Corrective Action Plans

Finding 505330 (2024-002)

Material Weakness 2024

City of Concord

NC

Questioned Costs HUD Housing Programs Material Weakness

Management has created a new Inspection Coordinator position that is responsible for the HCV inspection process. This position will report monthly on the status of scheduled inspections. The Housing Manager will be responsible to ensure that HAP payments are abated for units that do not meet inspect...

Management has created a new Inspection Coordinator position that is responsible for the HCV inspection process. This position will report monthly on the status of scheduled inspections. The Housing Manager will be responsible to ensure that HAP payments are abated for units that do not meet inspection requirements.

View Audit 327974 Questioned Costs: $1

Finding 505329 (2024-004)

Significant Deficiency 2024

City of Concord

NC

HUD Housing Programs Special Tests & Provisions Significant Deficiency

The agreement will be revised and updated in accordance with regulations. A budget will be adopted by the duly elected resident council for the use of the resident participation funds.

View Audit 327974

Finding 505328 (2024-003)

Material Weakness 2024

City of Concord

NC

Eligibility Material Weakness Internal Control / Segregation of Duties

The Housing Manager will complete quality control file reviews from a random sampling of applicant files to ensure that they contain all required documentation for eligibility determination. An external agency will be hired to conduct a complete a full file audit of active files.

View Audit 327974

Finding 505327 (2024-001)

Significant Deficiency 2024

City of Concord

NC

Special Tests & Provisions Cash Management HUD Housing Programs

City Staff incorrectly thought that all projects noted in the Action Plan submitted to HUD were covered under the Release of Funds (ROF). As the environmental review had not been fully completed at the time the project was submitted in the Action Plan, a separate ROF was needed. The necessary steps ...

City Staff incorrectly thought that all projects noted in the Action Plan submitted to HUD were covered under the Release of Funds (ROF). As the environmental review had not been fully completed at the time the project was submitted in the Action Plan, a separate ROF was needed. The necessary steps have been taken to correct the documentation and to prevent future occurrences.

View Audit 327974

Finding 505314 (2024-001)

Significant Deficiency 2024

McCook Public School District No 17

NE

Internal Control / Segregation of Duties

The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concer...

The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concern for the School District and the Board.

View Audit 327941

Finding 505309 (2024-001)

Significant Deficiency 2024

Family Pathways

MN

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

Planned Action: Family Pathways Food Access and Finance staff will communicate the audit finding to the appropriate authoritative TEFAP bodies: the Minnesota Department of Human Services, as administrator of Minnesota’s TEFAP program and issuer of Minnesota’s TEFAP Policy and Operations Manual, as w...

Planned Action: Family Pathways Food Access and Finance staff will communicate the audit finding to the appropriate authoritative TEFAP bodies: the Minnesota Department of Human Services, as administrator of Minnesota’s TEFAP program and issuer of Minnesota’s TEFAP Policy and Operations Manual, as well as Second Harvest Heartland, as pass-through agent and contractor of TEFAP food distribution. In addition to communicating the audit finding, Family Pathways will confirm what authorities exist for Family Pathways, as a TEFAP provider, to implement additional internal controls, including but not limited to: modifying current DHS TEFAP forms and applications, and/or requiring additional client application forms. Family Pathways would like to note that the current DHS TEFAP Policy and Operations Manual 2023, effective for the audit period indicated above, states that “additional eligibility criteria cannot be imposed on participants” and that “TEFAP Providers agree to make it as easy as possible for those in need to access food.”

View Audit 327924

Finding 505305 (2024-001)

Material Weakness 2024

University Preparatory Charter School for Young Men

NY

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Audit Recommendation 2024-001: • The School should ensure that processes are in place to understand reporting requirements that ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue ...

Audit Recommendation 2024-001: • The School should ensure that processes are in place to understand reporting requirements that ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue Plan (ARP ESSER) reports are conducted by a 3rd party agency. To ensure accuracy, they will be monitored internally; reviewed and approved prior to the final submission/upload of the report. Reports will not be submitted without final approval of School Officials. Implementation Date: • This change will be reflected in the upcoming 2025 annual report. Control processes will be communicated between the School and the 3rd party reporting agency. Person Responsible for Implementation: • This process will be managed by the Director of Business and reviewed by the Chief Financial Officer.

