Corrective Action Plans

Finding 370791 (2023-001)

Significant Deficiency 2023

MI

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Condition: There was a lack of timely account reconciliations performed by the Organization to ensure all withdrawals from the replacement reserve account had proper HUD approval and all required monthly deposits were made. During the year ended June 30, 2023, withdrawals of $4,202 and $4,025 were m...

Condition: There was a lack of timely account reconciliations performed by the Organization to ensure all withdrawals from the replacement reserve account had proper HUD approval and all required monthly deposits were made. During the year ended June 30, 2023, withdrawals of $4,202 and $4,025 were made from the replacement reserve without HUD authorization, and the Organization failed to increase the monthly reserve from $1,723.67 to $2,249.54 for May and June of 2023. Planned Corrective Action: Management acknowledges the significant deficiency in internal control over compliance and is implementing measures to improve this internal control over compliance. The underfunded amount of $9,279 was deposited to the reserve for replacement account on July 28, 2023. Contact person responsible for corrective action: Bruce Blalock, Sr. VP of Finance and Obligated Group Operations Anticipated Completion Date: July 28, 2023

View Audit 292460

Finding 370789 (2023-001)

Significant Deficiency 2023

Midland Univeristy

NE

Questioned Costs Student Financial Aid Reporting

The University agrees with the finding. The 21-22 audit, which ended in the spring of 2023, identified similar issues regarding Title IV credit balances. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional finding...

The University agrees with the finding. The 21-22 audit, which ended in the spring of 2023, identified similar issues regarding Title IV credit balances. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional findings in the current audit year. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review was conducted of current internal control processes and an evaluation of additional reporting within the student information system was done to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances were monitored during the Spring 2023 terms and new procedures have been put in place for the Fall 2024 term.

View Audit 292453 Questioned Costs: $1

Finding 370786 (2023-002)

Significant Deficiency 2023

Willow Oak Montessori Foundation, Inc.

NC

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

The Foundation remedied the deficiency by depositing the required amount into the account and has an ongoing autopay set up to ensure the monthly amounts are deposited. In addition, the Foundation will reconcile the accounts regularly to ensure the requirement for the account is met.

View Audit 292428

Finding 370779 (2023-006)

Significant Deficiency 2023

Clemson University

SC

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

After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit suppor...

After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit support to further explore this scenario and determine what would need to be changed with field mapping and review, if anything. Anticipated Completion Date: June 1, 2024 Person Responsible for Corrective action: Cecil (Rock) McCaskill, Associate Registrar Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

View Audit 292421

Finding 370778 (2023-005)

Significant Deficiency 2023

Clemson University

SC

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

The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks....

The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks. Student Financial Services staff will communicate with students who have outstanding checks as a proactive measure to decrease the volume of uncashed stale-dated checks. Anticipated Completion Date: October 31, 2023 Person Responsible for Corrective action: Rebecca Pruitt, Director of Student Financial Services Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

View Audit 292421

Finding 370777 (2023-004)

Significant Deficiency 2023

Clemson University

SC

Student Financial Aid Reporting Significant Deficiency § 200.303

The Office of Student Financial Aid will engage with the Office of Internal Audit (IA) to review the FISAP, and if any errors are found, will make corrections during the allotted time in December. Supporting schedules are centrally stored and will be made available to IA. Anticipated Completion Date...

The Office of Student Financial Aid will engage with the Office of Internal Audit (IA) to review the FISAP, and if any errors are found, will make corrections during the allotted time in December. Supporting schedules are centrally stored and will be made available to IA. Anticipated Completion Date: December 1, 2023 Person Responsible for Corrective action: Elizabeth Milam, Director of Financial Aid Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

View Audit 292421

Finding 370776 (2023-003)

Significant Deficiency 2023

Clemson University

SC

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

We will continue to proactively monitor for system data irregularities and take corrective action as needed. We have implemented a weekly review of Banner to COD data for Pell disbursement activity to quickly identify and resolve discrepancies. A senior staff member completes this review with findin...

We will continue to proactively monitor for system data irregularities and take corrective action as needed. We have implemented a weekly review of Banner to COD data for Pell disbursement activity to quickly identify and resolve discrepancies. A senior staff member completes this review with findings reported to management to determine if further action is required. Anticipated Completion Date: Tested plan of action, applied corrections and verified successful resolution as of March 1, 2023. Corrective action plan implemented March 9, 2023. Person Responsible for Corrective action: Elizabeth Milam, Director of Financial Aid Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

View Audit 292421

Finding 370770 (2023-002)

Significant Deficiency 2023

Clemson University

SC

Internal Control / Segregation of Duties Student Financial Aid Cash Management § 200.303

The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person ...

