Corrective Action Plans

Finding 529137 (2024-001)

Significant Deficiency 2024

Th, INC

WI

Internal Control / Segregation of Duties

Recommendation: We recommend the Organization adopt policies and procedures to ensure the accounting records are in compliance with generally accepted accounting principles. Additionally, procedures should remain for requiring the Organization’s management to review the drafted financial statements...

Recommendation: We recommend the Organization adopt policies and procedures to ensure the accounting records are in compliance with generally accepted accounting principles. Additionally, procedures should remain for requiring the Organization’s management to review the drafted financial statements with the accounting firm and take responsibility for the finalized financial statements. Management Response: TH, Inc's Administrator and Board recognize their responsibility for the financial statements. The following procedures have become written policy: - The administrator reviews and approves invoices and statements as they come in. -The Bookkeeper processes invoices and statements weekly, processing checks every other week. - A Board member and Administrator review and approve the checks and direct payments every other week. - Electronic payments are reviewed and approved monthly by a Board member and Administrator. - All financial reports are reviewed and approved by the Board at the monthly Board meetings.

View Audit 347099

Finding 529134 (2024-001)

Significant Deficiency 2024

Timothy L. Johnson Academy

IN

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.329

March 13, 2025 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Timothy L Johnson Academy Elementary school has already taken the following actions to address the FY2024 finding of noncompliance with Federal grant awards: 1. We transitioned to a new business services provid...

March 13, 2025 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Timothy L Johnson Academy Elementary school has already taken the following actions to address the FY2024 finding of noncompliance with Federal grant awards: 1. We transitioned to a new business services provider in FY2025, and part of that transition included a complete overhaul of our grants management. 2. As part of this transition, we created procedures that better integrated our grants management processes with our financial accounting processes. This already allows us to better track the differences in our reimbursement-based grants, cash-basis state reporting, and GAAP-based accounting principles. 3. We also now have a more transparent school-level view of all our grants, which adds a level of control while working with an outsourced business and grants service provider. 4. Dawn Starks and Brad Yoder were responsible on the school side for these procedure changes. Brian Anderson and Kim Tarin from the Center for Innovative Education Solutions were responsible for this as the new business and grants services provider.

View Audit 347076

Finding 529127 (2024-001)

Significant Deficiency 2024

Douglas Pointe III Associates, LLC

IN

Procurement, Suspension & Debarment HUD Housing Programs Reporting § 200.512

The Data Collection Form was submitted to the Federal Audit Clearinghouse on May 22, 2024, and management will submit the Data Collection Form timely going forward.

View Audit 347054

Finding 529126 (2024-002)

Material Weakness 2024

Knox Community School Corporation

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

FINDING 2024-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: I...

FINDING 2024-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context: The School Corporation paid $2,135,000 for HVAC and flooring improvements and $92,301 in concrete work at various locations using COVID-19 - Education Stabilization Funds grant funds. These capital improvements were added to the detailed listing of capital improvements; however, did not include a detailed description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds the title, and percentage of federal participation in the project costs for the federal award under which the property was acquired. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: AdTec does the inventory listing every two years and it will be placed on the Capital improvement listing. Anticipated Completion Date: Fall of 2025 during next inventory

View Audit 347048

Finding 529125 (2024-001)

Material Weakness 2024

Knox Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identif...

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The Annual Data Reports were prepared by School Corporation management and reviewed by someone other than the preparer, however, the review process in place did not prevent, or detect and correct, errors. During testing of the accuracy of the annual data reports, the following errors were noted: • The Year 2 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $2,219,321 for the period of July 1, 2021 through June 30, 2022 compared to underlying disbursement detail of $2,715,940. • The Year 3 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $224,309 for the period of July 1, 2022 through June 30, 2023 compared to underlying disbursement detail of $306,194. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There will be two people who look over the ESSER reports before submitting to the state to make sure they agree with the reports. Anticipated Completion Date: When next report is due.

View Audit 347048

Finding 529120 (2024-001)

Material Weakness 2024

Charleroi Area School District

PA

Cash Management School Nutrition Programs Internal Control / Segregation of Duties

Name of contact person: Mr. Joseph Gudac, Business Manager ...

