Corrective Action Plans

Finding 389342 (2023-003)

Significant Deficiency 2023

DE

HUD Housing Programs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

SIGNIFICANT DEFICIENCY 2023-003 Section 8 Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the County review and enhance its internal controls, policies, and procedures to ensure that the amounts included on the FDS are accurate. Explanation of disagreement...

SIGNIFICANT DEFICIENCY 2023-003 Section 8 Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the County review and enhance its internal controls, policies, and procedures to ensure that the amounts included on the FDS are accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The department will modify its SOP to include a second reviewer before the final FDS figures are submitted. The first submission is due in August and the final submission is due in March. Name(s) of the contact person(s) responsible for corrective action: Mike Kapa Planned completion date for corrective action plan: June 30, 2024

View Audit 300342

Finding 389338 (2023-003)

Material Weakness 2023

Columbiana Metropolitan Housing Authority

OH

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Melissa Bead...

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Melissa Beadle, Deputy Director, will be responsible for implementing this corrective action by June 30, 2024. CMHA is aware that the HAB/MRI software does not store waitlist reports by date processed and since then, CMHA has been saving Excel files of the waitlist reports. The applicants that were selected for the audit were applicants that had preference points. All applicants with preference points were contacted at the same time to be informed that they were eligible for a voucher. The CMHA waitlists were ran by preference points and time/date of application. Once those applicants were pulled the waitlist was not saved to Excel. The preference point list was then sorted alphabetically for sign in purposes and tracking of applicant documentation. This is the list that was provided to the auditor.

View Audit 300341 Questioned Costs: $1

Finding 389337 (2023-002)

Material Weakness 2023

Columbiana Metropolitan Housing Authority

OH

Questioned Costs HUD Housing Programs Material Weakness

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Michael McDo...

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Michael McDougle, HCV Manager, will be responsible to implement this corrective action by June 30, 2024. CMHA has been working diligently over the past IO months to implement this corrective action with the current two CMHA employee inspectors that are following up on the life and safety 24 hour inspections and also the 30 day follow ups. When landlords have informed CMHA that they are unable to find contractors to complement the maintenance failed items, CMHA is making a note on the inspection forms and tenant file as landlords inform CM HA that they are in need of additional time. The inspection reports under this audit were completed by the contractor, Inspection Group and have since then been corrected. To date, all of the failed inspections have been reinspected and passed.

View Audit 300341 Questioned Costs: $1

Finding 389336 (2023-001)

Material Weakness 2023

Columbiana Metropolitan Housing Authority

OH

Questioned Costs HUD Housing Programs Material Weakness

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Voucher programs and will implement internal control procedures that will ensure compliance with federal regulations. Michael McDou...

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Voucher programs and will implement internal control procedures that will ensure compliance with federal regulations. Michael McDougle, HCV Manager, will be responsible to implement this corrective action by June 30, 2024. CMHA has been working diligently over the past IO months to correct the inspection process that was not completed by the contracted inspectors through Inspection Group. Tenants were under the impression that they were not required to have inspections if someone was sick in their household, as previously waived during the pandemic. The HCV tenants have since been informed with each month's recertification mailing that they are required under HUD regulations to have an annual inspection. CMHA has also trained and assigned two HCV staff to become inspectors and have a process in place where one employee completes the annual inspections and the other employee follows up on the reinspection as needed. If inspections are not completed by time of recertification, the HAP payment is held. To date, annual inspections have been completed by CMHA staff.

View Audit 300341 Questioned Costs: $1

Finding 389334 (2023-001)

Significant Deficiency 2023

Lake County Crisis Center D/b/a A Safe Place

IL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure t...

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. Update: A Safe Place developed an infrastructure and implemented internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. The Program Administrative Manager will ensure all program performance reports (PPR) will be reviewed and submitted timely.

