Corrective Action Plans

Finding 397197 (2023-014)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects funded by the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring that our grant programs comply with federal regulations related to quality assurance (QA) requirements and safeguarding that materials and workmanship conform to approved plans and specifications through testing, inspections, or certifications. The Department has worked closely with the Federal Highway Administration (FHWA) on our QA program and continues to receive feedback on the strength of our program. The Department has been working towards replacement of the Record of Materials (ROM) legacy system; therefore, it was not practical to modify the system to help correct issues previously reported in the fiscal year 2022 audit. During fiscal year 2023, the Department eliminated the practice requiring updates to the ROM within 30 days of payment and instead relied on the required documentation as evidence of proper materials acceptance. Due to the timing of implementation, these changes were not fully reflected in the current year’s audit. In January 2023, as a result of recommendations from the fiscal year 2022 audit, the Department modified its practice related to how tester data is reviewed and entered into the tester certification tracking system. All offices now funnel tester data to the Headquarters Quality Assurance Program for review and entry. These procedure changes were communicated to appropriate staff and are reflected in the Construction Manual, which was reviewed and approved by FHWA. The Department is also assessing replacement of additional software legacy programs associated with the QA program. The Department will continue to improve the QA program while waiting for the new software programs to be fully developed. To address the audit recommendations, the Department’s Construction Division will examine current policies and procedures/practices related to the audit issues. The Department will: • Update policies and procedures, including the Department’s Construction Manual (M46-01), as needed to ensure staff practices meet federal regulations. Updates will also include other clarifications to address documentation and evidence of compliance, and a reasonable level of controls regarding materials testing, inspections, certification, acceptance, and tester certifications. Completion Date: Agency Contact: • Obtain approval of updates to the Construction Manual from the FHWA. • Communicate changes in policies and procedures to division staff and stakeholders. • Provide training to Project Engineering Office staff to emphasize QA program requirements. The conditions noted in this finding were previously reported in findings 2022-011, 2021-011, 2020-017 and 2019-019. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 306534

Finding 397196 (2023-013)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to collect certified payrolls from contractors on projects funded by the Highway Planning and Construction program. Questioned Costs: Assistance Listing # ...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to collect certified payrolls from contractors on projects funded by the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: In April 2019 and July 2020, the Department received management decision letters from the Federal Highway Administration (FHWA) in response to similar findings for the fiscal years 2018 and 2019, respectively, which stated: • FHWA approved the Department’s Construction Manual and Standard Specifications and confirmed that documented procedures contain the necessary controls to ensure reasonable compliance with 29 CFR 5.5 and the Davis-Bacon and Related Acts. • FHWA agreed that current processes in place are reasonable and satisfy the intent of the Department of Labor’s certified payroll requirements. • FHWA considers this finding to be resolved. The Department continues to strive for improvements in this area. To further address the audit recommendations, the Department is planning on taking the following actions by December 2024: • Update the Construction Manual to include language for certified payroll collection requirements when no work is performed on federal projects. • Review and update the Construction Manual, as needed, to clarify the authority to withhold payments regarding federal wage administration. • Standardize the required frequency of checking for certified payroll collection and the methods to document tracking. • Define “timely,” given the circumstances surrounding weekly collection of certified payrolls and sanctions on a monthly pay estimate, including: o Defining the timeline when the Department must communicate overdue certified payroll to the contractor and the allowable methods of that communication. o Defining the timeline for determining when the Department must consider imposing sanctions on the contractor after a certified payroll is overdue. o Defining the minimum required documentation that sanctions (e.g., partial deferral of payment) were considered against the contractor regarding an overdue certified payroll. • Communicate any changes to the Construction Manual to appropriate construction staff and partners. • Continue to work with our federal grantor, FHWA, for any further actions needed to resolve this finding. Completion Date: Agency Contact: Estimated December 2024 Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 306534

