Corrective Action Plans

Finding 538093 (2024-002)

Material Weakness 2024

South Dearborn Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.303

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager Contact Phone Number and Email Address: 812.926.2090, shawn.spindler@sdcsc.k12.in.us Views of Responsible Officials: We concur with t...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager Contact Phone Number and Email Address: 812.926.2090, shawn.spindler@sdcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ESSER data collection will be completed by the Business Manager and reviewed by the Superintendent. This review will be documented either via print out and signature or via email. Anticipated Completion Date: March 2025

View Audit 349120

Finding 538091 (2024-001)

Material Weakness 2024

South Dearborn Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsibl...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will verify our enrollment from the prior year October ADM count and have it reviewed and signed off by another staff member. For the non-pubs, the Title I Director will require student rosters as well as poverty information. This information will then be reviewed and signed off on. Anticipated Completion Date: June 2025

View Audit 349120

Finding 538088 (2024-001)

Significant Deficiency 2024

Housing and Redevelopment Authority of Wadena

MN

Internal Control / Segregation of Duties Reporting

2024-001 – Lack of Segregation of Duties Corrective Action Planned: Due to the Authority’s size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organiz...

2024-001 – Lack of Segregation of Duties Corrective Action Planned: Due to the Authority’s size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 349118

Finding 538084 (2024-001)

Significant Deficiency 2024

Spencer-Owen Community Schools

IN

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

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thoro...

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thorough and more fully documented process should be in place and that it needs to cover the full school year and not be done just the one time towards the beginning of the year. Description of Corrective Action Plan: The􀀃Technology􀀃and􀀃Food􀀃Service􀀃Reporting􀀃Assistant􀀃(TFSRA)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃the􀀃initial􀀃processing􀀃of􀀃applications􀀃and􀀃 Direct􀀃Certification􀀃(DC). The􀀃Claims/Deputy􀀃Treasurer􀀃(C/DT)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃a􀀃random􀀃check􀀃on􀀃applications􀀃to􀀃confirm􀀃that􀀃eligibility􀀃is􀀃applied􀀃 accurately. This􀀃check􀀃should􀀃happen􀀃four􀀃(4)􀀃times􀀃a􀀃year: 1. Around􀀃the􀀃Fall􀀃Membership􀀃Count􀀃Day􀀃(first􀀃few􀀃days􀀃in􀀃October)􀀃 2. Christmas􀀃Break􀀃(around)􀀃 3. Spring􀀃Break􀀃(around)􀀃 4. First􀀃part􀀃of􀀃May􀀃 The􀀃TFSRA􀀃will􀀃put􀀃the􀀃list􀀃of􀀃students􀀃and􀀃their􀀃eligibility􀀃from􀀃the􀀃food􀀃service􀀃software􀀃(currently􀀃Titan)􀀃at􀀃the􀀃point􀀃of􀀃each􀀃 check.􀀃The􀀃first􀀃pull􀀃of􀀃students􀀃in􀀃October􀀃will􀀃be􀀃all􀀃students􀀃while􀀃the􀀃subsequent􀀃pulls􀀃will􀀃be􀀃for􀀃the􀀃dates􀀃between􀀃the􀀃 previous􀀃pull􀀃and􀀃that􀀃date􀀃with􀀃the􀀃intention􀀃of􀀃catching􀀃any􀀃new􀀃students􀀃or􀀃new􀀃student􀀃eligibility. The􀀃C/DT􀀃will􀀃select􀀃a􀀃random􀀃sampling􀀃of􀀃students􀀃to􀀃verify.􀀃They􀀃will􀀃work􀀃with􀀃the􀀃TFSRA􀀃to􀀃look􀀃at􀀃the􀀃records􀀃in􀀃Titan􀀃for􀀃 applications􀀃and􀀃CNPWeb􀀃for􀀃the􀀃DC􀀃students􀀃to􀀃see􀀃applications􀀃or􀀃the􀀃DC􀀃eligibility􀀃as􀀃appropriate.􀀃Forms􀀃will􀀃be􀀃printed􀀃or􀀃 screen􀀃shot􀀃to􀀃create􀀃a􀀃file􀀃that􀀃will􀀃be􀀃saved􀀃by􀀃both􀀃parties. Anticipated Completion Date: March 14, 2025