Name of contact person: Mr. Joseph Gudac, Business Manager Corrective Action: We will follow our policy for ensuring the accuracy of meal counts before remitting the total meals to PDE. The district will implement a pre-submission review protocol to verify that monthly claims accurately reflect the meals served to eligible students. We also will develop a standardized checklist for reviewing and approving meal counts before submission and to ensure that discrepancies identified during review are promptly investigated and corrected. Anticipated Completion Date: The District will implement the above procedure immediately.

View Audit 347046

Finding 529112 (2024-001)

Significant Deficiency 2024

Chicago Commons Association

IL

Subrecipient Monitoring Cash Management Internal Control / Segregation of Duties § 200.305 § 200.516

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to v...

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to verify account updates; • Limited the amount of per vendor/subrecipient daily payments to our insurance limits, with verifications prior to releasing additional funds when the total payment exceeds the insurance limits; • Subrecipient payment receipt is verified by both the subrecipient and the Commons grants team; • Updated our policy and procedures to direct our subrecipients to request banking changes through our procurement system and not through email; and • Expanded implementation of our Kissflow procurement system across the organization, which includes new vendor process as well as a change of vendor information module. Vendor changes would be approved first by the program/department that works with the vendor prior to Finance approval. Completion Date With the exception of implementing the change of vendor information module in Kissflow, the above actions have all been completed by the date of this report. The projected completion date for Kissflow change of vendor information module is April 30, 2025. Responsible Party Dana Thomas, Chief Financial Officer Angela Allen, Vice President of Finance

View Audit 347007

Finding 529085 (2024-021)

Material Weakness 2024

State of North Dakota

ND

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.430

University System Response/Corrective Action Plan North Dakota State University: Agree. North Dakota State University agrees to certify federal payroll expenses in a timely manner. North Dakota State University implemented a new payroll certification system which went live Spring 2024. Previously,...

University System Response/Corrective Action Plan North Dakota State University: Agree. North Dakota State University agrees to certify federal payroll expenses in a timely manner. North Dakota State University implemented a new payroll certification system which went live Spring 2024. Previously, North Dakota State University utilized a manual effort reporting process as part of PeopleSoft. The new payroll certification process was built into Novelution Research Management System, which supports multiple aspects of grant management. Novelution allows PIs to review salary information and certify within the software, provides automated reminder emails, and provides a better tracking mechanism for compliance. There has been a learning curve in utilizing the new system, and during FY2025 we continued to refine the process and implement additional mechanisms to improve compliance. University of North Dakota: Agree. In accordance with University of North Dakota’s policy, we will remind pre-reviewers and certifiers of University of North Dakota's requirement for timely certification. As outlined in the policy, we will invoke the consequences for failing to timely certify, including removing uncertified payroll from a project. Contact Person: North Dakota State University: Karin Hegstad, Associate Vice President Finance & Administration University of North Dakota: Lauren Pite, Director Grants & Contracts Anticipated Completion Date: North Dakota State University: June 30, 2025 University of North Dakota: March 31, 2025

View Audit 346994 Questioned Costs: $1

Finding 529081 (2024-020)

Material Weakness 2024

State of North Dakota

ND

Questioned Costs Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303 § 200.317

University System Response/Corrective Action Plan Bismarck State College: Agree. On the published RFQ, Bismarck State College identified a selection committee composed of nine members with the registered engineer and registered architect listed as TBD, as these members had not yet been identified. T...

University System Response/Corrective Action Plan Bismarck State College: Agree. On the published RFQ, Bismarck State College identified a selection committee composed of nine members with the registered engineer and registered architect listed as TBD, as these members had not yet been identified. The selection committee later downsized to seven members. Bismarck State College understands that an amendment to the RFQ should have been released. Four selection committee members evaluated the RFQ submittals, three from Bismarck State College and a licensed contractor. Bismarck State College understands that all seven members must be present during the initial review. Bismarck State College did have all seven members present, including a registered engineer and registered architect during the interviews and final decision when selecting the CMAR. Bismarck State College has reviewed the selection process and will adhere to ensure compliance for construction projects. Minot State University: Minot State agrees with the audit recommendation in that not all the proper steps were completed in the procurement of architect and Construction Management at Risk (CMaR) services and will ensure proper procedures are followed going forward. Upon review, Minot State is confident that all Hartnett Hall remodel project expenses are appropriate, allowable, and allocable to the project. University of North Dakota: Agree. The University of North Dakota's solicitation templates for A/E and CMAR have been moved to an electronic system effective 2023, and our templates were updated with the correct proposal criteria at that time. Contact Person: Bismarck State College: Sonya Koble – Chief Financial Officer Minot State University: Krista Lambrecht, VP for Administration & Finance University of North Dakota: Tom Scrivener, CPO Anticipated Completion Date: Bismarck State College: September 2024 Minot State University: Immediately University of North Dakota: Completed.

