Corrective Action Plans

Finding 391569 (2023-009)

Significant Deficiency 2023

NY

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

Finding No. 2023-009 Department(s): New York City Department of Investigation Program(s): Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s): Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address...

Finding No. 2023-009 Department(s): New York City Department of Investigation Program(s): Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s): Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address the deficiencies and improve compliance with equipment and real property management requirements. • Strengthen Controls over the Inventory Process: We developed and implemented additional controls over the inventory process to ensure that equipment dispositions are updated in the equipment records, inventories performed are reconciled back to equipment records, and biennial inventory counts are consistently performed over all equipment within the required timeframe. • Training for Personnel: We provide training to all personnel involved in the equipment and real property management process, including property officers and program managers, to ensure they are aware of the new controls and standard operating procedure, and understand their roles and responsibilities related to compliance requirements. • Continuous Monitoring: We developed a continuous monitoring program to ensure that the new controls and procedures are being followed, and to identify any areas for improvement. • We developed Equitable Sharing Program Standard Operating Procedures (“SOPs”) for the New York City Department of Investigation (“DOI” or “Department”) apply to the Department’s use of U.S. Department of Justice (“DOJ”) Equitable Sharing Program (“Program”) funds. These SOPs are intended to complement, not replace, the required guidance found in the “Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies” (July 2018) (“Guide”) and Equitable Sharing Wires (“Wires”), as well as any relevant Department and City policies and procedures. The agency is actively pursuing a centralized inventory management system to improve the effectiveness of inventory management. These corrective actions will help to ensure that federally funded equipment is accurately recorded on inventory records and that inventory is not misplaced, misappropriated, or otherwise disposed of outside of the requirements of federal guidelines. We appreciate the opportunity to address the audit findings, and we are committed to implementing these corrective actions. Anticipated Completion Date: March 31, 2025 Person(s) Responsible for Implementation: Caspar Barrow, Executive Director of Finance/CFO CBarrow@doi.nyc.gov (212)-825-0666 Orane Gordon, Internal Auditor OGordon@doi.nyc.gov (212)-825-0123

View Audit 302042

Finding 391568 (2023-016)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health ...

Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period of the waivers until today, from February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow up to ideally have participants comply with requirements but if necessary to terminate assistance for those who do not comply. Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391565 (2023-015)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding No. 2023-015 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...

Finding No. 2023-015 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): These deficiencies result from HPD adopting HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of inspections and adverse actions. HPD conducted limited inspections and did not take enforcement action during the waiver period of 2/1/2020 through 12/31/2021. These waivers ended in 2022 in the midst of a significant HPD staffing shortage. HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Housing Maintenance Code inspection team that mirrored the 27 percent experienced in HPD’s rental subsidy program administration team. Although HPD’s COVID-era policies have ceased, and normal processes are now in effect, it will take a significant period of time for full standard operations to resume. Corrective Action(s): 1. Develop a detailed tracking process for routine inspection scheduling. 2. Prioritize inspections for units that are upcoming or those that have gone the longest without an inspection. 3. Develop a detailed tracking and follow up process for enforcing failed inspections. 4. Make every effort to ensure staff vacancy rates are addressed through in house recruitment or other means as needed. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391564 (2023-014)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...

Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow-up to ideally have participants comply with requirements (but if necessary to terminate assistance for those who do not comply). Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391561 (2023-005)

Significant Deficiency 2023

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are repor...

Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are reportedly above the prevailing Fair Market Rent (FMR) limits per bedroom size, and document follow up activities accordingly. Staff will continue to review support documentation during monitoring visits to ensure client rent calculations are current and accurately completed. HASA will continue facilitating monthly technical assistance meetings and convene training sessions with housing providers to address emerging issues and contract compliance findings from monitoring visits. Anticipated Completion Date: April 1, 2024 and ongoing Person(s) Responsible for Implementation: Xiomara Pamela Farquhar, Assistant Deputy Commissioner farquharx@hra.nyc.gov

View Audit 302042

Finding 391560 (2023-004)

Significant Deficiency 2023

The City of New York

NY

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

Finding No. 2023-004 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.241, Housing Opportunities for Persons with Aids Corrective Action(s): HASA will revamp its contract monitoring policies and procedures to ensure sampling of housing inspectio...