View Audit 349113

Finding 538083 (2024-001)

Significant Deficiency 2024

Housing Authority of the Town of Laurinburg

NC

HUD Housing Programs Eligibility Reporting

Section III – Federal Award Findings and Questioned Costs Finding 2024-001 Name of Contact Person: Amanda John Executive Director Corrective Action: We will implement proper internal control procedures for the Housing Choice Voucher Program eligibility requirements. Proposed Completion Date: Imm...

Section III – Federal Award Findings and Questioned Costs Finding 2024-001 Name of Contact Person: Amanda John Executive Director Corrective Action: We will implement proper internal control procedures for the Housing Choice Voucher Program eligibility requirements. Proposed Completion Date: Immedicately.

View Audit 349112

Finding 538073 (2024-002)

Significant Deficiency 2024

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Reporting Significant Deficiency

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E P063P130272 (7/1/2023 – 6/30/2024)...

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Related to the student status change which was reported to NSLDS outside of 60 days, the Rutgers Health and University Registrar will continue to provide training and support to University constituents through regular reporting and monthly check-in meetings to reiterate the importance of timely submissions. Related to the effective dates which did not match between the University record, Campus-Level Record and Program-Level Record, the Rutgers Health and University Registrar will continue work with the central Office of Information Technology, University Enrollment Services and Ellucian teams to refine the enrollment reporting process and will provide training to all involved to ensure accurate reporting. Anticipated Completion Date: The corrective action was in place as of March 1, 2025.

View Audit 349099

Finding 538063 (2024-001)

Material Weakness 2024

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Eligibility Material Weakness

2024-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pr...

2024-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Profession Student Loan Program (ALN 93.342), Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A132602 (7/1/2023 – 6/30/2024), E P033A132602 (7/1/2023 – 6/30/2024), E P038A132602 (7/1/2023 – 6/30/2024), E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024), E 01HP28821 02 02, E36HP26092, E36HP25751, E26HP25748, E11HP27284 (7/1/2023 – 6/30/2024), 1T08HP393200100 (7/1/2023 – 6/30/2024), 5 T08HP39320 03 00 (7/1/2023 – 6/30/2024) Contact Person: Ellen Law, AVP OIT Enterprise Application Services, 848-445-5064 Corrective Action: Management has documented and implemented system release management practices for the Oracle Student Financial Planning (OSFP) system. All change requests, updates and approvals for the OSFP system are tracked in a project tracking software. There is a dedicated OSFP administrator, segregating duties within the technical team, with the capability of deploying changes to production. A new access role was also implemented which limits the permissions, with only 4 administrators with the advanced privileges. Finally, a preliminary recertification process occurred in October 2023 and October 2024 without formal procedures which remained in development. Formalized procedures, which includes annual training, will be finalized in fiscal year 2025. Anticipated Completion Date: The corrective action for system release management, change management and system access were implemented as of June 30, 2024. The formalized procedures for recertification were developed by October 31, 2024, and the next recertification will be completed by October 31, 2025.

View Audit 349099

Finding 538061 (2024-001)

Significant Deficiency 2024

Oxbow Center

WY

Procurement, Suspension & Debarment Significant Deficiency Internal Control / Segregation of Duties

Dear Jason, I am writing to formally address the audit finding identified in the FY24 Independent Auditor Report conducted for year ended June 30, 2024. In response to finding 2024-001 Procurement Internal Control Policy - Non Compliance and Significant Deficiency, we have read, agree, and are taki...