View Audit 327915

Finding 505304 (2024-001)

Material Weakness 2024

Residence Connection, Inc.

OH

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-001 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Findi...

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-001 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Finding and Each Recommendation. Statement of Condition: The Project did not request tenant assistance payments for the month of April. Criteria: The Regulatory Agreement requires the Project to ensure controls exist to request the appropriate funds for each tenant on a monthly basis. Cause: The Project’s controls over monthly housing assistance payments were not working properly due to lack of management oversight due to turnover during the year. Effect of Condition: The Project is not in compliance with the HUD approved Regulatory Agreement. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen management oversight. b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor is aware of the requirements of the HUD Regulatory Agreement and is working with new staff to ensure they receive the proper training on HUD requirements. 2. In August 2024, the April 2024 HAP requests were submitted for payment.

View Audit 327914

Finding 505302 (2024-002)

Material Weakness 2024

Wood County Village, Inc.

OH

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

B. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-002 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Findi...

B. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-002 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Finding and Each Recommendation. Statement of Condition: The Project did not request tenant assistance payments for the month of April and failed to re-submit a tenant assistance request for the month of December. Criteria: The Regulatory Agreement requires the Project to ensure controls exist to request the appropriate funds for each tenant on a monthly basis. Cause: The Project’s controls over monthly housing assistance payments were not working properly due to lack of management oversight due to turnover during the year. Effect of Condition: The Project is not in compliance with the HUD approved Regulatory Agreement. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen management oversight oversight. b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor is aware of the requirements of the HUD Regulatory Agreement and is working with new staff to ensure they receive the proper training on HUD requirements. 2. In August 2024, the April 2024 HAP requests were submitted for payment.

View Audit 327913

Finding 505301 (2024-001)

Material Weakness 2024

Wood County Village, Inc.

OH

HUD Housing Programs Material Weakness Reporting

A. Current Financial Statement Findings 1. Finding 2024-001 Material Weakness in Internal Controls over Financial Reporting a. Comments on the Finding and Each Recommendation. Statement of Condition: Numerous accounts were identified that required adjustment as part of our audit procedures, includi...

A. Current Financial Statement Findings 1. Finding 2024-001 Material Weakness in Internal Controls over Financial Reporting a. Comments on the Finding and Each Recommendation. Statement of Condition: Numerous accounts were identified that required adjustment as part of our audit procedures, including accounts receivable -HUD and depreciation expense. Due to the number and nature of the required audit adjustments, we are considering this deficiency to be a material weakness in internal control over financial reporting. The misstatements that were discovered as a result of audit procedures would have had the following impact on the financial statements if left unadjusted: Assets understated by $26,943 Liabilities understated by $7,593 Net assts understated by $19,350 Revenues understated by $9,313 Expenses overstated by $10,037 Criteria: It is the responsibility of the Project’s Sponsor to design and implement internal controls over financial reporting to ensure that Project’s accounts are properly recorded in accordance with U.S. GAAP. Significant adjustments that arise as a result of audit procedures that were otherwise not detected by the Project’s sponsor are required to be reported as a deficiency in internal control over financial reporting. Cause: There were errors identified in the Project’s depreciation calculations which were not identified and corrected as part of the financial close and reporting process. Amounts due from HUD for HAP requests not filed during the year were not recorded as accounts receivable. Effect of Condition: Failing to review and/or fully reconcile all of the significant accounts of the Project, may cause the financial statements to be materially misstated. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen the Project’s internal controls. We also recommend the Project’s sponsor ensures there is a process in place to review year-end balances to ensure all transactions have been recorded correctly.b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor has implemented staff responsibility charts to ensure that all financial statement areas have the appropriate review and approval. 2. The Project’s sponsor is providing training to their staff on the HUD Handbook and related regulations.

View Audit 327913

Finding 505285 (2024-002)

Material Weakness 2024

Kearney Public Schools District No. 07

NE

Internal Control / Segregation of Duties

The district will continue to monitor the individual duties of staff. However, the district’s budget will not allow the means to hire sufficient staff to completely correct this finding. This will continue to be an ongoing concern.