The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person Responsible for Corrective action: Karen Robbins, Director of Financial Compliance Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

View Audit 292421

Finding 370747 (2023-005)

Significant Deficiency 2023

Region One Education Service Center

TX

Internal Control / Segregation of Duties

Corrective Action: The Center is currently reviewing our process and will be implementing a documented process with approvals before payments are made. Proposed Completion Date: February 23, 2024 Name of contact person: Rumalda Ruiz, Deputy Director for Business and Operations Contact: (956) 984-629...

Corrective Action: The Center is currently reviewing our process and will be implementing a documented process with approvals before payments are made. Proposed Completion Date: February 23, 2024 Name of contact person: Rumalda Ruiz, Deputy Director for Business and Operations Contact: (956) 984-6290

View Audit 292418

Finding 370742 (2023-006)

Significant Deficiency 2023

Shawano School District

WI

School Nutrition Programs Internal Control / Segregation of Duties Special Tests & Provisions

The District will continue to enhance procedures and controls over the verification compliance requirement with adequate oversight and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cor...

The District will continue to enhance procedures and controls over the verification compliance requirement with adequate oversight and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

View Audit 292416

Finding 370737 (2023-005)

Significant Deficiency 2023

Shawano School District

WI

School Nutrition Programs Internal Control / Segregation of Duties Eligibility

The District will continue to enhance procedures and controls over the eligibility requirements with adequate oversight of both manual and electronic processes and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requiremen...

The District will continue to enhance procedures and controls over the eligibility requirements with adequate oversight of both manual and electronic processes and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

View Audit 292416

Finding 370731 (2023-001)

Material Weakness 2023

Messiah Lifeways

PA

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control -...

To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control - Reporting Assistance Listing Number: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not Applicable Award Number/Year: Not Applicable / 2023 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Company did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. For the one report filed during the award year it was noted to include incorrect lost revenue totals, due to clerical errors and the exclusion of certain affiliates. In addition, the reports tested did not contain a documented review and approval of the reports prior to submission. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Total cumulative lost revenue should be $13,893,503. Questioned Costs: None reported. Cause: Lack of management oversight. Recommendation: We recommend that management review and update, as needed, their procedure for completion of the reporting to ensure that a review and approval of such reporting is completed and documented prior to submission. Additionally, we recommend that management revise their lost revenue totals in any future submissions. Views of Responsible Officials: Management will revise policies and update cumulative lost revenue for any future HRSA PRF Reporting Portal submissions and retain documented proof that the reports were reviewed prior to filing. In addition, revised lost revenues of $13,893,503 exceed cumulative PRF payments applied to lost revenues of $1,626,560. Date of anticipated Completion – March 15, 2024 Person/Persons responsible for completion – Jarrod Leo, CFO and Michele Brown, Senior Director of Fiscal Services Sincerely, Jarrod Leo Chief Financial Officer

View Audit 292412

Finding 370729 (2023-005)

Material Weakness 2023

South Putnam Community School Corporation

IN

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

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval pr...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024

View Audit 292410

Finding 370722 (2023-003)

Material Weakness 2023

South Putnam Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Reli...

FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct errors. Contact Person Responsible for Corrective Action: Hilarie Logan Contact Phone Number and Email Address: 765-653-3119 hlogan@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation has a new Grants Coordinator who will participate in Internal Controls Training and sign off that they have done so. We will also incorporate dual signatures on documents as an additional means of approval/oversight. Anticipated Completion Date: 3/2024

View Audit 292410

Finding 370656 (2023-001)

Significant Deficiency 2023

Realife Cooperative of Brooklyn Park

MN

Reporting Internal Control / Segregation of Duties

Housing and Urban Development Realife Cooperative of Brooklyn Park respectfully submits the following corrective action plan for the year ended December 31, 2023. Westberg Eischens, PLLP 2630 1st Street South P.O. Box 362 Willmar, MN 56201 Audit Period: December 31, 2023 The finding from the Decembe...

Housing and Urban Development Realife Cooperative of Brooklyn Park respectfully submits the following corrective action plan for the year ended December 31, 2023. Westberg Eischens, PLLP 2630 1st Street South P.O. Box 362 Willmar, MN 56201 Audit Period: December 31, 2023 The finding from the December 31, 2023 schedule of findings and questioned costs and the summary schedule of prior audit findings is discussed below. The finding is numbered consistently with the number assigned in the schedules. Summary of audit results does not include findings and is not addressed. Finding 2023-001 Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 292376

Finding 370647 (2023-002)

None 2023

Yorkville Joint #2 School District

WI

Internal Control / Segregation of Duties

Management Response - The District Superintendent and Business Manager review and approve the financial statements. Upon completion of the full audit, the school board reviews, comments on, and approves the audited financial statements.