View Audit 300326

Finding 389325 (2023-002)

Significant Deficiency 2023

Chatham University

PA

Internal Control / Segregation of Duties

Chatham University’s Response to Schneider Downs’ Finding 2023 - 002 - Student Financial Assistance - Cluster, Department of Education Programs, in connection with their audit of the University’s financial statements for the year ended June 30, 2023. The Gramm-Leach-Bliley Act (Public Law 106-102)...

Chatham University’s Response to Schneider Downs’ Finding 2023 - 002 - Student Financial Assistance - Cluster, Department of Education Programs, in connection with their audit of the University’s financial statements for the year ended June 30, 2023. The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314). The audit finding was based on 16 CFR 314.4(f), which requires the University to have a policy addressing how the institution will oversee its information system service providers. Issue and Cause: The University does not have a vendor management review process for information system service providers. Action Plan: The University acknowledges the specific requirements outlined in the finding and presents the following action plan to address the requirements of 16 CFR 314. • The University has a draft Vendor Access to Internal Systems Policy developed in 2021 that needs to be finalized and formally adopted. • The Chief Information Officer will review, update, and finalize this policy to ensure compliance with 16 CFR 314, 4(f). • The policy will be added to the University’s Cyber & Regulatory Compliance Policy document on the Intranet and any public-facing web pages as necessary. • The policy will be distributed to applicable information system service providers. • A process for the mandatory annual review and acknowledgment of the policy with applicable vendors will be implemented. • The University will consider the costs and benefits of using external resources or firms to advise and help implement this action plan. Chatham University’s Chief Information Officer, Paul Steinhaus, is responsible for implementing this corrective action by May 1, 2024.

View Audit 300314

Finding 389321 (2023-001)

Significant Deficiency 2023

Tougaloo College

MS

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid ...

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid Relief, and Economic Security (CARES) Act Program: • There was no evidence provided regarding the submission of the annual and quarterly reports. Recommendation – We recommend that the College ensure reporting requirements are met for all grant programs. Corrective Action – The Office of Fiscal Affairs understands the importance of federal compliance. The U.S. Department of Education was contacted about the late filings. Under federal guidance, the Year 3 quarterly reports were submitted on the College website in January 2024. The annual report for Year 3 will be submitted in July 2024 when the U. S. Department of Education reopens the portal, Annual Report Data Collection Tool.

View Audit 300307

Finding 389283 (2023-002)

Significant Deficiency 2023

Early Learning Coalition of the Big Bend Region, Inc.

FL

Cash Management Reporting Internal Control / Segregation of Duties

Finding 2023-002: Internal Control over Compliance and Compliance with Cash Management Federal Programs ALN: 93.575, 93.596, 93.558 Criteria: In accordance with the grant agreement, and Division of Early Learning (DEL) Program Guidance 240.01, Cash Management Procedures, any advance that cannot be...

Finding 2023-002: Internal Control over Compliance and Compliance with Cash Management Federal Programs ALN: 93.575, 93.596, 93.558 Criteria: In accordance with the grant agreement, and Division of Early Learning (DEL) Program Guidance 240.01, Cash Management Procedures, any advance that cannot be expended or offset by September 18, must be returned to DEL by September 30 of the following year. Condition: The Coalition did not timely remit the unexpended advance related to the 2022-2023 fiscal year in compliance with the grant agreement and DEL Program Guidance. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with grant and DEL Program Guidance. Effect: The Coalition did not timely remit the unexpended advance related to the 2022-2023 fiscal year to DEL until January 8, 2024. Recommendation: We recommend the Coalition implement procedures to ensure that all advances are reconciled on a monthly basis and remitted to DEL in accordance with the grant agreement and DEL guidance. Corrective Action Plan: ELC Management will make sure that measures are in place to ensure all advances are reconciled monthly and paid timely back to DEL. Responsible Party: Felicia Milton, CFO Anticipated Completion Date: March 2024

View Audit 300296

Finding 389279 (2023-003)

Material Weakness 2023

Saint Louis University

MO

Matching / Level of Effort / Earmarking Student Financial Aid Internal Control / Segregation of Duties § 200.303

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust...

