Corrective Action Plans

Finding 4004 (2023-001)

Significant Deficiency 2023

SD

Student Financial Aid Reporting Significant Deficiency

Department of Education Augustana University respectfully submits the following corrective action plan for the year ended July 31, 2023. Audit period: August 01, 2022 – July 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consis...

Department of Education Augustana University respectfully submits the following corrective action plan for the year ended July 31, 2023. Audit period: August 01, 2022 – July 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268, 84.379 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately 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: We have implemented a secondary compliance check of student withdrawal dates. As the Registrar Assistant is notified of student withdrawals, the ‘Leave Date’ is entered into the Jenzabar/CX system. On a weekly basis, the Assistant Registrar will double check the withdrawal notice with the date in Jenzabar/CX. Performing this double check on a weekly basis should catch any incorrectly entered dates before they are transmitted to NSLDS. If an incorrectly entered date is found, the Assistant Registrar will notify the Director of Financial Aid, who will check NSLDS to further ensure the date has not been incorrectly included in enrollment reporting. Name(s) of the contact person(s) responsible for corrective action: Joni Krueger Planned completion date for corrective action plan: immediately / already implemented If the Department of Education has questions regarding this plan, please call Joni Krueger at 605.274.4121.

View Audit 6326

Finding 4000 (2023-001)

Material Weakness 2023

Granite School District

UT

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.326

The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted C...

The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable.

View Audit 6311

Finding 3985 (2023-001)

Significant Deficiency 2023

Carleton College

MN

Student Financial Aid Reporting Significant Deficiency

Department of Education Carleton College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently...

Department of Education Carleton College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the Institute 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: We have developed additional validation steps to confirm that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and at NSLDS. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: 9/30/2023 If the Department of Education has questions regarding this plan, please call Theresa Rodriguez, Registar at 507-222-4290.

View Audit 6287

Finding 3982 (2023-002)

Significant Deficiency 2023

Chase Brexton Health Services, Inc.

MD

Eligibility Internal Control / Segregation of Duties

The operations team, under the guidance of Chief Operating and Quality Officer, will evaluate and develop a sustainable annual review process for all Chase Brexton patients qualifying for Ryan White services. This will ensure that all persons regardless of need will be evaluated annually or documen...

The operations team, under the guidance of Chief Operating and Quality Officer, will evaluate and develop a sustainable annual review process for all Chase Brexton patients qualifying for Ryan White services. This will ensure that all persons regardless of need will be evaluated annually or documented that they no longer quality for services under the Ryan White Part A program. Chase Brexton will begin the process of evaluating and developing these protocols immediately.

View Audit 6274

Finding 3975 (2023-001)

Significant Deficiency 2023

MacOmb Community College

MI

Reporting Internal Control / Segregation of Duties Special Tests & Provisions

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provis...

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that one out student of a testing population of two was not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the College was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the College consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. This situation occurred because the student graduated during a term in which they were not enrolled. This is connected to our upload to the National Student Clearinghouse which did not mark the student as graduated (G Not Applied) in our degree verify file. There is a known defect in our student information system that causes this issue. We are currently working collaboratively with our information technology department to resolve this defect which will ensure that we capture students in this situation in the future. Responsible Person. Registrar/Director of Enrollment Services Anticipated Completion Date. June 30, 2024

View Audit 6259

Finding 3966 (2023-001)

Significant Deficiency 2023

Summit Academy Oic

MN

Significant Deficiency Internal Control / Segregation of Duties

United States Department of Education Summit Academy OIC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numb...

United States Department of Education Summit Academy OIC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT No findings to report. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the Organization review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Summit Academy does acknowledge this finding and we have updated our WISP as recommended. Additionally, we have instituted a semiannual, pre-scheduled meeting of the responsible officials to review the most current requirements of the GLBA to assure that the organization WISP is always up to date. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO. Planned completion date for corrective action plan: Fall 2023 If the Department of Education has questions regarding this plan, please call Marc Carrier at 612-278-5282.

View Audit 6239

Finding 3961 (2023-001)

Significant Deficiency 2023

Urban Community School

OH

Internal Control / Segregation of Duties

Corrective Actions: We have re-assigned responsibility for submitting receipts for credit card charges to the Manager of the Food Service Program, who has been running our program for 18 years. We sent our policy on receipt requirements for all credit card receipts to all relevant staff. The CFO and...

Corrective Actions: We have re-assigned responsibility for submitting receipts for credit card charges to the Manager of the Food Service Program, who has been running our program for 18 years. We sent our policy on receipt requirements for all credit card receipts to all relevant staff. The CFO and Business Manager will both review the monthly credit card charges for appropriate supporting documentation for credit card charges.

View Audit 6236

Finding 3942 (2023-001)

Significant Deficiency 2023

Lutheran Family Services of Virginia, Inc. Dba Encircle

VA

Questioned Costs Cash Management Reporting

Department of Health and Human Services Lutheran Family Services of Virginia, Inc. and Subsidiaries d/b/a enCircle respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. ...