Finding 397195 (2023-012)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 St...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: The Washington State Department of Transportation (WSDOT) is committed to ensuring our grant programs comply with federal regulations regarding required risk assessments. Risk assessments for subrecipients under the Federal Highway Administration grant programs are the responsibility of WSDOT’s Regional Local Programs Engineers, located in the six WSDOT regions. The Department has attempted to complete a risk assessment at each phase of a project, however, staff turnover contributed to the lack of consistency and timeliness in completing these assessments. To help ensure consistency, the Department has updated position descriptions for Local Programs Engineers to reflect this requirement. The Department will: • Continue to communicate with Regional Local Programs Engineers to ensure risk assessments are performed and properly documented in accordance with the risk assessment program guidelines. • Continue to communicate with regional management to ensure required monitoring activities by staff are tracked, and the status of these activities are reported as part of annual performance evaluations. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 306534

Finding 397189 (2023-010)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure staff providing those service...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure staff providing those services received required training. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department concurs with the recommendation to review the calculation of the profile score within the Unemployment Tax and Benefit (UTAB) system. The Department will explore a plan and review resource allocations to more effectively validate the profile score to ensure that coefficient values are correctly determined and assigned by the UTAB system. The Department partially concurs with the recommendation to reconcile the UTAB and Reemployment Appointment Scheduler (RAS) interface. There is currently a process in place to notify the RAS team if a record fails at the time of data transmission between UTAB and RAS. The Department will review its processes to verify the complete UTAB exit file was successfully received by RAS. The Department does not concur with the recommendation to implement additional internal controls over the claimant profiling process. The Department has coordinated closely with the U.S. Department of Labor (USDOL) to conduct the randomized control trial (RCT) to evaluate the Reemployment Services and Eligibility Assessments (RESEA). The Department has written approval from USDOL to utilize this method concurrently with the program’s established process. All program-eligible applicants are scored and provided a risk profile score based on both established standards and a random score for the purposes of carrying out the RCT. The Department does not concur with the recommendation to ensure all employees receive the required RESEA training before providing reemployment screening services to claimants. The Department has internal controls in place to ensure training requirements are met and staff are not granted access to schedule appointments for RESEA services without first receiving the required training. The exceptions noted by the auditors relate to the annual refresher training. In the fall of 2022, the Department implemented procedures to formally track the refresher training completed by RESEA staff. The audit exceptions identified were for two staff not currently providing RESEA services to clients. These individuals will receive the refresher training prior to providing RESEA services going forward. Completion Date: Estimated April 2025 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534

Finding 397188 (2023-009)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with federal requirements to conduct case reviews for the Benefit Accuracy Measurement program of the Unemployment Insurance program in a timely manner. Questioned Costs: Assistance Listin...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with federal requirements to conduct case reviews for the Benefit Accuracy Measurement program of the Unemployment Insurance program in a timely manner. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: Historically, the Benefit Accuracy Measurement (BAM) unit has been challenged to maintain full levels of staffing. Staff turnover, long training requirements, and unique skill sets make these positions difficult to maintain. During the prior audit period, the Department was in a hiring freeze for Unemployment Insurance administrative funding, furthering the challenge to fully staff the unit and meet program requirements. The hiring freeze was lifted in April 2023 and the unit began filling vacant positions in May 2023. Due to the lengthy training timelines for new positions, the Department anticipated the unit would not meet federally mandated performance measures for case reviews for state fiscal year 2023. The Department continues to partner and frequently communicate with the U.S. Department of Labor (USDOL) Regional Offices to discuss staffing and training models. The Quality Assurance Manager and the Case Review Supervisor are committed to routinely monitor caseload, workload, and the overall assurance of meeting the BAM operations performance goals and measures as set forth by USDOL. The conditions noted in this finding were previously reported in findings 2022-006, 2021-005, and 2020-011. Completion Date: Estimated March 2025 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534

Finding 397187 (2023-008)

Significant Deficiency 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Equipment & Real Property Management

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate monthly reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Correctiv...

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate monthly reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: In response to the prior year’s finding, the Department immediately implemented the secondary review of the monthly ETA 9055 performance reports. However, the auditor’s recommendation and the Department’s implementation occurred after state fiscal year 2023 had begun. The Department expects adequate internal controls to be in place and functioning for fiscal year 2024 and onward. The conditions noted in this finding were previously reported in finding 2022-005. Completion Date: May 2023 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534

Finding 397186 (2023-007)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate financial reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Correct...