View Audit 327912

Finding 505280 (2024-003)

Significant Deficiency 2024

Brandywine Community Schools

MI

Significant Deficiency Internal Control / Segregation of Duties

The District is improving their current policy for support for any federal draw is immediately attached to the federal request. This will make the information readily available when requested.

View Audit 327909

Finding 505279 (2024-002)

Material Weakness 2024

Brandywine Community Schools

MI

Material Weakness Internal Control / Segregation of Duties

The District plans on reviewing federal revenue accounts with the District’s Grant Auditor Report, Berrien RESA report, and other federal grant documents and reconcile to federal grant expenditures in the District’s general ledger when preparing the District’s Schedule of Federal Awards.

View Audit 327909

Finding 505278 (2024-001)

Significant Deficiency 2024

McNc

NC

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Name of Contact Person: Sarah Taylor, CFO Corrective Action: The Organization agrees that a significant deficiency exists regarding internal controls over financial reporting related to the revision to the fiscal year 2023 consolidated financial statements for a gross vs. net presentation error rela...

Name of Contact Person: Sarah Taylor, CFO Corrective Action: The Organization agrees that a significant deficiency exists regarding internal controls over financial reporting related to the revision to the fiscal year 2023 consolidated financial statements for a gross vs. net presentation error related to ASC 606. The Organization identified the error in the current year review of revenue contracts in accordance with ASC 606, and informed Forvis Mazars of the presentation error. As part of the corrective action plan, Management continually assesses existing and new contracts with ASC 606 and has implemented policies and procedures surrounding the adherence to GAAP accounting requirements. Implementation Date: July 1, 2023

View Audit 327907

Finding 505267 (2024-001)

Material Weakness 2024

Birmingham Public Schools

MI

Reporting School Nutrition Programs Internal Control / Segregation of Duties

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School ...

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. For certain periods during the year the School District asserts there was a review process in place over the reimbursement requests; however, the review was not documented, and therefore we were not able to verify if the control was in place and operating effectively. For other periods during the year, the School District did not have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Ultimately, the lack of a review control during the 2023-2024 fiscal year did not result in inaccurate reporting or incorrect amount of reimbursement paid by the Michigan Department of Education. The Business Office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: Kevin Taratuta, Chief Financial and Operations Officer Anticipated Completion Date: August 1, 2024

View Audit 327892

Finding 505142 (2024-001)

Significant Deficiency 2024

Hamline University of Minnesota

MN

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14...

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Individual(s) responsible for processing refunds will review the current internal procedures for processing refunds and student account credits. They will also review the federal guidelines regarding Title IV funds available on fsapartners.ed.gov. After review, the Manager of student accounts will meet with this staff to ensure understanding of procedures and look for areas of improvement and opportunities for clarity. The Manager will also review current procedures to ensure documents are up-to-date and look for areas that require revision. Manager will review current reporting within the Workday system to ensure proper information is being pulled at time of running reports. Names of the contact persons responsible for corrective action: Sirena Huppert, Manager of Student Accounts Planned completion date for corrective action plan: January 1, 2025

View Audit 327809

Finding 505066 (2024-001)

Significant Deficiency 2024

Rowan-Salisbury Board of Education

NC

Questioned Costs School Nutrition Programs Matching / Level of Effort / Earmarking

Management will take the steps necessary to ensure matching requirements are met.

View Audit 327744 Questioned Costs: $1

Finding 505064 (2024-002)

Significant Deficiency 2024

Oconto Falls Public School District

WI

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

FINDINGS— FEDERAL AND STATE AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION 2024-002 Elementary and Secondary School Emergency Relief (ARP ESSER) – 84.425U Recommendation: CLA recommends the District review its internal controls and implement a procedure to ensure all journal entries are appro...