Department of Health and Human Services Lutheran Family Services of Virginia, Inc. and Subsidiaries d/b/a enCircle respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, Virginia 24018 Audit Period: Year ending June 30, 2023 The finding from the June 30, 2023 schedule of findings and questioned costs is discussed below. Findings – Financial Statement Audit NONE. Findings – Federal Award Programs Audits Department of Health and Human Services 2023-001: Unaccompanied Alien Children – ALN #93.676, Activities Allowed/Unallowed; Allowable Costs and Period of Performance and controls over Activities Allowed/Unallowed; Allowable Costs and Period of Performance. Significant Deficiency Criteria and Condition: Under the requirements of the Uniform Guidance, the drawdown of federal funds must be based on actual expenditures incurred. Context: We tested twenty-five reimbursed amounts from various awards. We noted two instances where the Organization obtained federal funds without incurring the actual expenditure. We also noted one instance where the expenditure occurred outside of the budget period. Cause: The Organization did not properly allocate expenditures within their general ledger and did not have an adequate review process in place. Effect: The lack of an adequate review process can cause federal funds to be obtained prior to the actual expenditure is incurred. Recommendation: We recommend that the Organization develop a review process to ensure the drawdown of federal funds does not occur before funds are expended and that the Organization submit expenditures incurred in the budget period. Action Taken: Management has implemented enhanced review processes to ensure the drawdown of Federal funds does not occur before funds are expended and that enCircle submits only expenditures incurred during the budget period. Name of Contact Person: David Pruett, Chief Financial Officer

View Audit 6220 Questioned Costs: $1

Finding 3938 (2023-007)

Significant Deficiency 2023

Presentation College

SD

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the...

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023

View Audit 6218

Finding 3933 (2023-005)

Significant Deficiency 2023

Presentation College

SD

Student Financial Aid Reporting Significant Deficiency

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reportin...

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023

View Audit 6218

Finding 3932 (2023-004)

Significant Deficiency 2023

Presentation College

SD

Internal Control / Segregation of Duties Student Financial Aid Cash Management

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the ...

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023

View Audit 6218

Finding 3931 (2023-003)

Material Weakness 2023

Presentation College

SD

Questioned Costs Student Financial Aid Eligibility

Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loan...

Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: • 2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by $2,773 and one was over awarded by $862. • 7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being awarded as the wrong academic year in school; and 3 students were over awarded subsidized loans as the student did not have financial need. • 5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students with errors were under awarded unsubsidized loans based on being awarded as the wrong academic year in school. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The College has reviewed all students impacted by the errors noted above and made corrections to the students as needed. Anticipated Completion Date: September 30, 2023

View Audit 6218 Questioned Costs: $1

Finding 3930 (2023-006)

Significant Deficiency 2023

Presentation College

SD

Student Financial Aid Reporting Significant Deficiency

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Oppor...

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023

View Audit 6218

Finding 3917 (2023-002)

Significant Deficiency 2023

Talbert House, Inc.

OH

Special Tests & Provisions Internal Control / Segregation of Duties

2023-002 Continuum of Care, Assistance Listing Number 14.267 Criteria: Special Tests and Provisions Reasonable Rental Rates. 24 CFR 578.49(b)(l) of the Continuum of Care Program requires rents paid for with grant funds to be reasonable and to not exceed fair market rents. The Agency should have int...

2023-002 Continuum of Care, Assistance Listing Number 14.267 Criteria: Special Tests and Provisions Reasonable Rental Rates. 24 CFR 578.49(b)(l) of the Continuum of Care Program requires rents paid for with grant funds to be reasonable and to not exceed fair market rents. The Agency should have internal controls in place to ensure compliance. Condition: We noted an instance (out of a sample of 19) of a client's original lease ending and no documentation being retained to indicate the future status of the lease in accordance with the Agency's policies and controls. Cause and Effect: The Agency may pay rent for a lease that is not housing a client or is in excess of fair market rents for a similar unit. The Agency did not adhere to its internal controls of obtaining a lease addendum or new lease at the conclusion of a previous lease. Recommendation: The Agency should provide education and training for all staff members involved in the program. In addition, management needs to perform a review of all client files to ensure proper documentation is retained for all clients and ongoing leases. Views of Responsible Officials and Planned Corrective Actions: Recommendation will be implemented including education and training of staff members responsible for lease documents. Agency will also complete a review of all client files to ensure properly inclusion of appropriate documentation.

View Audit 6169

Finding 3880 (2023-001)

Significant Deficiency 2023

Ellis Early Learning, Inc.

MA

Reporting Internal Control / Segregation of Duties § 200.430

Time & Reporting - Corrective Action Plan In order to strengthen the internal controls surrounding time and effort reporting, the Organization has modified its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel...

Time & Reporting - Corrective Action Plan In order to strengthen the internal controls surrounding time and effort reporting, the Organization has modified its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization. Further, the Organization plans to implement regular internal inspections of records to ensure completeness and adherence to the policies in place.

