Corrective Action Plans

Finding 386053 (2023-001)

Significant Deficiency 2023

Ripon College

WI

Special Tests & Provisions Student Financial Aid Reporting

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the Natio...

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that Department of Education (DOE) considers high risk. Statement of Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Corrective Action Plan: • The College agrees and concurs with the audit finding. • The Registrar’s Office has reviewed and remediated all files that were not accurately reported data elements in NSLDS as of September 2023. • The Registrar’s Office will work with the Financial Aid Office to review and regularly monitor student campus and program level enrollment status, especially in the cases of those that have dropped below full time, and are no longer enrolled for various reasons. • The Registrar’s Office will monitor the NSC error report which states discrepancies between NSC and NSLDS. • The Registrar’s Office will work with NSC to remediate processing issues between NSC and NSLDS reports in order to ensure that NSLDS is receiving accurate information. Names of Contact Persons Responsible for Corrective Action Plan: Michele Wittler (Associate Dean of Faculty and Registrar), wittlerm@ripon.edu, 920-748-8119 Katy Crane (Assistant Registrar), cranek@ripon.edu, 920-748-8119 Linda Kinziger (Director of Financial Aid), kinzigerl@ripon.edu, 920-748-8358 Anticipated Completion Date: This plan has been implemented with corrections already made as of September 2023 by the Registrar’s Office. It will be finalized with the fiscal year June 30, 2024 year-end review of Enrollment Reporting.

View Audit 298423

Finding 386039 (2023-003)

Material Weakness 2023

Paoli Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required ...

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control 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. 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: Greg Walker, Superintendent Contact Phone Number and Email Address: 812-723-4717 and walkerg@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent will enter information into the annual data report required for ESSER and once completed the Corporation Treasurer will review the information entered for accuracy. The Corporation Treasurer will sign off that the information entered is correct and then the Superintendent will submit the data report. Anticipated Completion Date: Projected date of completion is April 2024.

View Audit 298416

Finding 385975 (2023-005)

Significant Deficiency 2023

Idaho State University

ID

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matte...

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should review the requirements and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU reopened the prior financial aid years in COD and completed returns of federal aid funds via G5/6 from identified outstanding checks. ISU has implemented the following monitoring controls: At the beginning of each month finance runs check reissue forms for all checks that the check date is 180 days or older. These are mailed to the check recipient. Around the 15th of the month any checks containing Title IV funds that have not been reissued will be turned to the financial aid office. Financial Aid is provided with the date by which the funds need to be returned. Financial Aid attempts to work with the student to get the checks cashed if they are not successful will return funds before the 240-day limit. They will then notify Finance to cancel the original check. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller, James Martin, Director of Financial Aid Planned completion date for corrective action plan: Implemented in 2020.

View Audit 298414 Questioned Costs: $1

Finding 385654 (2023-001)

Significant Deficiency 2023

Idaho State University

ID

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 ...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: ISU should implement formal review procedures to document review and approvals over required reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU had a formal review procedure in place, but due to personnel changes it was not being followed. Staff has been trained and procedures will be followed. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented FY24

View Audit 298414

Finding 385651 (2023-001)

None 2023

Ncr of Central Pennsylvania Dba Decatur Village

OH

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment

The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.

View Audit 298410

Finding 385643 (2023-003)

Material Weakness 2023

Pennsylvania Housing Finance Agency

PA

Material Weakness Internal Control / Segregation of Duties

2023-003 Housing Assistance Fund Program – Assistance Listing No. 21.026 Recommendation: CLA recommended that PHFA review their procedures around the debt verification during the HAF program application process. Explanation of disagreement with audit finding: There is no disagreement with the audi...

2023-003 Housing Assistance Fund Program – Assistance Listing No. 21.026 Recommendation: CLA recommended that PHFA review their procedures around the debt verification during the HAF program application process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Based on this and other similar inadequacies with the vendor, the Agency terminated the contract of the non-compliant vendor (IEM) and moved the administration of the program in house. The new procedures and software being utilized provide the required documentation and verification to support disbursements as evidenced by the audit review. The Agency also anticipates making a mandatory discovery demand for all supporting program documentation to include the debt verification data and will seek judicial enforcement if IEM does not comply with the request. Name of the contact person responsible for corrective action: Kelly Wilson, PAHAF Program Manager Planned completion date for corrective action plan: The migration to in house administration was completed in March of 2023. The discovery request is expected to be made by no later than Monday, March 25th, 2024.