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.

View Audit 300294

Finding 388594 (2023-001)

Significant Deficiency 2023

School District Borough of Brentwood

PA

Internal Control / Segregation of Duties

School District Borough of Brentwood agrees with the finding and the recommended procedures have been implemented.

View Audit 300283

Finding 388588 (2023-002)

Significant Deficiency 2023

School District Borough of Brentwood

PA

Internal Control / Segregation of Duties

School District Borough of Brentwood agrees with the finding and the recommended procedures have been implemented

View Audit 300283

Finding 388587 (2023-002)

Material Weakness 2023

Chatham County Housing Authority

NC

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

2023-002 ALN 14.871 – Section 8 Housing Choice Vouchers Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: N. Lee Staton, Executive Dire...

2023-002 ALN 14.871 – Section 8 Housing Choice Vouchers Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: N. Lee Staton, Executive Director Projected Completion Date: June 30, 2024

View Audit 300281

Finding 388585 (2023-004)

Material Weakness 2023

Siouxland Human Investment Partnership, Inc.

IA

Cash Management Material Weakness Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.305

Federal Agency Name: Department of Education Pass-through Entity: State of Iowa Department of Education Federal Financial Assistance Listing #84.287 Program Name: Twenty-First Century Community Learning Centers Program Cash Management Material Weakness in Internal Control over Compliance Finding S...

Federal Agency Name: Department of Education Pass-through Entity: State of Iowa Department of Education Federal Financial Assistance Listing #84.287 Program Name: Twenty-First Century Community Learning Centers Program Cash Management Material Weakness in Internal Control over Compliance Finding Summary: No support could be provided for the third quarter draw requests to substantiate a secondary level of review was completed prior to submission of the draws. Documentation to support the review of draw requests prior to submission was not retained during the transition period in the Finance Director role. Corrective Action Plan: SHIP had a one-month period of transition in 2023 in which there was no one in the Finance Director role. The Executive Director took over those duties and also contracted for higher level review and approval from a third-party accounting firm during the transitional period. All draws were reviewed, approved and even supported by the Executive Director and the contractors. SHIP did provide current auditors with the time tracking from the contracted accounting firm that they did review the 3rd quarter report, the report was just not officially signed off on. Staff requesting the draw forgot to get one approval signature for quarter three, all others were signed. Moving forward, SHIP will re-train staff to ensure all draws are signed off on. Responsible Individuals: Mindy Baylor - SHIP Finance Director Anticipated Completion Date: September 2023

View Audit 300275

Finding 388569 (2023-002)

Material Weakness 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security progra...

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has updated its Gramm-Leach-Bliley Act Policy to be in accordance with the requirements, and we have also put in place adequate controls and practices to ensure that the policy is monitored effectively. Anticipated Completion Date- February 1, 2024

View Audit 300264

Finding 388567 (2023-001)

None 2023

Town of Orange

MA

Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Transportation The Town of Orange, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Transportation The Town of Orange, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY COVID-19 Coronavirus State and Local Recovery Funds Federal Assistance Listing Number 21.027 2023-001 – Reporting to the Federal Government Compliance Requirement: Reporting Type of Finding: Compliance and Internal Control over Compliance – Other Matter Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the U.S. Treasury that includes the total grant expenditures incurred for the reporting period. Since the Town is a Non-Entitlement Unit that received less than $10 million in funding, the Town was required to submit a project and expenditure report by April 30, 2022, and annually thereafter. Condition: The electronic report the Town submitted to the U.S. Treasury on April 30, 2023 reported the incorrect amount for total expenditures. Questioned Costs: None Reported. Context: The Town filed the required project and expenditure report in a timely manner. However, while submitting the report the Town entered the incorrect amount for total expenditures. Effect: The expenditures reported on the Town’s project and expenditure report did not match the accounting records. Cause: The Town entered the incorrect amount when submitting the report. Recommendation: Management should correct the report in the next reporting submission. Views of Responsible Officials and Planned Corrective Actions: Management made a good faith effort to correctly report its expenditures to the Treasury Department but made an error while filling out the report. Management will rectify the issue with the next submission in accordance with U.S. Department of Treasury’s recommended guidance. If the Oversight Agency has questions regarding this plan, please call Amber Dupell, Town Accountant at 978-544-1100.