Finding No. 2023-004 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.241, Housing Opportunities for Persons with Aids Corrective Action(s): HASA will revamp its contract monitoring policies and procedures to ensure sampling of housing inspection reports and related maintenance and repairs documentation are included to assess compliance with housing quality standards. Documentation reviewed will also include confirmation of apartments’ readiness prior to occupancy and corrective action measures taken to address outstanding deficiencies, including failed inspections. Anticipated Completion Date: April 1, 2024 and ongoing Person(s) Responsible for Implementation: Xiomara Pamela Farquhar, Assistant Deputy Commissioner farquharx@hra.nyc.gov

View Audit 302042

Finding 391558 (2023-002)

Material Weakness 2023

The City of New York

NY

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

Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar er...

Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar error type but significantly decreased to $296 from over $18,000. Included in the FY22 recommended Corrective Action was the onboarding of the Executive Director to shepherd the charge with strengthening the teams’ internal governance, appropriate monitoring and future compliance. Adversely, the onboarding of the executive director was lengthy and only recently finalized in the 2nd quarter of FY24. HRA agrees to strengthen internal controls and the new Executive Director is working with the team to ensure they are intentional in appropriately applying the correct formula for calculating allowable cost, particularly the inclusion of “gross” and not “net” income. The Quality Assurance Tool has been updated including specific sub-items to ensure allowable cost is correctly calculated as well as the other deliverables. Corrective Action(s) • Strengthen internal governance and future compliance. • Executive Director for the Home-TBRA now on board. • Update the Quality Assurance tool that includes sub-items information that supports improved review and approval. • Provide refresher training for staff involved with TBRA to improve performance and outcomes. Anticipated Completion Date: June 30, 2024 and ongoing Person(s) Responsible for Implementation: Dori Hopkins-Figeroux, Director - HTBRA hopkinsfigerouxd@hra.nyc.gov 929-252-6089 Jordan Worrell, Executive Director RAP/HTBRA worrellj@hra.nyc.gov 929-252- 5403 Dwana Abraham, Assistant Deputy Commissioner abrahamd@hra.nyc.gov 929-221-6726

View Audit 302042 Questioned Costs: $1

Finding 391557 (2023-003)

None 2023

The City of New York

NY

Internal Control / Segregation of Duties Special Tests & Provisions HUD Housing Programs

Finding No. 2023-003 Department(s): New York City Department of Human Resources Administration Program(s): Assistance Listing Number 14.231, Emergency Solutions Grants Program Corrective Action(s): The oversight in 2022 (regarding obligation of the 2021 grant) occurred prior to the initiation of...

Finding No. 2023-003 Department(s): New York City Department of Human Resources Administration Program(s): Assistance Listing Number 14.231, Emergency Solutions Grants Program Corrective Action(s): The oversight in 2022 (regarding obligation of the 2021 grant) occurred prior to the initiation of the Corrective Action Plan implemented to strengthen the internal controls based on the FY 2022 Single Audit finding (regarding obligation of the 2020 grant). As indicated in our response to the FY 2022 finding, we will ensure in the future that we strengthen our internal controls to ensure that 100% of the total ESG grant amount is obligated within 180 days of the signed grant agreement. This will include an added layer of review by the Associate Commissioner of Homeless Policy and Innovation, who oversees the unit that obligates the funds in IDIS. Additionally, as communicated in the ICQ, Federal Homeless Policy and Reporting (“FHPR”) and Finance have detailed the following process: • FHPR will notify Finance when the new ESG funding is awarded and the total amount. • Finance will contact OMB to share that a new award was announced and to expect an updated FY budget construct. • FHPR will work with Programs to confirm funding allocations and will send an updated construct to Finance. • Finance will share updated construct with OMB. • FHPR will use updated construct to complete all funding obligations in IDIS. • FHPR will set progressive reminders following ESG award announcements to ensure the 180-day deadline is met. Going forward, these activities and action steps will be completed by a dedicated ESG staff person working within the FHPR team. This new position was created and posted, and a candidate was selected in late 2023; we expect to onboard the selected candidate shortly. Anticipated Completion Date: May 1, 2024 Person(s) Responsible for Implementation: Martha Kenton, Executive Director, Continuum of Care kentonm@dss.nyc.gov 929-221-6283 ESG Project Manager, candidate currently in the onboarding process

View Audit 302042

Finding 391540 (2023-003)

Material Weakness 2023

City of Tucker, Georgia

GA

Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: The Finance Department has implemented the use of electronic timekeeping that has established supervisory approvals that must occur before timesheets are submitted.