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate financial reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has implemented procedures to ensure the ETA 9130 and ETA 2112 reports have a secondary review by management prior to submission to the federal grantor. Additionally, documentation of the review and submission will be maintained. Completion Date: February 2024 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534

Finding 397182 (2023-003)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Li...

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action in progress Corrective Action: In response to the audit finding, the Office: • Will establish policies and procedures and internal controls to communicate federal award information and requirements to all subrecipients. • Is consulting with the U.S. Department of Agriculture for additional guidance on communicating subaward information for programs that are reimbursement based. Completion Date: Estimated August 2024 Agency Contact: Leanne Eko Chief Nutrition Officer PO Box 47200 Olympia, WA 98504-7200 (360) 725-0410 Leanne.eko@k12.wa.us

View Audit 306534

Finding 397174 (2023-005)

Material Weakness 2023

Dakota Plains Legal Services, Inc.

SD

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Special Tests & Provisions -Accounting Requirements Material Weakness in Internal Control over Compliance Condition: DPLS has not...

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Special Tests & Provisions -Accounting Requirements Material Weakness in Internal Control over Compliance Condition: DPLS has not performed an annual risk assessment since 2021, nor tested an emergency disaster prevention and recovery plan. Management Response: DPLS is going to seek outside assistance to have a complete risk assessment and review of our emergency disaster and recovery plans completed. After the assessment is finished, management will review the findings, and make every effort to enact the recommendations made to the program. Responsible Individuals: Lori Stanford, Deputy Director, Tom Mortland, Executive Director. Anticipated Completion Date: December 31, 2024.

View Audit 306525

Finding 397170 (2023-003)

Significant Deficiency 2023

Dakota Plains Legal Services, Inc.

SD

Internal Control / Segregation of Duties Questioned Costs Cash Management

Legal Services Corporation FFAL #09-742018 Legal Services Corporation - Basic Field - General FFAL #09-742018 Legal Services Corporation - Basic Field - Native American Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Condition: The auditor's testing detecte...

Legal Services Corporation FFAL #09-742018 Legal Services Corporation - Basic Field - General FFAL #09-742018 Legal Services Corporation - Basic Field - Native American Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Condition: The auditor's testing detected two instances in which U.S. Citizen Attestation was not retained. Management's Response: All employees have received additional training on compliance procedures, and new employees will receive the same. All files being closed are now reviewed first for accuracy by the case handler of that file. The files are double checked by the office secretary. At the end of the quarter, all files are sent to compliance for a third review. Any needed corrections are noted by compliance and the file is then sent back to the office where it originated from to be corrected. Then the corrections to the file are reported back to compliance to verify that they have been made. All Legal Secretary staff have just completed a mandatory two-day in-person training session, which in large part covered this and other compliance related issues. By the end of June 2024, all case handlers will receive in-person training on compliance issues. The program has also started a new procedure where any client coming into an office is asked to complete an attestation statement which can be added to the client file if needed. Responsible Individuals: Dawn Marshall, Co-Compliance Officer, Kaeleigh Lundberg, Co-Compliance Officer, Tom Mortland, Executive Director, Lori Stanford, Deputy Director. Anticipated Completion Date: July 31, 2024.

View Audit 306525

Finding 397162 (2023-001)

Significant Deficiency 2023

City of Texas City, Texas

TX

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Please note the following corrective action plan regarding the CD BG-CAPER for the single audit report for FY-2023. Should you have any questions or require additional information, please contact me at your convenience. I. Corrective Action Plan Finding #2023-001 - Entitlement Grants Cluster; Perfo...