View Audit 292366

Finding 370646 (2023-001)

None 2023

Yorkville Joint #2 School District

WI

Internal Control / Segregation of Duties

Management Response – Because of the size of the office and the district, we are precluded from maintaining a proper staff size to ensure a proper segregation of duties. We are aware of this condition, and we realize that the concentration of duties and responsibilities in a limited number of indiv...

Management Response – Because of the size of the office and the district, we are precluded from maintaining a proper staff size to ensure a proper segregation of duties. We are aware of this condition, and we realize that the concentration of duties and responsibilities in a limited number of individuals in not desirable for an effective system of internal control. To mitigate the issue of lack of segregation of duties, we have cross trained virtually each of the business office employees. While we do have a dedicated payroll person, another individual will perform cross checks & verifications independently. The same goes for issuing checks, accounts receivable, accounts payable, and activity funds. These functions are overseen by the business manager.

View Audit 292366

Finding 370644 (2023-002)

None 2023

Golden Ridge Housing Inc.

RI

Questioned Costs Internal Control / Segregation of Duties

Management has corrected the error in the January 2024 requisition

View Audit 292353 Questioned Costs: $1

Finding 370633 (2023-002)

Significant Deficiency 2023

Tippecanoe Valley School Corporation

IN

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

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Correcti...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024

View Audit 292331

Finding 370632 (2023-004)

Significant Deficiency 2023

High Point University

NC

Questioned Costs Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2023-004 Program: Federal Work-Study Program CFDA No.: 84.033 Federal Agency: Department of Education Award Year: FY 2022 - 2023 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid du...

Finding 2023-004 Program: Federal Work-Study Program CFDA No.: 84.033 Federal Agency: Department of Education Award Year: FY 2022 - 2023 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors the importance of not working during scheduled class hours, regardless of whether their jobs are funded by the Federal Work Study program or by the institution. This policy applies even if classes are canceled or let out early. The Student Employment Program holds annual training sessions for these responsible individuals and provides updated publications. As part of the University's student employment application process, students are required to submit their class schedules. Supervisors are expected to utilize these schedules and ensure that work schedules do not conflict with class times. Additionally, supervisors are expected to obtain students' class schedules each semester and update their work schedules accordingly, to prevent students from working during class hours. In the University’s effort to meet the FISAP correction deadline and out of an abundance of caution, all questionable work-study transaction funds were returned and converted to institutionally full-paid hours for these students. This action aims to avoid penalizing the students for any errors and to rectify potential misappropriation of federal work-study funds. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication emphasizes their responsibility to adhere to these guidelines and to keep their supervisor informed of any changes to their class schedule that may require adjustments to their work schedule. Student employee supervisors are expected to hold a mandatory meeting with their student staff at or before the start of each semester. The University also continues its internal audit process, implemented in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure they are not working during class hours. This review will be conducted by Brad Calloway, Senior Vice President for Business Affairs. Any violations of the school's student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for necessary corrective action. In mid-January 2024, the University will institute the Give Pulse platform, which will integrate with the University’s current HR/Payroll timekeeping system, Workday. The Give Pulse platform will assist in flagging students whose work hours fall outside the parameters of hours worked. Further training and instruction to pay closer attention to these discrepancies, such as failing to clock out or working for eight or more hours in a day, will be provided to student employee supervisors as part of the monthly email communication. The University is investigating the feasibility of implementing parameters within Workday that would notify student supervisors when their student workers are clocked in for more than 8 hours straight as well as when they are nearing 20 hours of work in a week. This notification would enable supervisors to ensure the accuracy of their students' clocked hours and make adjustments if necessary. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: February 29, 2024

View Audit 292330 Questioned Costs: $1

Finding 370631 (2023-003)

Significant Deficiency 2023

High Point University

NC

Cash Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding 2023-003 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management University’s Response: The University has continued to ensure that these funds are not commingled and has protected them f...

Finding 2023-003 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management University’s Response: The University has continued to ensure that these funds are not commingled and has protected them from being spent. Due to the discrepancies identified, it is necessary to review and compare each student's loan history between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation process has proven to be tedious but necessary to identify funds that were never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: With additional assistance, the University made further progress in identifying records with discrepancies. We reviewed the types of discrepancies identified with the DoE and, with their guidance, are detailing the individual student accounts to which funds need to be returned to correct the students' NSLDS loan records. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2024

View Audit 292330

Finding 370573 (2023-001)

Material Weakness 2023

Unified School District #457

KS

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management

Finding 2023-001 Planned Corrective Action: The District’s management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate and timely, with a planned implementation date by the Financial Officer of December 15, 2023.