Dear Jason, I am writing to formally address the audit finding identified in the FY24 Independent Auditor Report conducted for year ended June 30, 2024. In response to finding 2024-001 Procurement Internal Control Policy - Non Compliance and Significant Deficiency, we have read, agree, and are taking immediate steps to write internal controls that abide by federal regulation to correct this deficiency. To address this finding, we are implementing the following corrective actions: a policy titled Procurement Internal Control Policy will be created with the input of our CHRO, CFO and CEO and reviewed and approved by our Board of Directors. We expect this will be completed in the next 2 months, with Jackie Robertson being responsible for overseeing completion and implementation. We take this matter seriously and are committed to ensuring compliance and operational excellence. Please let us know if you require any further information or clarification. We appreciate your time and consideration and look forward to your feedback.

View Audit 349093

Finding 538059 (2024-002)

Significant Deficiency 2024

Elderly Housing Corporation of Clay County 092-35748-Np-L8

MN

Internal Control / Segregation of Duties Special Tests & Provisions Cash Management

Contact Person Dara Lee, Executive Director of Clay County HRA (Authorized Representative and Agent) Corrective Action Plan The Corporation is aware of the issue and has taken subsequent steps to ensure internal procedures are followed as established. Planned Completed Date for CAP Immediately

View Audit 349089

Finding 538047 (2024-003)

Material Weakness 2024

Fort Scott Community College

KS

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

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the C...

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and two (2) of five (5) tested had not been returned as of the date of fieldwork which exceeded the required timeframe to return funds. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know the student financial aid was returned to Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared OneDrive electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from Poise to monitor students who have withdrawal on their records so that this can be updated and proper calculations done. All financial aid staff will attend training to stay up to date on regulations and changes. Starting in July 2025 the new J1 system will be integrated with JFA (financial aid system). This will create operational efficiencies and reporting capabilities that are not currently available. Less manual transactions will also provide more accurate student reports. Measurable targets will be achieved by documenting the records within the OneDrive shared electronic folder between the Financial Aid office and the Business Office, who handles the return of funds. Daily changes and/or withdrawal of students will be monitored and funds will be returned as required. This will become of a part of the regular duties of staff.

View Audit 349075

Finding 538046 (2024-002)

Material Weakness 2024

Fort Scott Community College

KS

Special Tests & Provisions Student Financial Aid Cash Management

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to th...

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of policies and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalize the policies and procedures in the Financial Aid policy manual. The policies and procedures will have shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. A OneDrive electronic folder has been created with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system generates a listing of students. The list of students will be created for each draw-down that is initiated and will be placed in the shared folder in OneDrive. Draw-downs will not be initiated without a corresponding student list that shows the student account has been credited with the financial aid award. The documentation will be found in the shared OneDrive electronic folder, which has already been implemented. The transfer (interface) of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.

View Audit 349075

Finding 538041 (2024-001)

Material Weakness 2024

Sylvan Heights Science Charter School

PA

Internal Control / Segregation of Duties Reporting

The School had established processes to ensure the accuracy of required reports. For the PDE Reconciliation of Cash on Hand Quarterly Reports, all filings were reviewed with management immediately following submission. Given the low risk of material misstatement associated with these reports, the ex...

The School had established processes to ensure the accuracy of required reports. For the PDE Reconciliation of Cash on Hand Quarterly Reports, all filings were reviewed with management immediately following submission. Given the low risk of material misstatement associated with these reports, the existing procedures were effective in ensuring compliance. For the annual report, management conducted all reviews, discussions and approvals prior to submission; however, the review process was not formally documented. To strengthen internal controls, the School will implement a process to ensure that all reviews and approvals are documented in advance of submission. This will provide clear evidence of oversight while maintaining the efficiency of the reporting process. This is further evidenced by the Principal/CAO providing documented approval of the most recent report submission.

View Audit 349069

Finding 538037 (2024-003)

Significant Deficiency 2024

Community Action Program Region Vii, Inc.

ND

Internal Control / Segregation of Duties Cash Management Significant Deficiency

2024-003: Segregation of Duties – Significant Deficiency a. Prior Year Findings • The current year finding is not a repeat finding from the prior year. b. Comments on Findings and Recommendations • We concur with the findings. c. Action Taken or Planned • Management and the Board will review the ac...