Please note the following corrective action plan regarding the CD BG-CAPER for the single audit report for FY-2023. Should you have any questions or require additional information, please contact me at your convenience. I. Corrective Action Plan Finding #2023-001 - Entitlement Grants Cluster; Performance Reporting Corrective Action Plan The City will identify and assign additional personnel to cross-train on CAPER preparation as well as filing protocols for subsequent periods. Anticipated Completion Date September 30, 2024 Auditee Contact Person Jon R. Branson, Executive Director of Management Services

View Audit 306520

Finding 397078 (2023-002)

Significant Deficiency 2023

Legal Aid of Nebraska

NE

Equipment & Real Property Management Internal Control / Segregation of Duties

FINDING 2023-002: SUPPORT FOR LSC FUNDED PROPERTY Please provide an explanation of how your Organization plans to resolve any further issues surrounding eligibility moving forward. Legal Aid will continue to follow up with last year’s auditors to obtain the necessary information. If these attempts a...

FINDING 2023-002: SUPPORT FOR LSC FUNDED PROPERTY Please provide an explanation of how your Organization plans to resolve any further issues surrounding eligibility moving forward. Legal Aid will continue to follow up with last year’s auditors to obtain the necessary information. If these attempts are unsuccessful, we will collaborate with LSC to determine if they have the information on file. Should neither of these avenues yield results, we will review physical audit files from previous years in an attempt to retrieve the information retroactively. Reasonable completion date: December 31st, 2024 Responsible Party: Stephanie Kitselman, Interim CFO – this will transition to the new inhouse Finance Director upon hire in 2024.

View Audit 306498

Finding 397067 (2023-001)

Significant Deficiency 2023

The University of Vermont Health Network INC

VT

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303

Management’s Views and Corrective Action Plan 2023-001 Significant deficiency in reporting for lack of submitting required documentation related to HRSA for previously reported Provider Relief Funds Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) ...

Management’s Views and Corrective Action Plan 2023-001 Significant deficiency in reporting for lack of submitting required documentation related to HRSA for previously reported Provider Relief Funds Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) Award Year: 1/1/2020 6/30/2023 Assistance Listing #: 93.498 Assistance Listing Title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-through entity: Not applicable Management has reassessed its internal controls over the review and approval of PRF submissions. The Network has now completed all PRF portal submissions, and this program has come to an end. Leadership Responsible: Steve Warren, Network Mgr. Grants Management Finance; Melissa Laurie, Network VP/Corporate Controller Anticipated Completion Date: 3/1/2024

View Audit 306487

Finding 397034 (2023-007)

Material Weakness 2023

George Washington Carver Academy

MI

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Corrective Action Plan: The Academy along with its new management company are reviewing, revising, and developing internal controls as necessary in order to comply with compliance requirements relevant to federal programs. Responsible Department: School Leadership and Board and Financial Service ...

Corrective Action Plan: The Academy along with its new management company are reviewing, revising, and developing internal controls as necessary in order to comply with compliance requirements relevant to federal programs. Responsible Department: School Leadership and Board and Financial Service Provider together with which includes the bookkeeping, payroll, grants management, and purchasing functions. Responsible Person: Laura Carpenter, Comptroller, CS Partners Planned Completion Date: Immediate

View Audit 306409

Finding 397024 (2023-002)

Significant Deficiency 2023

Town of Swansea

MA

Questioned Costs Special Tests & Provisions Significant Deficiency

Moving forward, internal controls have been updated to require all projects that necessitate prevailing wage rates have the proper backup and documentation.

View Audit 306406

Finding 396994 (2023-006)

Material Weakness 2023

City of Idaho Falls, Idaho

ID

Reporting Material Weakness Internal Control / Segregation of Duties § 200.329

Federal Agency Name: U.S. Treasury Department; Assistance Listing Number: 21.027; Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Material Weakness in Internal Control Over Compliance – Compliance Requirement – Reporting Finding Summary: The City’s submitted quarterly r...

Federal Agency Name: U.S. Treasury Department; Assistance Listing Number: 21.027; Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Material Weakness in Internal Control Over Compliance – Compliance Requirement – Reporting Finding Summary: The City’s submitted quarterly reports as required, but the reports contained errors including incorrect amounts and reporting information on the incorrect line items. Corrective Action Planned: The City concurs with the auditors’ findings. The City is working to coordinate and maintain supporting documentation used to prepare and review quarterly reports prior to submission to ensure the accuracy of the reports submitted. Responsible Individual(s): Mark Hagedorn, Finance Manager/Treasurer; Brooks Slyter, Assistant Finance Manager; Lisa Farris, Grant Administrator Anticipated Completion Date: October 2024

View Audit 306396

Finding 396987 (2023-002)

Material Weakness 2023

Connected Lane County

OR

Questioned Costs Material Weakness Internal Control / Segregation of Duties

Finding 2023-002 Corrective Action Planned : Management is already tracking federal expenditures throughout the year. Management will review annual federal expenditures in a timely manner to ensure that we understand whether we need to undergo a single audit. Date by which corrective action will be ...