View Audit 346994 Questioned Costs: $1

Finding 529060 (2024-008)

Significant Deficiency 2024

State of North Dakota

ND

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services disagrees with the finding. The federal regulations do not explicitly mandate the separation of duties between employees conducting audits and those processing claims. While 42 CFR 456...

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services disagrees with the finding. The federal regulations do not explicitly mandate the separation of duties between employees conducting audits and those processing claims. While 42 CFR 456.2 requires Medicaid agencies to implement a surveillance and utilization control program, it does not specifically require the segregation of these roles. The regulation promotes control measures but does not mandate a distinct separation of duties. Based on this, we do not support this recommendation, as it exceeds the requirements outlined in the applicable federal rules. HHS remains committed to maintaining strong internal controls and believe our current structure aligns with regulatory expectations. Contact Person: Sarah Aker, Medicaid Executive Director Krista Fremming, Assistant Director Anticipated Completion Date: N/A

View Audit 346994

Finding 529057 (2024-010)

Significant Deficiency 2024

State of North Dakota

ND

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. HHS has begun the process of recoupment and will work to receive full repayment, to date the balance remaining was $5,000 and a payment plan has been...

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. HHS has begun the process of recoupment and will work to receive full repayment, to date the balance remaining was $5,000 and a payment plan has been sent up to recoup the remaining amount. The Accounts Payable team will collaborate with OMB to implement additional processes within Peoplesoft to verify payment information in the future. Currently, we are working to add display options in the Mass Voucher Approval screen to allow for tallying of the totals of vouchers in range. This addition will enhance the review step to ensure payments are consistent with Program totals for a secondary check before approval of payments are made. Contact Person: Karol Riedman, Assistant CFO Ann Scott, AP Accounting Manager Anticipated Completion Date: 06/30/2025

View Audit 346994 Questioned Costs: $1

Finding 529053 (2024-009)

Significant Deficiency 2024

State of North Dakota

ND

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.302 § 200.303

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. During review of audit found two overpayment errors as a result of outdated supporting documents. Refunds have been requested. HHS provides ongoing t...

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. During review of audit found two overpayment errors as a result of outdated supporting documents. Refunds have been requested. HHS provides ongoing training with eligibility and supervisory staff regarding document and eligibility requirements with staff. HHS actively monitors application quality and provides ongoing quality control reviews ensuring consistent adherence to best practices. Contact Person: Jessica Thomasson, Executive Policy Director Anticipated Completion Date: October 2024

View Audit 346994 Questioned Costs: $1

Finding 529052 (2024-013)

Significant Deficiency 2024

State of North Dakota

ND

Internal Control / Segregation of Duties Eligibility Matching / Level of Effort / Earmarking § 200.303

Department of Health and Human Services Response/Corrective Action Plan HHS agrees with the recommendation. During a period of high application volume, HHS temporarily bypassed its two-stage review process, assigning supervisors to review cases directly. The audit found no errors in eligibility du...

Department of Health and Human Services Response/Corrective Action Plan HHS agrees with the recommendation. During a period of high application volume, HHS temporarily bypassed its two-stage review process, assigning supervisors to review cases directly. The audit found no errors in eligibility during this time. To address this, HHS updated policies to document exceptions, including thresholds for initiating and ending them, ensuring transparency. Training sessions are being conducted to familiarize staff with these updates, and weekly monitoring of application volumes continues to anticipate surges. Contingency hiring plans and cross-training initiatives are in place to reduce future exceptions. Periodic reviews will ensure compliance, fostering a scalable, accountable process while maintaining high standards during peak periods. These measures ensure consistency and preparedness moving forward. Contact Person: Jessica Thomasson, Executive Policy Director Anticipated Completion Date: August 2024

View Audit 346994

Finding 529023 (2024-015)

Significant Deficiency 2024

State of North Dakota

ND

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. The issue has already been corrected as stated in the finding. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: The issue has already been corrected.