View Audit 6138

Finding 3862 (2023-001)

Significant Deficiency 2023

MacAlester College

MN

Student Financial Aid Reporting Significant Deficiency

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently...

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.007, 84.063 Recommendation: We recommend the College evaluate the circumstances that delayed reporting disbursements to COD to ensure that it will not happen again. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We experienced a malfunction in our reporting software and were not aware of the issue until after the reporting deadline. We now have procedures in place whereby we confirm that COD has received the file once we have submitted it. Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: Implemented in November 2022. If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

View Audit 6092

Finding 3857 (2023-001)

Significant Deficiency 2023

Northeast Iowa Mental Health Center

IA

Internal Control / Segregation of Duties Reporting

Internal control deficiencies: See Finding 2023-001

View Audit 6077

Finding 3857 (2023-001)

Significant Deficiency 2023

Northeast Iowa Mental Health Center

IA

Internal Control / Segregation of Duties Reporting

Recommendation: We realize that with a limited number of office employees, segregation of duties is difficult. However, the Center should review the operating procedures to obtain the maximum internal control possible under the circumstances. The Center should also consider the potential consequenc...

Recommendation: We realize that with a limited number of office employees, segregation of duties is difficult. However, the Center should review the operating procedures to obtain the maximum internal control possible under the circumstances. The Center should also consider the potential consequence of reliance on one person for financial, grant and payroll reporting.

View Audit 6077

Finding 3857 (2023-001)

Significant Deficiency 2023

Northeast Iowa Mental Health Center

IA

Internal Control / Segregation of Duties Reporting

Action Taken: This issue is reviewed annually through the audit review with the Board of Directors. The size of the Center prevents further segregation of duties.

View Audit 6077

Finding 3857 (2023-001)

Significant Deficiency 2023

Northeast Iowa Mental Health Center

IA

Internal Control / Segregation of Duties Reporting

Anticipated Date of Completion: June 30, 2024

View Audit 6077

Finding 3849 (2023-002)

Material Weakness 2023

Appalachian Mountain Community Health Centers

NC

Special Tests & Provisions Internal Control / Segregation of Duties

for certain patients with visits to the Organization during the year ended June 30, 2023. Management recognizes the importance of complying with sliding fee guidelines. In response to Finding 2023-002, proper training will be given to employees and sliding fee discounts will be reviewed by a supe...

for certain patients with visits to the Organization during the year ended June 30, 2023. Management recognizes the importance of complying with sliding fee guidelines. In response to Finding 2023-002, proper training will be given to employees and sliding fee discounts will be reviewed by a supervisor on a periodic basis the ensure compliance with the sliding fee scale.

View Audit 6064

Finding 3827 (2023-002)

Material Weakness 2023

Northern Tioga School District

PA

Cash Management Reporting School Nutrition Programs

The district has implemented procedures for the future to ensure all transacttions are recorded in the period of benefit and account reconciliations are performed in a timely manner. Anticipated Completion Date: June 30, 2023 Responsible Party: Kathy VanSchaick

View Audit 5986

Finding 3823 (2023-001)

Significant Deficiency 2023

Victory College Prep., Inc.

IN

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

1780 Sloan Avenue Indianapolis, IN 46203 (317) 351-1534 To Whom It May Concern, This letter is in response to our Single Audit/Uniform Guidance Finding. We understand that we are to verify two items when ESSER funds are used for construction contracts over $2,000: 1. Verify that the required prevail...

1780 Sloan Avenue Indianapolis, IN 46203 (317) 351-1534 To Whom It May Concern, This letter is in response to our Single Audit/Uniform Guidance Finding. We understand that we are to verify two items when ESSER funds are used for construction contracts over $2,000: 1. Verify that the required prevailing wage rate clauses are included in the contract—also known as Davis-Bacon Act compliance. 2. For each week in which work was performed under the contract, verify that the contractor submitted the required certified payrolls. Although we did state the contractor was to be compliant with all applicable laws and regulations, the contractor did not provide this information in a timely manner and we were subsequently unable to provide these requirements during the audit. Regarding Finding 2023-001, please know that our organization understands this requirement and will adhere to it moving forward. Our plan of action includes incorporating strict language of the requirement in both contract and bid documents, correspondence submitted weekly, and explicit penalties for a contractor if they are unable to comply, which could include withholding of payment or stopped work. In addition to the measures above, I will be responsible to ensure all contractors are following these requirements. If you have any questions, please do not hesitate to contact me. Best Regards, Luke Kahren Chief Operating Officer luke.kahren@vcpindy.org (317) 351-1534

View Audit 5982

Finding 3822 (2023-001)

Significant Deficiency 2023

Village Cooperative of Centennial

CO

Internal Control / Segregation of Duties Significant Deficiency

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

View Audit 5976

Finding 3821 (2023-001)

Significant Deficiency 2023

Village Cooperative of Fergus Falls

MN

Internal Control / Segregation of Duties Significant Deficiency

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

View Audit 5975

Corrective Action Plans

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