Finding 2023-002 Corrective Action Planned : Management is already tracking federal expenditures throughout the year. Management will review annual federal expenditures in a timely manner to ensure that we understand whether we need to undergo a single audit. Date by which corrective action will be implemented: July 2024, following the close of year-end. Person(s) Responsible: Heidi Larwick, Executive Director and Mary Bell , Finance Specialist

View Audit 306391

Finding 396671 (2023-001)

None 2023

City of Taunton

MA

Questioned Costs Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The City of Taunton, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Po...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The City of Taunton, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number 21.027 2023-001: Reporting to the Federal Government Compliance Requirement: Reporting Type of Finding: Compliance and Internal Control over Compliance – Other Matter Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the U.S. Treasury that includes reporting the total grant expenditures incurred for the reporting period. Since the City is a Metropolitan City with a population below 250,000 residents that was allocated more than $10.0 million in funding, the City is required to submit, to the U.S. Department of Treasury, a project and expenditure report 30 days after the end of each quarter. The City is also required to submit quarterly reports to Bristol County no later than 15 days following the end of each fiscal quarter. Condition: The City submitted the quarterly project and expenditure report timely, however the expenditures reported as of June 30, 2023, did not reconcile with the City’s accounting ledger. Similarly, while the City submitted quarterly reports to the County timely, expenditures reported as of June 30, 2023, did not reconcile with the City’s accounting ledger. Questioned Costs: None Reported. Context: The City filed the required project and expenditure report in a timely manner, however the report submitted to the U.S. Treasury’s Portal did not reconcile with City’s accounting ledger. Similarly, the City filed the required quarterly reports to Bristol County in a timely manner, however the report submitted did not reconcile with the City’s ledger. Effect: The expenditures reported on the City’s project and expenditure report and County report were not accurate. Cause: The City did not have adequate controls in place to reconcile expenditures submitted on the project and expenditure and County reports with the City’s ledger. Recommendation: Management should implement procedures to ensure that all expenditures that are incurred in a particular reporting period are included on the applicable project and expenditure report. Additionally, the City should ensure that the omitted expenditures are reported in the next reporting submission. Views of Responsible Officials and Planned Corrective Actions: Management made a good faith effort to correctly report its expenditures to the U.S. Treasury Department and Bristol County on an accurate and timely basis. Reconciliation between the reporting and accounting ledger must be completed to ensure expenditures reported are accurate. Management expects to correct this on the subsequent period’s reporting in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Patrick D. Dello Russo Jr., Chief Financial Officer at (508)-821-1000. Sincerely yours, Patrick D. Dello Russo Jr Chief Financial Officer City of Taunton, Massachusetts

View Audit 306283

Finding 396661 (2023-001)

Material Weakness 2023

Mount Adams School District No. 209

WA

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

The District corrected the issue late in the stated audit period. The District will continue to ensure all applicable contracts include not just the term “prevailing wage” but specify “Federal Wage Rate Compliance” to comply with the applicable CFR. The District will also continue to verify payrolls...

The District corrected the issue late in the stated audit period. The District will continue to ensure all applicable contracts include not just the term “prevailing wage” but specify “Federal Wage Rate Compliance” to comply with the applicable CFR. The District will also continue to verify payrolls have been submitted by the contractor before issuing progress payments. Finally, the District will continue to retain documentation of this confirmation for audit. The District disagrees with the statement that, during the audit, the District subsequently collected all weekly certified payrolls. The District uses the Washington State Department of Labor and Industries prevailing wage system as the tool for all contractors to submit their weekly certified payrolls to the District. All weekly certified payrolls were submitted into the L&I system before the audit began and immediately provided to the audit team upon request.

