a system of checks and balances for report preparation and submission. ● Designate specific personnel responsible for reviewing reports before submission to ensure accuracy and timeliness. ● Develop a tracking mechanism (e.g., a checklist or calendar) to monitor report deadlines and submission status. Enhance Internal Controls: ● Develop and document written policies and procedures for the bi-weekly reporting process. This documentation should clearly outline: ○ Report preparation guidelines, following 2 CFR 200.302. ○ Data sources and required supporting documentation, following 2 CFR 200.300. ○ Review and approval processes, following 2 CFR 200.303. ○ Submission deadlines and methods, following grantor requirements and 2 CFR 200.343. ● Provide training for staff responsible for preparing and submitting reports, emphasizing the importance of accuracy and adherence to deadlines, following 2 CFR 200.303. ● Implement a process for regular reconciliation of report data with underlying financial records to ensure accuracy, following 2 CFR 200.302. Improve Report Accuracy: ● Clearly define what constitutes an allowable expenditure for the federal program, in accordance with 2 CFR Part 200 Subpart E. ● Provide specific guidance and examples to staff to prevent the inclusion of non-expenditure items (like employee payroll tax retentions) in reports. ● Implement automated checks or validation rules in the reporting process to detect and prevent errors. ● Conduct pre-submission audits by a compliance officer to review expenditures against federal guidelines, including OMB Circular A-133. ● Develop a retroactive correction protocol to address past errors, including communication with the grantor if amendments are Timely Submission of Reports: ● Implement a system of reminders for report deadlines. ● Establish clear consequences for failing to submit reports on time. ● Evaluate the current reporting timeline and assess if adjustments are needed to ensure timely submission. Communication with Grantor: ● Proactively communicate with the grantor regarding the corrective actions being taken to address the findings. ● Provide the grantor with a timeline for implementation of these actions. By implementing these corrective actions, Sociedad para Asistencia Legal de Puerto Rico, Inc. can improve the accuracy and timeliness of its bi-weekly reporting, ensure compliance with federal requirements, and mitigate the risk of penalties or other adverse actions. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor A. Díaz Pomales - Director de Finanzas Anticipated Completion Date: March 26, 2025

View Audit 351297

Finding 546923 (2024-002)

Significant Deficiency 2024

Margaret B. MacK Supportive Housing Corporation Hud Proj. #017-Hd038

CT

Internal Control / Segregation of Duties Significant Deficiency

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management review the amount billed to the Project and compare it to the timesheet to ensure that the amount billed is accurate. Explanation of disagreement with audit finding: There ...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management review the amount billed to the Project and compare it to the timesheet to ensure that the amount billed is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although other controls assist to safeguard and mitigate compensation errors, the property manager will ensure that all time sheets are properly approved prior to payment, and if necessary the VP of Operations or the President of the managing agent will provide further assurance of internal controls through reviews. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: May 30, 2025

View Audit 351285

Finding 546922 (2024-001)

Significant Deficiency 2024

Margaret B. MacK Supportive Housing Corporation Hud Proj. #017-Hd038

CT

Internal Control / Segregation of Duties Significant Deficiency

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend management to ensure that required deposits are made 60 days following the fiscal year-end. Explanation of disagreement with audit finding: There is no disagreement with the audit findin...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend management to ensure that required deposits are made 60 days following the fiscal year-end. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A residual receipts account has been established and required funds have been deposited as of February 22, 2024, and June 20, 2024. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: Completed on June 20, 2024.

View Audit 351285

Finding 546921 (2024-002)

Material Weakness 2024

Puerto Rico Department of Economic Development and Commerce

PR

Questioned Costs Eligibility Internal Control / Segregation of Duties

Findings and Questioned Costs Relating to Federal Awards: Energy Incentive Program Disbursement to Ineligible Providers and Beneficiaries. Similar to prior year finding 2023-003, the program “Apoyo Energético”, funded by the American Rescue Plan Act (ARPA), that resulted in this finding concluded ea...

Findings and Questioned Costs Relating to Federal Awards: Energy Incentive Program Disbursement to Ineligible Providers and Beneficiaries. Similar to prior year finding 2023-003, the program “Apoyo Energético”, funded by the American Rescue Plan Act (ARPA), that resulted in this finding concluded early 2023, which lack of a complete and robust operational guidance. The guidance used to manage the process were simple, not quite restrictive, and with little internal controls for both suppliers and beneficiaries. DDEC has adopted guidelines for both suppliers and beneficiaries that are more restrictive, and specific with internal regulations that ensure data retention and storage. A second initiative of this program, being “Apoyo Energético 2.0” commenced April 2024, which is funded by a CDBG-DR funds, for registration of potential suppliers and are following the guidelines issued. No findings were noted related to this program for which controls were enhanced, as a result corrective actions related to the 2023 finding.

View Audit 351279 Questioned Costs: $1

Corrective Action Plans

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