View Audit 346994 Questioned Costs: $1

Finding 528963 (2024-001)

Material Weakness 2024

South Adams Schools

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying N...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Finding: Material Weakness Context: During the grant period, the School Corporation expended a total of $5,803,458 in Economic Stabilization Funds (ESSER) for a building project. Although this project was included in the School Corporation's capital asset records, it was recorded at the estimated total project cost of $6,256,000 in a prior audit period prior to these costs being expended. In addition, the School Corporation did not designate the amount of the project that was paid with federal grant funds, complete an inventory in the two-year audit period, or record expenditures and report budgeted amounts in the proper object code. Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will reach out to Asset Controls to have them fix the expended amount of $5,803,458 to reflect on our reports. The School Corporation will also have Asset Controls itemize which project was paid for with federal grant funds to reflect our reports. The School Corporation will put into place the following schedule to update our inventory to stay in compliance with state and federal requirements. The School Corporation will have Asset Controls or the Director of Operations physically count the inventory of capital assets on even year audits. During the odd year audits, the School Corporation will have Asset Controls or the Director of Operations perform a perpetual count. Anticipated Completion Date: 06/30/2025

View Audit 346958

Finding 528957 (2024-003)

Significant Deficiency 2024

City of Lynwood

CA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Gabriel Linares, Director of Community Development, will enhance the department’s policy/desk procedure to ensure timely filing of the CAPER and Section 15011 reports starting Quarter Four, FY2024 -25. Personnel Responsible for Implementation: Gabriel Linares Position of Responsible Personnel: Dir...

Gabriel Linares, Director of Community Development, will enhance the department’s policy/desk procedure to ensure timely filing of the CAPER and Section 15011 reports starting Quarter Four, FY2024 -25. Personnel Responsible for Implementation: Gabriel Linares Position of Responsible Personnel: Director of Community Development Expected Date of Implementation: June 30, 2025

View Audit 346949

Finding 528956 (2024-002)

Significant Deficiency 2024

City of Lynwood

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Gabriel Linares, Director of Community Development, will enhance the department’s HOME assistance rules to ensure the value of the HOME-assisted property after rehabilitation will not exceed 95 percent of the median purchase price for the area starting Quarter 4, FY2024 -25. Personnel Responsible ...

Gabriel Linares, Director of Community Development, will enhance the department’s HOME assistance rules to ensure the value of the HOME-assisted property after rehabilitation will not exceed 95 percent of the median purchase price for the area starting Quarter 4, FY2024 -25. Personnel Responsible for Implementation: Gabriel Linares Position of Responsible Personnel: Director of Community Development Expected Date of Implementation: June 30, 2025

View Audit 346949 Questioned Costs: $1

Finding 528948 (2024-003)

Material Weakness 2024

Galena City School District

AK

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding 2024-003 Reporting – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan The District acknowledges the finding regarding failure to retain source check documentation supporting student count certification for the Impact Aid program. In resp...

Finding 2024-003 Reporting – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan The District acknowledges the finding regarding failure to retain source check documentation supporting student count certification for the Impact Aid program. In response to this issue, which pertained to source check forms from FY22 that were subject to review when payment was made in FY24, we have already implemented corrective measures. Under the oversight of our Director of Federal Programs, the District established and implemented comprehensive records retention procedures compliant with 2 CFR 200.303, including clear documentation requirements for federally connected children, a centralized digital repository for all Impact Aid records, a verification checklist system, and staff training on proper documentation protocols. This implementation was completed in June 2024, ensuring all records are now maintained in accordance with federal uniform guidance requirements. Expected Completion Date 07/01/2024

View Audit 346942

Finding 528885 (2024-011)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Guidance email was provided to program supervisors in February 2025, reiterating the requirement that all RESEA Checklists must be completed by staff and supervisors. Yearly file reviews – Bureau of Workforce Partnership and Operations (BWPO) is currently conducting case file reviews of the local o...