View Audit 306282

Finding 396652 (2023-002)

Significant Deficiency 2023

City of Fayetteville

NC

Internal Control / Segregation of Duties Questioned Costs Reporting

Management's Response: The City agrees with the audit recommendations Responsible Party: Jody Picarells, Chief Financial Officer Corrective Action Plan: The corrective action plan will consist of the following measures: 1. Ensure staff are trained on proper submission of the PR29-CDBG Cash on Ha...

Management's Response: The City agrees with the audit recommendations Responsible Party: Jody Picarells, Chief Financial Officer Corrective Action Plan: The corrective action plan will consist of the following measures: 1. Ensure staff are trained on proper submission of the PR29-CDBG Cash on Hand Quarterly Report to include due dates for review and timely submission. 2. Ensure adequate staff are available, any combination of permanent, temporary or contracted positions, and assigned the task of timely submission of the PR29-CDBG Cash on Hand Quarterly Report. Proposed Implementation Date: May 31, 2024

View Audit 306255

Finding 396649 (2023-002)

Significant Deficiency 2023

Greenburgh Housing Authority

NY

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

Auditee's Response and Planned Corrective Action: HQS Failed Inspection register will be implemented immediately by the Section 8 Department. Planned Implementation Date of Corrective Action: 5/14/2024 Person Responsible for Corrective Action: Raju Abraham, Executive Director

View Audit 306245

Finding 396648 (2023-001)

Significant Deficiency 2023

Greenburgh Housing Authority

NY

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Auditee's Response and Planned Corrective Action: Recertification Checklist will be implemented immediately for use by the Section 8 Department. Planned Implementation Date of Corrective Action: 5/14/2024 Person Responsible for Corrective Action: Raju Abraham, Executive Director

View Audit 306245

Finding 396632 (2023-001)

Material Weakness 2023

Clarkston School District No. J250-185

WA

Subrecipient Monitoring Questioned Costs Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Clarkston School District No. J250-185 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Cod...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Clarkston School District No. J250-185 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements.Name, address, and telephone of District contact person: Randy Lybyer, Director of Financial Services 1294 Chestnut St Clarkston, WA 99403-0070 (509) 769-5538 Corrective action the auditee plans to take in response to the finding: The Clarkston School District welcomes the State Auditor’s Office review of federal wage rate requirements in our use of federal funds for the Grantham Elementary HVAC construction project. We agree with the auditor’s findings that our internal control structure was inadequate to ensure compliance with wage rate requirements. The following internal control processes have been implemented effective May 2023. 1. Identify public works projects and other contracts that require compliance with federal wage rate requirements through regular communication with District administrators and maintenance/operations management staff. 2. Complete and enhance the Districts contracts checklists for agreements entered into with contractors, agencies or purchasing cooperatives for the contraction of public works projects. 3. Consult with ESD, OSPI, and SAO to assure proper and complete terms are included in agreement documentation. 4. Collect and review weekly Certified Payroll Reports from contractors and subcontractors upon commencement of applicable projects until completion. 5. Confirmation of receipt and review of Certified Payroll Reports shall be verified prior to vendor payments. A contributing factor to this internal control weakness was turnover in key compliance positions during the time the contracts were being processed and construction was commencing. This finding effectively carried over from the prior audit period September 1, 2021 through August 31, 2022, to the current audit period September 1, 2022 through August 31, 2023. The final invoices for this project were received by the District in March 2023. The finding was originally identified after March 2023 and responded to in May 2023. The opportunity had passed for the District to include prevailing wage clauses in the contract and collect weekly certified payroll from the contractor. The internal control processes listed above were put into place after the project was completed. Anticipated date to complete the corrective action: Immediately

View Audit 306241

Finding 396604 (2023-005)

Material Weakness 2023

Phillips County Hospital Association

MT

Questioned Costs Material Weakness Reporting § 200.303

Management will submit the audited financial statements to the Department of Agriculture.

View Audit 306230

Finding 396603 (2023-004)

Material Weakness 2023

Phillips County Hospital Association

MT

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

Management will establish and fund a segregated reserve account.

View Audit 306230

Corrective Action Plans

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