Corrective Action Plans

Finding 384414 (2023-004)

Material Weakness 2023

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.303

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related t...

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. There was no documentation of a review process to confirm that all appropriate staff completed assessment system security training as required. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Special Tests and Provision – Assessment System Security – All personnel who come in contact with state assessment are trained in prodigals, procedures, and security. Everyone trained has completed a security and integrity agreement, which is kept on file at each school. The School Testing Coordinators (principals) will send to the Corporation Testing Coordinator, Tanner Hedrick, a copy of the security and integrity agreement and a copy of the sign in sheet for the state assessment training. Mr. Hedrick will verify that all appropriate personnel have be adequately training and will sign the sign in sheets after he confirms the information is complete. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384412 (2023-003)

Material Weakness 2023

Rush County Schools

IN

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

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the ...

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The October 1st Real Time Report of Pupil Enrollment (PE) was used by the Indiana Department of Education to pull data into the Title I application. These numbers were then used to calculate Percent Poverty which was used to rank schools for Title I eligibility. One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. The Indiana Department of Education (IDOE) used the October 1 Real Time reports for fiscal years 2020- 2021 and 2021-2022, as provided by the School Corporation, to determine Title I Eligibility for the 2021- 2022 and 2022-2023 grant programs, respectively. There was no October 1 Real Time report presented for audit for fiscal year 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Eligibility – The Technology Director, Brevin Runnebohm will supply the Title I director with the official October 1 count each school year. This will be retained for audit and will be used by the Grant Coordinator, Nancy Schroeder, to determine the enrollment numbers in the Title I application have INDIANA STATE BOARD OF ACCOUNTS 45 been prepopulated correctly. The Grant Coordinator will sign off that she has reviewed this information and find it accurate. Anticipated Completion Date: 10/2024

View Audit 297571

Finding 384408 (2023-001)

Material Weakness 2023

Wadsworth City School District

OH

Questioned Costs School Nutrition Programs Cash Management

Finding Number: 2023-001 Planned Corrective Action: In previous school years the Wadsworth City School District allowed a student to charge up to $10.00 before an alternative lunch was provided. At that time the Point of Sale (POS) system only allowed student accounts to go up to a negative $10.0...

Finding Number: 2023-001 Planned Corrective Action: In previous school years the Wadsworth City School District allowed a student to charge up to $10.00 before an alternative lunch was provided. At that time the Point of Sale (POS) system only allowed student accounts to go up to a negative $10.00. Recently the district changed this policy (due to donations from community members) to allow students to charge beyond the $10.00. However, instead of changing the $10.00 limit in POS a courtesy lunch option was created. This allowed the cashier to charge a courtesy lunch to the student. Later in the day the Food Service Supervisor would override the $10.00 limit and post all courtesy lunch charges to the student’s account. During the 2022-23 school year the Food Service Director was under the understanding that charged lunches could be reimbursed at the free lunch reimbursement rate. Therefore, the Food Service director was allocating all the courtesy lunches to free and the district was receiving the full reimbursement rate. Correction: 1) The district is aware that courtesy lunches are not eligible for free lunch rate reimbursement and the Food Service Supervisor is no longer reporting lunches in this manner beginning with the 2023-24 school year. 2) The courtesy button has been removed from the electronic cash register and the POS system now allows students to go beyond $10.00 for charging purposes. This eliminates the manual process that was being done each day and eliminates the possibility that paid or reduced lunch students are reported as free lunch students. Anticipated Completion Date: 1) The change for reporting courtesy lunches as free lunches occurred at the start of the 2023-24 school year. 2) The change removing the courtesy lunch button from the cash register and allowing students to charge more than $10.00 occurred on February 23, 2024 Responsible Contact Person: Douglas D. Beeman, Treasurer Kelly Gnap, Food Service Director

View Audit 297568 Questioned Costs: $1

Finding 384400 (2023-002)

Significant Deficiency 2023

Parc Developmental Homes, Inc., Project No 072-11104

IL

Internal Control / Segregation of Duties Questioned Costs HUD Housing Programs

2023-002 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects – CFDA No. 14.155 Recommendation: Management should fully fund the reserve for replacements and also ensure the Corporation makes the required payment to the reserve for replacements on a monthly bas...

2023-002 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects – CFDA No. 14.155 Recommendation: Management should fully fund the reserve for replacements and also ensure the Corporation makes the required payment to the reserve for replacements on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will monitor to ensure the Corporation makes the required payments to the reserve on a monthly basis. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 297532

Finding 384399 (2023-001)

Significant Deficiency 2023

Parc Developmental Homes, Inc., Project No 072-11104

IL

Internal Control / Segregation of Duties Reporting Significant Deficiency

U.S. Department of Housing and Urban Development 2023-001 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects – CFDA No. 14.155 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management's and the...