2024-003: Segregation of Duties – Significant Deficiency a. Prior Year Findings • The current year finding is not a repeat finding from the prior year. b. Comments on Findings and Recommendations • We concur with the findings. c. Action Taken or Planned • Management and the Board will review the accounting functions and will strive to improve the areas that are economically feasible.

View Audit 349065

Finding 538032 (2024-001)

Significant Deficiency 2024

School District of Green Lake

WI

Internal Control / Segregation of Duties

The District will continue to have a designated Administrator/Principal review monthly the bank reconciliations. The Board will continue to review monthly a revenue, expense, and balance sheet report. Year-to-date percentages along with over/under spent dollar amount will be indicated on such report...

The District will continue to have a designated Administrator/Principal review monthly the bank reconciliations. The Board will continue to review monthly a revenue, expense, and balance sheet report. Year-to-date percentages along with over/under spent dollar amount will be indicated on such reports. Explanations for any variances will be reviewed. The Administrator will continue to approve all purchase orders and review all journal entries prepared by the Bookkeeper. Cross training of back-up individuals will continue for all office/financial personnel.

View Audit 349059

Finding 538019 (2024-004)

Significant Deficiency 2024

Catholic Charities of Los Angeles, Inc.

CA

School Nutrition Programs Equipment & Real Property Management Internal Control / Segregation of Duties

Catholic Charities is required to conduct at least monthly inventory of USDA foods. We tested all 12 food distribution locations for inventory reporting and two of the locations were unable to provide evidence of inventory work performed for the month of June 2024. Recommendation: Management should...

Catholic Charities is required to conduct at least monthly inventory of USDA foods. We tested all 12 food distribution locations for inventory reporting and two of the locations were unable to provide evidence of inventory work performed for the month of June 2024. Recommendation: Management should ensure that staff at the food distribution locations are aware of the compliance requirements and provide additional training deemed necessary. Inventory processes and internal controls can be tailored to the nature and size of the location receiving and distributing the food resources. Action Taken: Management will review monthly inventory reports for each food pantry going forward and ensure reports are created to report zero amounts of inventory at month end. Name of responsible person: Daniel O'Brien, Chief Financial Officer Anticipated completion date: March 1, 2025 If there are questions regarding this plan, please call Catholic Charitie of Los Angeles's, Chief Financial Officer at (213) 251-3410. Sincerely yours, Daniel O'Brien Chief Financial Officer

View Audit 349032

Finding 538015 (2024-001)

Material Weakness 2024

Montpelier Housing Authority

VT

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties § 200.514

RE: Audit Finding-Missing EIV Reports Montpelier Housing Authority Audit Finding Response: The auditor reviewed the finding with me and the following action plan was put in place to ensure that key EIV reports are run on a scheduled basis and appropriate actions are taken: • Policies and procedures ...

RE: Audit Finding-Missing EIV Reports Montpelier Housing Authority Audit Finding Response: The auditor reviewed the finding with me and the following action plan was put in place to ensure that key EIV reports are run on a scheduled basis and appropriate actions are taken: • Policies and procedures surrounding EIV were reviewed. •We implemented the use of a chart to prompt EIV reports within 90 days for new moveins. (see attached chart) •We already monitor EIV monthly and quarterly to ensure that EIV reports are run for all move-ins and re-certifications.

View Audit 349026

Finding 538013 (2024-001)

Significant Deficiency 2024

Hertford Housing Authority

NC

HUD Housing Programs Eligibility Reporting

Corrective Action Plan Section III – Federal Award Findings and Questioned Costs Finding 2024-001 Name of Contact Person: Arnesa Holley, Executive Director Corrective Action: We will implement proper internal control procedures for the Section 8 Project Based Cluster eligibility requirements....

Corrective Action Plan Section III – Federal Award Findings and Questioned Costs Finding 2024-001 Name of Contact Person: Arnesa Holley, Executive Director Corrective Action: We will implement proper internal control procedures for the Section 8 Project Based Cluster eligibility requirements. Management has established a checklist for applications and will establish checklists for move-ins and move-outs. Proposed Completion Date: Immediately.