View Audit 292263

Finding 370551 (2023-001)

Significant Deficiency 2023

Lakeland University and Affiliate

WI

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with...

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of all students who received Title IV aid to ensure enrollment data is accurate. Name(s) of the contact person(s) responsible for corrective action: Debra Buffington Planned completion date for corrective action plan: 06/30/2024

View Audit 292250

Finding 370541 (2023-002)

Significant Deficiency 2023

Octorara Area School District

PA

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Federal Program COVID-19 - Education Stabilization Fund ALN 84.425; passed through the Pennsylvania Department of Education Condition/Cause We tested a sample of 8 nonpayroll invoices charged to the Education Stabilization Fund. For 1 out of the 8 invoices tested, the invoice was miscoded to the g...

Federal Program COVID-19 - Education Stabilization Fund ALN 84.425; passed through the Pennsylvania Department of Education Condition/Cause We tested a sample of 8 nonpayroll invoices charged to the Education Stabilization Fund. For 1 out of the 8 invoices tested, the invoice was miscoded to the grant and should have been charged to a different program. Controls at the District did not catch this miscoding prior to the audit. The Board of Directors approves all salaried positions that are funded by the Education Stabilization Fund. For one of the individuals charged to the program, the Board did not approve their position as a grant funded position. Instead, a different individual was approved but not charged to the grant. Controls at the District did not catch this miscoding prior to the audit; however, the individual charged to the grant was in a position that was allowable under the grant requirements. Recommendation We recommend the District review their internal controls over allowable activities and allowable costs charged to the Education Stabilization Fund to ensure they are designed and operating to detect coding errors that may result in noncompliance with grant requirements. Management Response Objective Address the identified issues related to the misallocation of costs and lapses in internal controls within the Education Stabilization Fund program. 1. Immediate Actions • Correct the miscoded invoice immediately, ensuring that the $2,613 erroneously charged to the Education Stabilization Fund is properly allocated to the correct program. • Conduct a thorough review of all nonpayroll invoices charged to the Education Stabilization Fund to identify and rectify any other miscoding errors. 2. Internal Controls Enhancement • Review and strengthen internal controls over allowable activities and costs within the Education Stabilization Fund program. • Implement a systematic process for verifying the appropriateness of each cost before it is charged to the grant, including a cross-check against grant agreements and Board approvals. 3. Board Approval Process • Establish a clear and documented process for obtaining Board approval for salaried positions funded by the Education Stabilization Fund. • Ensure that all individuals charged to the program have received explicit approval from the Board, and that the approval is well-documented. 4. Training and Awareness • Provide training to relevant staff involved in coding and approving expenses related to the Education Stabilization Fund. • Enhance awareness among employees about the importance of accurately coding expenses and obtaining proper approvals. 5. Review of All Salaried Positions • Conduct a comprehensive review of all salaried positions funded by the Education Stabilization Fund, ensuring that each position aligns with Board approvals and grant requirements. • Verify that individuals charged to the program have the necessary approvals and qualifications. 6. Documentation and Record-Keeping • Establish a centralized and well-maintained repository for all documentation related to Education Stabilization Fund expenditures. • Ensure that records of Board approvals, coding decisions, and supporting documentation for all expenses are readily accessible for audit purposes. 7. Periodic Internal Audits • Implement a schedule for periodic internal audits specifically focused on the Education Stabilization Fund program. • Conduct random checks and audits to verify the accuracy of coding and compliance with internal controls. 8. Reporting and Transparency • Develop a reporting mechanism to keep the Board of Directors and relevant stakeholders informed of expenditures under the Education Stabilization Fund. • Periodically report on the status of internal controls and any corrective actions taken. 9. Continuous Monitoring: • Establish a continuous monitoring process to detect and address any deviations from established internal controls promptly. • Implement real-time alerts or notifications for potential coding errors or deviations from approved positions. 10. External Review • Consider engaging external auditors to perform an independent review of the strengthened internal controls and corrective actions taken. • Seek recommendations for further improvements and best practices. By implementing these corrective actions, we aim to enhance internal controls, ensure compliance with grant requirements, and prevent the misallocation of funds within the Education Stabilization Fund program. Regular monitoring and a commitment to continuous improvement will be critical for sustained success.

View Audit 292221 Questioned Costs: $1

Finding 370527 (2023-001)

Significant Deficiency 2023

Colton Joint Unified School District

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the...

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the rationale behind charging a substitute to Title I. Additionally, backup documentation will be collected to bolster the support for the allowability of these activities. This proactive plan aims to maintain continuous compliance with Title I guidelines.

View Audit 292192 Questioned Costs: $1

Corrective Action Plans

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