Guidance email was provided to program supervisors in February 2025, reiterating the requirement that all RESEA Checklists must be completed by staff and supervisors. Yearly file reviews – Bureau of Workforce Partnership and Operations (BWPO) is currently conducting case file reviews of the local offices. Once the review is completed, each area will get a results email with concerns and recommendations. These reviews started in September 2024 and will continue until they are completed. Anticipated completion is November 2025. Quarterly meetings were held for all local areas (2/4/25, 2/5/25 & 2/6/25). Next quarterly meetings will be held in May 2025. These meetings will reiterate the importance of following the RESEA process as detailed in the RESEA desk guide. Anticipated Completion Date: 11/30/2025 Contact Name: Dorraine Rauch, Division Chief

View Audit 346904

Finding 528884 (2024-010)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing...

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing the following from the list: - Those who registered for work. - Those exempt for other reasons. - Those denied benefits for other reasons. - Those with no payments for weeks beyond the 4th week of the claim. - The remaining individuals’ payments for the fifth week of the claim and later were totaled in January 2025: - 3,481 individuals - $22,597,596.92 - These amounts are described as “maximum” because only an individual review of each claim would reveal if the person was truly not properly registered and if weeks of benefits should be overpaid. - The Department is choosing to waive these individuals’ requirement to register based on UC law section 401(b)(6): The department may waive or alter the requirements of this subsection in cases or situations with respect to which the secretary finds that compliance with such requirements would be oppressive or which would be inconsistent with the purposes of this act. Since the individuals would currently be told of requirements they needed to meet in the past and, as a result, given debts to repay, this is oppressive in nature and inconsistent with the purpose behind the registration requirement. Anticipated Completion Date: Completed Contact Names: Stacy Walter, Management Analyst 2, Special Projects, Office of UC Service Centers; Rick Plesnarski, Management Supervisor, Special Projects Unit & Quality Assurance, Office of UC Service Centers

View Audit 346904 Questioned Costs: $1

Finding 528881 (2024-012)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

BWPO acknowledges that these errors were made, and the indicated accounts were updated immediately. The following steps will be taken to prevent this from happening again. 1. Desk Guides and Training Manuals for Central Offices CWDS Access Administrators will be updated to clearly define what ro...

BWPO acknowledges that these errors were made, and the indicated accounts were updated immediately. The following steps will be taken to prevent this from happening again. 1. Desk Guides and Training Manuals for Central Offices CWDS Access Administrators will be updated to clearly define what roles are restricted to state staff. Completed February 2025. 2. The Access Forms will be updated with the AdministratorLO role being in the restricted roles section and marked as only available to state staff. Completed February 2025. 3. During future reviews of restricted roles CWDS Users with these roles will be checked against staffing lists to confirm their employment status and availability for these roles. To be completed at the next Annual Review of Restricted Roles. A supplementary Annual Restricted Role Audit being completed currently for Restricted Roles. Completed March 2025. Anticipated Completion Date: Completed Contact Name: Jeremy Bender, Customer Service Unit Workforce Development Supervisor BWPO acknowledges that these errors occurred. The accounts were immediately deactivated upon discovery that the staff were no longer with the Commonwealth. The following steps will be taken to prevent a re-occurrence of this issue. 1. Three of the accounts in question were originally BWPO staff who moved to ATO, still needing CWDS Access, and then left state employment at a later date. There is currently not a system in place to review ATO staff separations. Going forward, Monthly Account Deactivation reviews will be expanded to BWDA and ATO with those Bureaus having to attest to all separations during the prior month. This should help ensure the Customer Service Unit is notified timely of staff separations in the other Bureaus. To begin March 31, 2025. 2. During periodic review of deactivations, the Customer Service Unit will compare CWOPA accounts against state staffing lists provided by HR, to ensure separated staff have their accounts deactivated timely. This will likely have to be quarterly or semi-annually as it is unfeasible for HR to have to generate full staff complements monthly for the multiple Bureaus whose CWDS Access BWPO’s Customer Service Unit manages. This will catch any issues that step 1 doesn’t resolve. To begin March 31, 2025. Anticipated Completion Date: 03/31/2025 Contact Name: Jeremy Bender, Customer Service Unit Workforce Development Supervisor

View Audit 346904

Finding 528851 (2024-007)

Material Weakness 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Office of Income Maintenance (OIM) Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card ...