View Audit 349022

Finding 538005 (2024-001)

Material Weakness 2024

Wisconsin Heights School District

WI

Internal Control / Segregation of Duties

Finding #2024-001- Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The limited size of the District’s office staff prevents the ideal separation of functions. The Accounts Payable/Payroll Administrative Assistant prints accounts payable checks, has access to the password t...

Finding #2024-001- Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The limited size of the District’s office staff prevents the ideal separation of functions. The Accounts Payable/Payroll Administrative Assistant prints accounts payable checks, has access to the password to print electronic signatures and performs bank reconciliations. The Accounts Payable/Payroll Administrative Assistant also performed payroll functions during the previous year. Criteria: Internal controls should be in place that provide adequate segregation of duties. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: Limited number of personnel. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district’s operations. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Board reviews and approves all expenditures on a monthly basis prior to mailing accounts payable checks. The Business Official also reviews accounts payable checks, bank reconciliations and payroll for accuracy. Contact Person: Michelle McGrath Anticipated Completion: Not applicable

View Audit 349014

Finding 538002 (2024-001)

Material Weakness 2024

Cordell Independent School District #78

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Davis-Bacon Act Procedures: The Davis-Bacon Act requires contractors and subcontractors working on federally funded or assisted construction projects to pay their laborers and mechanics prevailing wages and benefits, as determined by the Department of Labor. For school districts involved in such ...

Davis-Bacon Act Procedures: The Davis-Bacon Act requires contractors and subcontractors working on federally funded or assisted construction projects to pay their laborers and mechanics prevailing wages and benefits, as determined by the Department of Labor. For school districts involved in such projects, ensuring compliance with the Davis-Bacon Act involves several key procedures: 1. Project Planning and Contracting: Prevailing Wage Determination: Obtain the prevailing wage rates from the Department of Labor for the locality where the project is to be performed. Contract Clauses: Include Davis-Bacon Act clauses in all construction contracts and subcontracts. This should specify the obligation to pay prevailing wages, submit certified payrolls, and allow for site inspections. 2. Pre-Construction Conference: Training and Guidance: Conduct pre-construction meetings with contractors and subcontractors to explain Davis-Bacon Act requirements, including prevailing wage rates, payroll reporting, and compliance procedures. 3. Wage Decision Posting: On-Site Posting: Ensure that the applicable wage determination and the Department of Labor's "Employee Rights Under the Davis-Bacon Act" poster are posted at the job site in a conspicuous place accessible to all workers. 4. Certified Payrolls: Submission Requirements: Require contractors and subcontractors to submit weekly certified payrolls using Form WH-347 or an equivalent form. The payroll must include details on hours worked, wage rates, fringe benefits, and deductions. 5. Review and Verification: Payroll Review: Regularly review submitted certified payrolls to verify compliance with wage determinations. Cross-check the reported wage rates and classifications with the prevailing wage rates. Worker Interviews: Conduct periodic on-site interviews with workers to verify that they are receiving the appropriate wages and benefits as reported on the certified payrolls. 6. Enforcement Actions: Non-Compliance Follow-Up: If discrepancies or non-compliance are identified, promptly address these issues with the contractor. Require corrective actions and ensure that any underpayments are rectified. Withholding Payments: Withhold contract payments as necessary to ensure compliance or to cover any underpayments until the contractor corrects the violations. 7. Documentation and Recordkeeping: Maintan Records: Keep detailed records of all wage determinations, certified payrolls, enforcement actions, and communications related to compliance with the Davis-Bacon Act. Retain these records for at least three years after project completion. 8. Audit and Oversight: Internal Audits: Conduct internal audits and oversight activities to ensure ongoing compliance. This may involve random checks and reviews by the district's compliance officers or external auditors. 9. Reporting to Funding Agencies: Regular Reports: Submit required reports to the relevant federal or state agencies overseeing the project, demonstrating compliance with the Davis-Bacon Act requirements. Cordell Public Schools has implemented the above procedures in January 2024, we can ensure compliance with the Davis-Bacon Act, thereby protecting workers' rights and avoiding potential legal and financial penalties. The carryover from a fiscal year project will be reevaluated. The project still fell under our corrective action plan but was not a new project that was in line with the actions listed above. We closed out the fiscal year, opened the new year to continue the project, therefore we still were not in compliance with the Davis-Bacon Act or our procedures. However, all future projects have been in compliance. In the next overlapping project, we will consult our auditors and find the best way to leave open funds to finish the project, but not start over in a new fiscal year.