View Audit 302016

Finding 391531 (2023-103)

Significant Deficiency 2023

Espiritu Community Development Corporation

AZ

Subrecipient Monitoring Internal Control / Segregation of Duties

Condition and Context: The School used funding from the grant to complete renovation and construction projects. The School requested the contractors to provide certified payroll reports in the proposal meetings, however they did not obtain the reports from the contractors. Recommendation: The aud...

Condition and Context: The School used funding from the grant to complete renovation and construction projects. The School requested the contractors to provide certified payroll reports in the proposal meetings, however they did not obtain the reports from the contractors. Recommendation: The auditors recommend that the School establish a system of monitoring contracts for construction greater than $2,000 in which the wage rate requirement exists and verify the certified payroll reports are received prior to payment. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: Moving forward, the management team will include the remittance of a certified payroll report in the scope of work when obtaining bids for federally funded construction projects as a primary condition of awarding the contract. Anticipated Completion Date: June 30, 2024

View Audit 302013

Finding 391515 (2023-102)

Significant Deficiency 2023

Espiritu Community Development Corporation

AZ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.327

Condition and Context: The four quarterly reports were not filed within the 30 days required by the contract. Recommendation: The auditors recommend that the School establish a system of monitoring for the filing of all required reporting and that the chief operating officer review the monitoring ...

Condition and Context: The four quarterly reports were not filed within the 30 days required by the contract. Recommendation: The auditors recommend that the School establish a system of monitoring for the filing of all required reporting and that the chief operating officer review the monitoring list on a regular basis consistent with the timing of report filings. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The management team will establish a system for monitoring all required reporting deadlines. This system will be designed to track the filing requirements for each grant and contract, ensuring that deadlines are clearly identified and adhered to. The Chief Operating Officer will be designated as the responsible authority for overseeing the monitoring process. They will review the monitoring list on a regular basis, ensuring that all required reports are filed in a timely manner. The grant team will institute regular compliance reviews to assess our adherence to reporting deadlines and identify any areas for improvement. Anticipated Completion Date: June 30, 2024

View Audit 302013

Finding 391459 (2023-001)

Significant Deficiency 2023

City of Westminster, Maryland

MD

Subrecipient Monitoring Reporting Significant Deficiency

The finance department experienced staff turnover and vacancies during the fiscal year, impacting the fiscal year end close processes. We have consulted with a fractional CFO and are now fully staffed. We are working to remedy the items noted above by assessing our current procedures and implementin...

The finance department experienced staff turnover and vacancies during the fiscal year, impacting the fiscal year end close processes. We have consulted with a fractional CFO and are now fully staffed. We are working to remedy the items noted above by assessing our current procedures and implementing changes for more effective and efficient financial reporting. We are also in the final stages of selecting new ERP software, which would be implemented during fiscal years 2025 and 2026 to allow for more streamlined processes to be implemented. We will be developing comprehensive year end close and audit preparation procedures that will ensure a timely close of the fiscal year.

View Audit 301948

Finding 391442 (2023-003)

Significant Deficiency 2023

City of Humboldt

IA

Reporting Internal Control / Segregation of Duties

A policy and procedure will be established to ensure the annual Project and Expenditure Report is submitted prior to the reporting deadline.

View Audit 301938

Finding 391440 (2023-001)

Significant Deficiency 2023

Community Action Partnership of Oregon

OR

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Corrective Action: Susan Matlack Jones (SMJ) took over as CAPO’s fiscal service provider in July of 2022. The first six months were spent largely cleaning and correcting journal entries from FY22 – a significant task. CAPO did not begin to receive truly accurate and trustworthy financial statements ...

Corrective Action: Susan Matlack Jones (SMJ) took over as CAPO’s fiscal service provider in July of 2022. The first six months were spent largely cleaning and correcting journal entries from FY22 – a significant task. CAPO did not begin to receive truly accurate and trustworthy financial statements until early in 2023. CAPO also experienced two staff losses in the finance department from March through May of 2023. In light of our growth and increased administrative needs, we revised our job posting to increase the level of fiscal skill and responsibility needed for the Finance Manager role. In September of 2023, CAPO was successful in hiring a Finance and Grants Manager with experience in federal fund accounting for Community Action and in SSVF (our major grant). Since that time, he has organized, revamped, and significantly improved internal processes to assure timely review of all finances and reconciliations and works closely with SMJ to assure overall accuracy. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of October 2023

View Audit 301926

Finding 391432 (2023-004)

Material Weakness 2023

County of Nevada

CA

Reporting Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303

The Auditor-Controller’s office will provide additional training to applicable departments to educate staff on appropriate records maintenance related to grant files and the importance documented review and approval processes. This training will provide additional education over appropriate supporti...