View Audit 300260

Finding 388566 (2023-001)

Material Weakness 2023

Berlin Housing Authority

NH

HUD Housing Programs Internal Control / Segregation of Duties § 200.514

BHA Audit Finding Response: Finding reviewed with program specialist and manager with following action plan in place to ensure key EIV reports are run on a scheduled basis and appropriate actions are taken; Policies and procedures surrounding EIV reviewed. Program specialist implemented the use of "...

BHA Audit Finding Response: Finding reviewed with program specialist and manager with following action plan in place to ensure key EIV reports are run on a scheduled basis and appropriate actions are taken; Policies and procedures surrounding EIV reviewed. Program specialist implemented the use of "tickler" reminders on outlook calendar to prompt EIV reports within 90 days for new move-ins. The manager will monitor monthly and quarterly to ensure EIV report is run for all move-ins and recertifications.

View Audit 300252

Finding 388562 (2023-010)

Material Weakness 2023

Crothersville Community Schools

IN

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

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted...

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted each annual data report without a review or oversight process in place to prevent, or detect and correct, errors. All five reports were selected for testing, two of which were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start to review the information entered into the required ESSER reports prior to submission and supporting documentation will be retained. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388561 (2023-009)

Material Weakness 2023

Crothersville Community Schools

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303 § 200.313

Finding 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation made one purchase of equipment with grant funds, a school bus in the amount of $204,961. The school bus was acquired in June 2021, late in the...

Finding 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation made one purchase of equipment with grant funds, a school bus in the amount of $204,961. The school bus was acquired in June 2021, late in the prior audit period, and the expenditure was reimbursed under the ESSER II award in July 2021 in the current audit period. The lack of internal controls resulted in material noncompliance with the equipment requirements of the federal award. The School Corporation did not maintain a capital asset ledger during the audit period, so the equipment purchased was not maintained in the property records as required. Additionally, the School Corporation did not perform a physical inventory of equipment at least once every two years as required. The School Corporation did comply with the requirements to appropriately safeguard and maintain the equipment, but no key control was identified that would prevent, or detect and correct, noncompliance with these requirements if it were to occur. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and the superintendent will investigate a capital asset program that we will be able to maintain ourselves. This might include reaching out to districts similar in size to see what they utilize or to work with an agency that can get us started. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388559 (2023-008)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.207 § 200.303

FINDING 2023-008 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had not adopted a test security policy. Although training had been provided to staff on an annual basis, the School Co...

FINDING 2023-008 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had not adopted a test security policy. Although training had been provided to staff on an annual basis, the School Corporation had not established a system of internal controls to ensure monitoring of Assessment System Security occurred and was adequate. There were no INDIANA STATE BOARD OF ACCOUNTS 40 documented internal controls in place to ensure all individuals that should have received training did receive training. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will implement a Test Security Policy. Currently, the board is on the first reading and the second reading will occur on April 15, 2024. Superintendent is now the Title I director and is keeping the training certifications on file and retained for future audits. Anticipated Completion Date: April 15, 2024

View Audit 300250

Finding 388557 (2023-007)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Special Tests & Provisions § 200.303 § 200.334

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Summary of Finding: The School Corporation did not have effective internal controls in place to ensure the correct reporting requirements fo...