View Audit 349009

Finding 537995 (2024-002)

None 2024

Puerto Aqueduct and Sewer Authority

PR

Reporting Internal Control / Segregation of Duties § 200.512

On July 31, 2024, the Authority issued the audited financial statements for the fiscal year 2023 and Single Audit reporting package corresponding to year ended June 30, 2023 was submitted on August 30, 2024. Currently, the audit for the fiscal year 2024 is in process and the Authority expects to iss...

On July 31, 2024, the Authority issued the audited financial statements for the fiscal year 2023 and Single Audit reporting package corresponding to year ended June 30, 2023 was submitted on August 30, 2024. Currently, the audit for the fiscal year 2024 is in process and the Authority expects to issue and submit the 2024 financial statements and Single Audit reporting package within the established due date.

View Audit 349005

Finding 537987 (2024-005)

Material Weakness 2024

North Newton School Corporation

IN

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.1 § 200.303 § 200.308 § 200.403

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials...

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

View Audit 349004

Finding 537978 (2024-003)

Material Weakness 2024

North Newton School Corporation

IN

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

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business official or superintendent will review and sign off and date the eligibility reports. Anticipated Completion Date: September 30, 2025

View Audit 349004

Finding 537977 (2024-004)

Significant Deficiency 2024

White River Valley School District

IN

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

Context: For the one project sampled for Davis-Bacon requirements, the contract with the company did not include the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $784,155. The School Corporation did obtain the weekly payroll...

Context: For the one project sampled for Davis-Bacon requirements, the contract with the company did not include the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $784,155. The School Corporation did obtain the weekly payroll reports certifications from the company that performed renovations. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Future contracts will include Davis-Bacon requirements. Any future contracts will be reviewed by the Superintendent or his designee to ensure that the required language is included in the contract. Anticipated Completion Date: Immediate

View Audit 348999

Finding 537976 (2024-003)

Material Weakness 2024

White River Valley School District

IN

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

Context: The School Corporation expended $1,313,973 on building renovations which was charged to the ESSER III (84.425U) grant award. The School Corporation was unable to provide the capital asset listing as of June 30, 2024, for testing to ensure the building renovations were properly included on ...

Context: The School Corporation expended $1,313,973 on building renovations which was charged to the ESSER III (84.425U) grant award. The School Corporation was unable to provide the capital asset listing as of June 30, 2024, for testing to ensure the building renovations were properly included on the listing. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A fixed asset inventory will be secured prior to the next audit. Anticipated Completion Date: December 31, 2025

View Audit 348999

Finding 537974 (2024-002)

Material Weakness 2024

White River Valley School District

IN

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

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 I and ESSER II amounts reported for the reports covering the FY2...

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 I and ESSER II amounts reported for the reports covering the FY22 time period ($0 and $459,915 respectively) did not agree to the underlying expenditure records ($27,092 and $455,658 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($459,616 and $22,273 respectively) did not agree to the underlying expenditure records ($107,610 and $1,274,716 respectively) for the period of July 1, 2022 through June 30, 2023. We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Additionally, the School Corporation was unable to provide the supporting reports containing the FTEs reported as of 9/30/22 and 9/30/23. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Federal reporting will be completed by the due date assigned and approved by the Superintendent prior to submission. After submission, the reports will be maintained. Anticipated Completion Date: Immediate

View Audit 348999

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