The Auditor-Controller’s office will provide additional training to applicable departments to educate staff on appropriate records maintenance related to grant files and the importance documented review and approval processes. This training will provide additional education over appropriate supporting documentation to verify internal controls and compliance requirements are being reasonably followed

View Audit 301919

Finding 391403 (2023-002)

Significant Deficiency 2023

County of Nevada

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.403 § 200.430 § 200.431

The County is continuing to draft and establish written procedures for county-wide and department specific use when determining the allowability of personnel costs related to federal awards. A primary function of this policy will be to provide guidance to county staff to ensure personnel costs are r...

The County is continuing to draft and establish written procedures for county-wide and department specific use when determining the allowability of personnel costs related to federal awards. A primary function of this policy will be to provide guidance to county staff to ensure personnel costs are recognized in accordance with cost principles, statues, regulations, and terms and conditions of federal awards.

View Audit 301919

Finding 391395 (2023-004)

Significant Deficiency 2023

Bethany Lutheran College, Inc.

MN

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

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.033, 84.007 Recommendation: We recommend the College implements a formalized yearly reconciliation of Federal Work Study, Perkins, and Supplemental Education Opportunity Grants. Explanation of disagreement with audit fi...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.033, 84.007 Recommendation: We recommend the College implements a formalized yearly reconciliation of Federal Work Study, Perkins, and Supplemental Education Opportunity Grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: FWS: Jeff Younge, Director of Financial Aid, directs Business Office on when to pull funds. Reconciliation between financial aid system and payroll system is done annually, prior to end of fiscal year by Director of Financial Aid. Piece we will add is for Director of Financial Aid to verify amounts requested to be pulled actually got pulled by Business Office. This has not been a problem, but additional step will serve as an extra safeguard so that all stays in balance. Perkins: No new Perkins loans are being made. Annual FISAP serves as reconciliation for this program. SEOG: Jeff Younge, Director of Financial Aid, directs Business Office on when to pull funds at time of disbursement. Piece we will add is for Director of Financial Aid to verify amounts requested to be pulled actually got pulled by Business Office. This has not been a problem, but additional step will serve as an extra safeguard so that all stays in balance. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

View Audit 301916

Finding 391390 (2023-003)

Significant Deficiency 2023

Bethany Lutheran College, Inc.

MN

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

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office looks for over award situations throughout the academic year, as changes to Cost of Attendance and financial aid (Scholarships/Grants, Loans, and Work- Study earnings) can change throughout the year. That said, Financial Aid Staff (Jeff Younge and/or Sally Sorensen) will review every student for potential over awards during the 1st two weeks of fall semester (beginning August 20, 2024), to catch any over awards that may have been created between the time of packaging, and beginning of the academic year. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

View Audit 301916 Questioned Costs: $1

Finding 391385 (2023-002)

Significant Deficiency 2023

Bethany Lutheran College, Inc.

MN

Student Financial Aid Reporting Significant Deficiency

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation ...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Issue: Taylor Theiste began official withdrawal process on 1/31/23. This date was used in Return of Title IV calculations, and entered into PowerFAIDS system. Student was asked to unenroll from the courses by the Registrar, which she did, but not until 2 days later. Resolution: Jeff Younge (Director of Financial Aid) met with Sergio Salgado (Registrar) and Lisa Shubert (Manager of Administrative Computing and Institutional Reporting) on 11/29/23. Going forward, when student indicates intent to withdraw, Registrar will unenroll the student from courses using the withdrawal date used for Title IV purposes. This will ensure that the correct date is reported to Clearinghouse, and then to NSLDS. Issue: Ben Draper began official withdrawal process on 1/20/23. Since this was the 10th day of class, he was not included in the Census Report that was run at the end of the day (although correct date was used for Return of Title IV calculations, and transcript shows Ws). Consequently, he was treated for reporting purposes as if he did not return for spring semester, and withdrawal date sent to Clearinghouse, and then on to NSLDS, reverted to last day of the previous fall semester, which was 12/15/22. Resolution: On December 20, 2023, meeting was held in Luther Hall that included the following: (Stacey Dawley, Jeff Lemke, Jason Lowrey, Ted Manthe, Daniel Mundahl, Sergio Salgado, Lisa Shubert, Renee Tatge, Estelle Vlieger, Jeff Younge) Proposal was made (and accepted by this group, and later the President) that stated the following: 1. Add/Drop period is day 1-5 of fall and spring semester. During this time, classes can be added, and dropped courses disappear from student schedule/transcript, as if student did not begin the class. Courses withdrawn from after 5th day result in a grade on the transcript (W, WP/WF, or F, depending on the timing of the withdrawal). This is the current policy, not a proposed change. 2. Change wording of refund policy, so that instead of Week 1, Week 2, Week 3...it is worded as Day 1-5, Day 6-10, Day 11-15... (This solves the issue of 1st week being only 4 days in the fall, but 5 days in the spring, and the day after Labor Day being the 10th day of class, but 3rd week of the semester). 3. Change Census report figures from being (10th day) to (end of 5th day). That does not mean census report is available on the 5th day, but just that the information is “locked” as of that day for reporting purposes. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