Office of Income Maintenance (OIM) Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties. 2. The BOO will ensure offices know EBT cards are only to be made during business hours. BOO will work with the EBT Project Office to update the OIM EBT Procedure Manual for clarification. This will occur by April 1, 2025. 3. All CAOs and district offices will be reminded to update the EBT card tracking database within 24 hours of an individual’s status change. Clarification will be sent to the Area Managers to distribute to staff. This will occur by April 1, 2025. 4. All EBT Coordinators will be reminded to review the updates/changes to the OIM EBT Procedure Manual quarterly. Anticipated Completion Date: 04/01/2025 Contact Name: Jeanette Coulston, Staff Assistant to Director of Bureau of Operations OIM Bureau of Program Support (BPS)/EBT Project Office: BPS will take the following actions to address the finding: 1. The EBT Project Office will provide clarification and make updates to the OIM EBT Procedure Manual, in the Staff Security Section, for removing individuals from the EBT card tracking database. The updates will include screenshots for easier comprehension. This is expected to be completed by April 1, 2025. 2. The EBT Project Office will make updates to the OIM EBT Procedure Manual, in the EBT Security for Over the Counter (OTC) Card Mailing Section, to include “CAOs should not print OTC EBT Cards outside of normal business hours”. This is expected to be completed by April 1, 2025. 3. The OIM EBT Procedure Manual is updated quarterly. An email notification is sent to all EBT Coordinators, via a distribution list, notifying them of the updates/changes. This is expected to be completed by April 1, 2025. Anticipated Completion Date: 04/01/2025 Contact Name: Tonya Holloway, Division Director OIM Bureau of Program Evaluation (BPE)/Division of Corrective Action (DCA): BPE will take the following actions to address the finding: The Bureau of Program Evaluation, Division of Corrective Action conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a three-year rotation to ensure compliance in the execution of documented policies and procedures. When needed, BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the OIM EBT Procedure Manual. Annually, BPE/DCA EBT Headquarters staff provide training to DCA Income Maintenance Examiners in both field offices, to ensure awareness of any policy or procedure changes, prior to the start of the EBT reviews. The current rotation schedule spans FFY 2025- FFY 2027. The new three-year schedule began October 2024. Anticipated Completion Date:Completed Contact Name: Amira S. Milikin, Division Director

View Audit 346904 Questioned Costs: $1

Finding 528829 (2024-004)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Information on the federal program : Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Departmen...

Information on the federal program : Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context : For the 2 sample items tested, the School Corporation expended $205,068 on building renovations which was charged to the ESSER III (84.425U) grant award. It was noted these capital asset acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2024. Additionally, we noted the School Corporation’s capital asset listing did not contain all the required information, including the source of funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will request that funding sources be updated on our capital asset ledger. Personnel will ensure that all improvements are listed on the capital asset ledger. Anticipated Completion Date: November 2025

View Audit 346885

Finding 528827 (2024-003)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

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

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Nu...

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context : The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY22 time period ($230,281) did not agree to the underlying expenditure records ($4,290 for the period of July 1, 2021 through June 30, 2022). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Finance will review financial statements and ensure they agree to amounts reported on the annual data reports. Reviews will be documented with a signature. FTE documentation will be retained. Anticipated Completion Date: When the next report is due

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Finding 528824 (2024-002)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

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

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying...

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context : For 18 selections, in a sample of 40 payroll transactions, the School Corporation based the employees’ time charged to the grant on an annual time and effort log. The employee’s time was split with a non-federal fund. The School Corporation allocated the employee’s time based on a time and effort log completed in September of each year which was reviewed by the Superintendent. The School Corporation did not complete time and effort logs more frequently than annually to ensure the amounts being charged to food service were based on worked performed for each payroll period. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of doing a time study, we will fully implement an analysis of percentages paid by the school lunch program on a monthly basis. Anticipated Completion Date: Beginning of April 2025, fully implemented and corrected by the end of May 2025.

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Corrective Action Plans

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