View Audit 298360

Finding 385642 (2023-002)

Significant Deficiency 2023

Pennsylvania Housing Finance Agency

PA

Questioned Costs Cash Management HUD Housing Programs

2023-002 Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

2023-002 Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA will implement electronic time tracking, this will replace the current manual process of preparing timesheets that are entered into a database used to accumulate administrative expenses charged to federal programs. PHFA is currently in the process of implementing a Human Capital Management system that will allow employees to track the time they work on federal programs. Name of the contact person responsible for corrective action: Adrianne Trumpy, Director of Accounting Planned completion date for corrective action plan: July 1, 2024

View Audit 298360 Questioned Costs: $1

Finding 385641 (2023-001)

Significant Deficiency 2023

Pennsylvania Housing Finance Agency

PA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

U.S. Department of Housing and Urban Development 2023-001 Home Investment Partnerships Program – Assistance Listing No. 14.239 Recommendation: CLA recommended that PHFA review their procedures surrounding the division sign-off form utilized in the pre-commitment meeting. Explanation of disagreeme...

U.S. Department of Housing and Urban Development 2023-001 Home Investment Partnerships Program – Assistance Listing No. 14.239 Recommendation: CLA recommended that PHFA review their procedures surrounding the division sign-off form utilized in the pre-commitment meeting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA implemented a new process to ensure the required divisional signoffs are received after the completion of the pre-commitment meeting. The Lending Officer prepares an electronic approval listing in Microsoft Teams to capture the approvals after the pre-commitment meeting. The Lending Officer follows up with the requested signors to ensure that all outstanding questions have been answered and the signer can mark the Microsoft Teams’ listing approved. Name of the contact person responsible for corrective action: Jessica Perry, Director of Development The new Microsoft Teams approval system was implemented in August 2023. To date, approximately 20 developments have been approved via the new system.

View Audit 298360

Finding 385637 (2023-001)

Significant Deficiency 2023

School in the Square Public Charter School

NY

Cash Management School Nutrition Programs Matching / Level of Effort / Earmarking

The contact for this plan is Monica Merchant. The School will implement procedures to establish proper internal controls related to the submission of meal counts to the Child Nutrition Management System effective March 15, 2024, allowing for proper segregation of duties and review prior to submissio...

The contact for this plan is Monica Merchant. The School will implement procedures to establish proper internal controls related to the submission of meal counts to the Child Nutrition Management System effective March 15, 2024, allowing for proper segregation of duties and review prior to submission. Meal Counts will continue to be tracked daily. Monthly participation counts, by meal type and location, will be reviewed and entered on the Child Nutrition Management System by the School’s financial consultant. Prior to submission, these data elements will be reviewed, verified and submitted by the organization’s Data and Special Projects Manager. The addition of a second layer of approval should allow for adequate internal control over monthly meal claims.

View Audit 298344

Finding 385615 (2023-001)

Material Weakness 2023

South Spencer County School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent...

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385535 (2023-008)

Significant Deficiency 2023

Clarkson College

NE

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

2023-008 Student Financial Assistance – Assistance Listing No. Various Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations. Explanation of disagreemen...

2023-008 Student Financial Assistance – Assistance Listing No. Various Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will ensure that procedures are in place and financial aid staff are trained in requirements related to monthly reconciliations. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385534 (2023-007)

Significant Deficiency 2023

Clarkson College

NE

Questioned Costs Student Financial Aid Significant Deficiency

2023-007 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Explanation of disagreement w...

2023-007 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review the R2T4 requirements and will implement procedures to ensure R2T4 calculations are completed accurately. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311 Questioned Costs: $1

Finding 385533 (2023-006)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Reporting Significant Deficiency

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement wit...

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review procedures and starting immediately, all disbursements reported to COD will be reported within the appropriate timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385532 (2023-005)

Significant Deficiency 2023

Clarkson College

NE

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

2023-005 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding...

2023-005 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An automatic email notification will be set up in Anthology, Clarkson College’s new student information system, so that students receive a notification to their student email of their exit counseling information. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: May 2024

View Audit 298311

Finding 385531 (2023-004)

Significant Deficiency 2023

Clarkson College

NE

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

2023-004 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Expl...

2023-004 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An automatic email notification has been set up in Anthology, Clarkson College’s new student information system, so that students receive a notification to their student email of their loan disbursements. Documentation is maintained in Anthology. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385530 (2023-003)

Significant Deficiency 2023

Clarkson College

NE

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

2023-003 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Explanation of disagreement with audit finding: There is...

2023-003 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There is going to be training with current financial aid staff to make sure we are using the correct cost of attendance budget and that we package students correctly based on their grade level. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311

Finding 385529 (2023-002)

Significant Deficiency 2023

Clarkson College

NE

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

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagre...

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review, revise and implement procedures for cost of attendance, awarding of financial aid offers, and R2T4, in addition to the review of the process of all monthly reconciliations related to Pell, Direct Loan, SEOG and FWS along with G5 drawdowns annotated and reconciled with the Finance Department. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311

Finding 385528 (2023-001)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Internal Control / Segregation of Duties Reporting

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in tit...