FINDINGS— FEDERAL AND STATE AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION 2024-002 Elementary and Secondary School Emergency Relief (ARP ESSER) – 84.425U Recommendation: CLA recommends the District review its internal controls and implement a procedure to ensure all journal entries are approved prior to being posted within the general ledger. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District will review its internal controls and implement a procedure to ensure all journal entries are approved prior to being posted within the general ledger. Name of the contact person responsible for corrective action: Kim Sinclair, District Business Manager. Planned completion date for corrective action plan: June 30, 2025

View Audit 327742

Finding 505052 (2024-001)

Significant Deficiency 2024

National Arbor Day Foundation

NE

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

A plan has been put in place that involves the Accounting Director monitoring the FFATA reporting activity monthly to ensure that the Foundation meets the reporting requirements of the program. Each month, the Accounting Director contacts the Grant Administrator to determine if any new first-tier s...

A plan has been put in place that involves the Accounting Director monitoring the FFATA reporting activity monthly to ensure that the Foundation meets the reporting requirements of the program. Each month, the Accounting Director contacts the Grant Administrator to determine if any new first-tier subaward contracts have been signed during the last 30 days. If any contracts have been signed, the Accounting Director obtains a copy of the FFATA report that the Grant Administrator filed during the month to verify that it contains those subaward contracts and that they have been reported on a timely basis and in the correct amount. In addition, the Accounting Director compares information on the monthly FFATA reports to a master list of approved sub awardees to verify contract amounts and to ensure that all contracts are being reported.

View Audit 327737

Finding 505044 (2024-002)

Significant Deficiency 2024

St. Ignace Area School District

MI

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

The District will review vendors over $25,000 spent with federal funds to ensure that they are not suspended or debarred and retain documented support for the procedures performed.

View Audit 327725

Finding 504994 (2024-010)

Significant Deficiency 2024

Clarkson College

NE

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal Operations Report for 2023-2024 and Applicati...

Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal Operations Report for 2023-2024 and Application to Participate for 2025-2026 (FISAP) for the Campus-Based programs is the second FISAP the Financial Aid & Scholarships Director has completed. The error on the FISAP was the enrollment number. The Financial Aid & Scholarships Director was first provided with a number from the Office of Institutional Effectiveness that was still being further calculated and checked for accuracy. Currently, in our new student information system, reporting and verifying correct numbers is more time-consuming. The Director later received the accurate number and updated the FISAP. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: October 2024

View Audit 327718

Finding 504990 (2024-009)

Significant Deficiency 2024

Clarkson College

NE

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is ...

Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds are processed within 48 hours according to our standard procedures, which ensures that refunds are processed within 14 days according to the federal requirements. However, in the instance of this finding, it appears that the procedure was not followed due to unusual circumstances. We will add a step to our procedure that requires the supervisor to oversee that the credit balance is refunded within guidelines of 14 days. Name(s) of the contact person(s) responsible for corrective action: Robyn Hansen Planned completion date for corrective action plan: October 18, 2024

View Audit 327718 Questioned Costs: $1

Finding 504986 (2024-008)

Significant Deficiency 2024

Clarkson College

NE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have a designated staff member who ensures that all students selected for verification are being reported to the FAFSA Portal. Please note the Department of Education has listed on their FAFSA Portal that 24/25 verification reporting is not currently available, and schools will be notified when it becomes available. At that time, all 24/25 verifications will be reported in the FAFSA Portal. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

View Audit 327718

Finding 504982 (2024-007)

Significant Deficiency 2024

Clarkson College

NE

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement B23with the audit findi...

Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement B23with the audit finding. Action taken in response to finding: With the start of the 2024-2025 school year, the Financial Aid and Student Accounts departments are working together to reconcile all federal aid, Nurse Student Loans and Nurse Faculty Loans weekly on Fridays. This has worked well since its inception in August 2024. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

View Audit 327718

Finding 504978 (2024-006)

Significant Deficiency 2024

Clarkson College

NE

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With our new student information system, Anthology Student, there are tasks we can assign to a staff member to alert them that there are R2T4s to process. We think this will be helpful in making sure we accurately calculate R2T4s. Anthology Student also has regulatory controls in the R2T4 calculation process that calculates number of days in the semester and break days. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

View Audit 327718 Questioned Costs: $1

Corrective Action Plans

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