View Audit 301916

Finding 391381 (2023-001)

Material Weakness 2023

Marshall Public Schools

WI

Internal Control / Segregation of Duties

Finding #2023-001 – Material Audit Adjustments Condition: The auditors proposed audit adjustments that, if not made, would have resulted in the financial statements being materially misstated. Effect: The District’s system of internal control may not prevent, detect, or correct misstatements in t...

Finding #2023-001 – Material Audit Adjustments Condition: The auditors proposed audit adjustments that, if not made, would have resulted in the financial statements being materially misstated. Effect: The District’s system of internal control may not prevent, detect, or correct misstatements in the financial statements. Financial reports generated by the accounting system may not provide an accurate reflection of the District’s financial position or activities. Not reconciling accounts on a timely basis could lead to errors or other problems not being recognized and resolved. Cause: Financial information was not recorded in a timely manner and material adjustments were needed in order to correct various transactions Criteria: Proper financial closing and year-end reconciliation procedures should be in place to identify and adjust the financial records to ensure the financial statements are fairly stated. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded and reconciled in a timely manner. Response: The District acknowledges their responsibility for the financial statements and recording of the current year activity. Going forward, the District will verify that all activity is completely and accurately recorded in the financial records and reflected on the financial statements. Marshall School District's Corrective Action Plan: School Business Manager Kristin Wilkinson will engage in the following tasks to better understand and put processes in place to address the finding: Meet with experienced School Business Managers Wendy Brockert and/or Tim Stellmacher in regards to ensuring account balances are properly recorded and reconciled in a timely manner. When Ongoing. Completed by 6/30/2024. Attend WASBO University class through Wisconsin Association of School Business Officials, specifically Internal Controls for the School Business Office. When Ongoing. This specific course completed 3/19/2024. Complete one full year as School Business Manager at Marshall Public Schools (first position in this role in any district) learning about the role, structures and processes that are in place, need to be put in place, and need to be refined. When May 2, 2024. Implement procedures to ensure account balances are properly recorded and reconciled in a timely manner. When 6/30/2024.

View Audit 301915

Finding 391379 (2023-003)

Material Weakness 2023

Ifoster, Inc.

CA

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-003 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial reporting. Ensuring accruals and expenses are recorded in the appropriate time period and meet the criteria for recognition is a key component of effect...

Finding 2023-003 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial reporting. Ensuring accruals and expenses are recorded in the appropriate time period and meet the criteria for recognition is a key component of effective internal control over financial reporting. Certain expenses were not recorded in the correct financial reporting period. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Payroll accruals, which have in the past been immaterial, are being accrued on a monthly basis in fiscal year ending June 30, 2024. Anticipated Completion Date: Ongoing

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Finding 391378 (2023-002)

Material Weakness 2023

Ifoster, Inc.

CA

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-002 Finding Summary: Internal controls should be in place to provide reasonable assurance that protects iFoster, Inc. from errors or omissions. iFoster, Inc. internal control system did not require consistent approval of grant expenditures as well as properly allocating costs within the...

Finding 2023-002 Finding Summary: Internal controls should be in place to provide reasonable assurance that protects iFoster, Inc. from errors or omissions. iFoster, Inc. internal control system did not require consistent approval of grant expenditures as well as properly allocating costs within the accounting program. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Due to the compressed timeframe between initial single audits, corrective action could not be implemented. All grant expenditures now require approval and QuickBooks will be used to allocate costs in fiscal year ending June 30, 2024 rather than using Excel. Anticipated Completion Date: April 20, 2024

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Finding 391377 (2023-001)

Material Weakness 2023

Ifoster, Inc.