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar Office reports enrollment statuses to the National Student Clearinghouse (Clearinghouse) and then the Clearinghouse reports enrollment statuses to NSLDS. Clarkson College Financial Aid will resume a procedure put in place in July 2022, according to the 2022 Corrective Action Plan, prior to the new Financial Aid staff that started in June 2023. The procedure is for one Financial Aid staff person to work with the Registrar each time enrollment is reported and that all errors are cleared in the allowed timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: April 2024

View Audit 298311

Finding 385524 (2023-001)

Significant Deficiency 2023

Clayton County

IA

Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN February 28, 2024 To: U.S. Department of Treasury Clayton County respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 123 W. Water Street Decorah,...

CORRECTIVE ACTION PLAN February 28, 2024 To: U.S. Department of Treasury Clayton County respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 123 W. Water Street Decorah, IA 52101 Audit period: Year ended 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. FINDING - FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Treasury: • Federal Assistance Listing Number 21.027 Coronavirus State and Local Fiscal Recovery Funds Internal control deficiencies: See Finding 2023-001 Recommendation: The County should review the operating procedures of the County offices to obtain the maximum internal control possible under the circumstances utilizing currently available staff, including elected officials. While we do recognize that the County is not large enough to permit a segregation of duties for effective internal controls, we believe it is important the Board be aware that this condition does exist. Action Taken: Management is cognizant of this limitation and will implement additional procedures where possible. Anticipated Date of Completion: June 30, 2024. Page 2 If the U.S. Department of Treasury has questions regarding this plan, please call Jennifer Garms, County Auditor, at 563-245-1106. Sincerely yours, Jennifer Garms, County Auditor Clayton County cc: Amanda Webb, CPA

View Audit 298305

Finding 385519 (2023-010)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventin...

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

View Audit 298302

Finding 385517 (2023-009)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.208 § 200.302 § 200.303 § 200.305 § 200.328

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in prev...

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385513 (2023-008)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation...

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Allowable Activities and Allowable Costs/Cost Principles compliance requirements. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee to ensure all costs are correct and allowable before giving their approval. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the Schools Corporation’s fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will be checking for Allowable Activities and Allowable Costs/Cost Principles and verifying that they meet compliance. During the reimbursement process the grants person will also make sure all sections of the grant have been properly expended. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385511 (2023-007)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-007 Finding Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Earmarking, Period of Performance Summary of Finding: Activities Allowed or Unallowed and Allowable Costs/Cost Principles The School Corporation did not have adequat...

FINDING 2023-007 Finding Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Earmarking, Period of Performance Summary of Finding: Activities Allowed or Unallowed and Allowable Costs/Cost Principles The School Corporation did not have adequate procedures in place to ensure that only employees performing duties for the Special Education Program were being paid out of the grant funds. The Corporation Treasurer was reviewing a total amount paid from each fund account; however, a detailed payroll report was not being reviewed that would have identified the employees being paid from the grant fund. Earmarking The School Corporation did not have internal controls in place to ensure that they were in compliance with the earmarking requirements. The Special Education Director and Corporation Treasurer compiled and reviewed the proportionate share reports that get sent to Indiana Department of Education to track non-public school expenses, however, that control was not able to be verified as the reports were not retained. Period of Performance The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. During this meeting they will also review payroll (salary and benefits) to identify employees who are included in the grant. All reimbursements and proportionate share documents are reviewed, signed and filed in an individual grant binder, housed in the special education office. Special education director will code initial expenditures to grant appropriation lines and submit to payroll and corporation treasurer. Payroll then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: April 2024

View Audit 298302

Finding 385507 (2023-005)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation is no longer part of the Special Education Cooperative. The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. The Special education director will code initial expenditures to grant appropriation lines and submit to accounts payable specialist. Accounts payable specialist then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: March 2024

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Finding 385501 (2023-002)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation had not properly designed or implemented a system of internal controls, which woul...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation had not properly designed or implemented a system of internal controls, which would include segregation of duties, that would prevent or detect and correct noncompliance relating to the eligibility determination of a child receiving meals. There was no oversight or review to ensure the eligibility determination was correct. Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Account Specialist performed the verification of free and reduced price applications. There was no documentation that an oversight, review, or approval process, or other compensating control, had been established to ensure the proper number of applications were verified for accuracy. Contact Person Responsible for Corrective Action: Josh Sinclair, Food Service Director and Allison Vanover, Corporation Treasurer. Contact Phone Number and Email Address: 812-246-3375 jsinclair@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will use the proposed USDA form that has two signatures required. Mr. Sinclair will ensure that all signatures are collected for proof of verification. Mr. Sinclair and Ms. Susan Westfall will be a second check on the eligibility determination. One will do paper applications and the other will do online applications. Then, they will check each other for accuracy. Anticipated Completion Date: March 2024

View Audit 298302

Corrective Action Plans

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