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Summary of Finding: The School Corporation did not have effective internal controls in place to ensure the correct reporting requirements for the High School Graduation Rate were being followed and that documentation was retained for audit. There was no tangible evidence of a process in place over the Annual Report Card/High School Graduation Rate to ensure that mobility codes were entered correctly. Of the 11 students tested, documentation was not presented for 9 students that were removed from the high school graduation cohort. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. A reminder will go to the High School guidance counselor, secretary, and principal about getting withdrawal forms from students and placing the form in their permanent records. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388555 (2023-006)

Material Weakness 2023

Crothersville Community Schools

IN

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

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or...

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the final expenditure report for the Title I School Improvement for program year 2021, due December 30, 2021, was submitted March 7, 2024. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 39 Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start reviewing the final expenditure reports prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388553 (2023-005)

Material Weakness 2023

Crothersville Community Schools

IN

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

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Matching, Level of Effort, Earmarking INDIANA STATE BOARD OF ACCOUNTS 38 Summary of Finding: Earmarking: There was no oversight or review process in place to ensure monitoring of each required set aside. The School Corp...

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Matching, Level of Effort, Earmarking INDIANA STATE BOARD OF ACCOUNTS 38 Summary of Finding: Earmarking: There was no oversight or review process in place to ensure monitoring of each required set aside. The School Corporation did not provide documentation to show that the obligation was met or not met to service all the homeless students in the School Corporation and did not transfer the unused funds to the next grant award. Level of Effort: There was an oversight or review process at the School Corporation level over vendor expenditures; however, the oversight and review process was not documented to ensure the data used to complete the Form 9 was reported accurately in the correct fund, account, and object code. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Communication from IDOE stating we do not have homeless students will start to be retained for support and we will obtain correct procedures from IDOE on proper procedures on transferring the unused funds to the next grant award. The Superintendent or Board will start to review vendor payments are paid from the proper fund, account and object code. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388551 (2023-004)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.334 § 200.77 § 200.78

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to...

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. There was no October 1 Real Time report presented for audit for either fiscal year 2020-2021 or 2021- 2022, which would have been used to pull in enrollment and poverty information for the 2021-2022 and 2022-2023 grants, respectively. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will retain the Real Time reports and other supporting documentation. Superintendent will also start verifying the numbers pre-populated on the grant application to ensure correct reporting. Another person will start reviewing the application prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388549 (2023-003)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Summary of Finding: The School Corporation did not have a properly developed internal control process over payroll transactions to ensure expenditures were allowed and in conformance with the cost prin...

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Summary of Finding: The School Corporation did not have a properly developed internal control process over payroll transactions to ensure expenditures were allowed and in conformance with the cost principles. The Program Administrator reviewed a report attached to program reimbursement requests which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee and related payroll benefits being paid from the grant fund. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 37 The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will start to review the detailed payroll report posted to the Title I funds to match to the reimbursement request. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388538 (2023-004)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will b...

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will be uploaded into our SIS within 1-2 days. When the report is loaded in our SIS, we will review each file to see which files did not transmit to COD. For the files that fail, we will correct the error/issue in our SIS and send the file out to COD in a timely manner for processing. After our Pell reconciliation is complete, we wll review our SIS and COD to ensure records agree between our SIS and COD (award amounts and processing dates). WCU is currently reviewing its policies and procedures around COD reporting and will ensure students' information is reported timely and accurately between our SIS and COD. WCU understands and agrees that the errors identified in the program review relate to Pell Grant disbursement reporting; and agrees, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculation as students' interest accrues based on the disbursement date reported to COD. Going forward, WCU will review the SIS and COD data to ensure that all booked files link to the appropriate dates between our SIS and COD. Kutztown University: We reviewed our policies and procedures for COD reporting. A financial aid resource has implemented a sweep every fourteen days to ensure that compliance with the 15-day rule for PELL reporting is met consistently.

View Audit 300242

Corrective Action Plans

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