CA

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-001 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial statement reporting. One of the components of an effective system of internal control over financial reporting is the preparation of full disclosure fin...

Finding 2023-001 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial statement reporting. One of the components of an effective system of internal control over financial reporting is the preparation of full disclosure financial statements that do not require adjustment as part of the audit process. A second component is that reconciliations and transactions are properly reviewed and approved by the appropriate personnel. As auditors, we were requested to draft the financial statements and accompanying notes to the financial statements. Certain reconciliations and journal entries were not reviewed and approved. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Due to the compressed timeframe between initial single audits, corrective action could not be implemented. All journal entries are now approved as a part of our month end close process. Although we anticipate the auditor to continue to prepare the financial statements, we believe addressing the internal control noted above will address any material errors noted. Anticipated Completion Date: Ongoing

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Finding 391374 (2023-005)

Significant Deficiency 2023

Board of Education of Prince George's County Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.344

Special Education-Grants for Infants and Families– Assistance Listing No. 84.181 Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Explanation of disagreement with audit fin...

Special Education-Grants for Infants and Families– Assistance Listing No. 84.181 Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. Professional development sessions will be attended to enhance invoice scrutiny for allowable expenses within the grant period. Quarterly reminders and Financial Quarterly Review meetings will be instituted for supervisors, ensuring timely action on outstanding purchase orders. Following will be implemented: 1. Infants and Toddler Supervisor will hold monthly meetings with the Financial Analyst and the secretarial staff to ensure consistent actions are taken when generating purchase orders and processing invoices. 2. The Infants and Toddler secretary will review invoice dates against contracts and purchase orders to ensure they fall within grant timelines before submitting them to the supervisor for signature. 3. Infants and Toddler Supervisor will confirm that purchases made with grant funds are allowable and within the designated grant period. The Supervisor will cross-reference invoice dates against grant periods before signing and sending to accounts payable. 4. The infants and Toddler Supervisor will confirm the work being invoiced has been completed and vendor details are checked, and dates verified. 5. Grant Accountants will provide transaction detail reports (at least quarterly). The Infant and Toddlers Coordinating Supervisor will review and sign-off on the quarterly transaction reports. 6. The Financial Analyst will meet monthly with the Infants and Toddler Supervisor and Coordinating Supervisor to ensure grant allowable expenses are adhered to and invoicing is updated and falls within grant-specific timelines. Name(s) of the contact person(s) responsible for corrective action: Office of Infant and Toddlers/Coordinating Supervisor & Fiscal Analyst and Business Operation Office/Fiscal Analyst & Office of Infant and Toddlers/Coordinating Supervisor Planned completion date for corrective action plan: June 2024

View Audit 301912 Questioned Costs: $1

Finding 391341 (2023-004)

Significant Deficiency 2023

Board of Education of Prince George's County Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.344

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Explanation of disagreement with audit finding: There is...

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. Professional development sessions will be attended to enhance invoice scrutiny for allowable expenses within the grant period. Quarterly reminders and Financial Quarterly Review meetings will be instituted for supervisors, ensuring timely action on outstanding purchase orders. Following will be implemented: 1. Infants and Toddler Supervisor will hold monthly meetings with the Financial Analyst and the secretarial staff to ensure consistent actions are taken when generating purchase orders and processing invoices. 2. The Infants and Toddler secretary will review invoice dates against contracts and purchase orders to ensure they fall within grant timelines before submitting them to the supervisor for signature. 3. Infants and Toddler Supervisor will confirm that purchases made with grant funds are allowable and within the designated grant period. The Supervisor will cross-reference invoice dates against grant periods before signing and sending to accounts payable. 4. The infants and Toddler Supervisor will confirm the work being invoiced has been completed and vendor details are checked, and dates verified. 5. Grant Accountants will provide transaction detail reports (at least quarterly). The Infant and Toddlers Coordinating Supervisor will review and sign-off on the quarterly transaction reports. 6. The Financial Analyst will meet monthly with the Infants and Toddler Supervisor and Coordinating Supervisor to ensure grant allowable expenses are adhered to and invoicing is updated and falls within grant-specific timelines. Name(s) of the contact person(s) responsible for corrective action: Office of Infant and Toddlers/Coordinating Supervisor & Fiscal Analyst and Business Operation Office/Fiscal Analyst & Office of Infant and Toddlers/Coordinating Supervisor Planned completion date for corrective action plan: June 2024

View Audit 301912 Questioned Costs: $1

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