U.S. Department of Housing and Urban Development 2023-001 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects – CFDA No. 14.155 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management's and the board’s close supervision and review of accounting information can help to prevent or detect errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and reconcile bank accounts with the general ledger, particularly for training purposes and periods when there are staff vacancies. Financial resources are insufficient to hire the additional staff to allow for greater segregation of responsibilities. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 297532

Finding 384398 (2023-002)

Significant Deficiency 2023

Parc Place, Inc., Project No. 072-Hd112

IL

Internal Control / Segregation of Duties Questioned Costs HUD Housing Programs

2023-002 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: To establish proper internal control over security deposit refunds, the Corporation should design and implement the necessary procedures to ensure th...

2023-002 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: To establish proper internal control over security deposit refunds, the Corporation should design and implement the necessary procedures to ensure the move-out notifications are provided to the accounting office in a timely manner and ensure the tenant's security deposit is processed and refunded within 30 days of the move-out date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will monitor future move-outs to ensure the security deposits are processed and refunded within 30 days of the move-out date. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 297529

Finding 384397 (2023-001)

Significant Deficiency 2023

Parc Place, Inc., Project No. 072-Hd112

IL

Internal Control / Segregation of Duties Reporting Significant Deficiency

U.S. Department of Housing and Urban Development 2023-001 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, mana...

U.S. Department of Housing and Urban Development 2023-001 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management’s and the board’s close supervision and review of accounting information can help to prevent or detect errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and reconcile bank accounts with the general ledger, particularly for training purposes and periods when there are staff vacancies. Financial resources are insufficient to hire the additional staff to allow for greater segregation of responsibilities. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 297529

Finding 384396 (2023-001)

Significant Deficiency 2023

Parc Residential Options, Inc., Project No. 072-Hd045

IL

Internal Control / Segregation of Duties Reporting Significant Deficiency

U.S. Department of Housing and Urban Development 2023-001 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, mana...

U.S. Department of Housing and Urban Development 2023-001 Section 811 – New Construction – Capital Advance Program – Supportive Housing for Persons with Disabilities – CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management’s and the board’s close supervision and review of accounting information can help to prevent or detect errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and reconcile bank accounts with the general ledger, particularly for training purposes and periods when there are staff vacancies. Financial resources are insufficient to hire the additional staff to allow for greater segregation of responsibilities. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 297525

Finding 384395 (2023-001)

Significant Deficiency 2023

Vna Apartments, Inc.

WI

HUD Housing Programs Internal Control / Segregation of Duties

Financial Reporting – The Organization has evaluated the cost/benefit of outsourcing the task of preparing the financial statements to an external accountant. It would be cost prohibitive to hire additional staff to outsource the task to an outside accountant. However, management of the Organization...

Financial Reporting – The Organization has evaluated the cost/benefit of outsourcing the task of preparing the financial statements to an external accountant. It would be cost prohibitive to hire additional staff to outsource the task to an outside accountant. However, management of the Organization has obtained the necessary skills, knowledge, and experience to accept responsibility for preparation of the Organization’s financial statements. Responsible Official - Vicki McAuliffe, CFO Anticipated Completion Date: The finding will not completely resolve itself given the cost/benefit the Oganization continues to make.

View Audit 297523

Finding 384391 (2023-001)

Material Weakness 2023

Cheyenne Independent School District #7

OK

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Cheyenne Public Schools have developed internal controls to meet the Davis-Bacon Act. Any time federal awards are used on construction Cheyenne Public School will be in compliance. We have an effective monitoring process to ensure all contracts are in compliance, contracts will include prevailing ...

Cheyenne Public Schools have developed internal controls to meet the Davis-Bacon Act. Any time federal awards are used on construction Cheyenne Public School will be in compliance. We have an effective monitoring process to ensure all contracts are in compliance, contracts will include prevailing wage clauses to assure federal wage rates and fringes will be met. We will review weekly certified payroll reports from the contractors/subcontractors as well as post all items at the work site to ensure compliance.

View Audit 297492

Finding 384365 (2023-003)

None 2023

Eastern University

PA

Questioned Costs Eligibility Internal Control / Segregation of Duties

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Rut...

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: Completed

View Audit 297474 Questioned Costs: $1

Finding 384358 (2023-001)

Material Weakness 2023

Eastern University

PA

Questioned Costs Student Financial Aid Material Weakness

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and deter...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023

View Audit 297474

Finding 384354 (2023-001)

Significant Deficiency 2023

University of Denver

CO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469 Questioned Costs: $1

Finding 384339 (2023-001)

Significant Deficiency 2023

Chestnut Health Systems, INC

IL

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.430

An automated reporting process of salaries through our payroll provider (ADP) has been established to eliminate the manual data entry of payroll amounts. This will eliminate the opportunity for errors in manual salary entries.

View Audit 297454 Questioned Costs: $1

Finding 384321 (2023-002)

Significant Deficiency 2023

Erikson Institute

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

View Audit 297439

Finding 384318 (2023-001)

Significant Deficiency 2023

Erikson Institute

IL

Internal Control / Segregation of Duties Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GL...

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GLBA) by June 9, 2023, the required date of compliance. Of the eight required elements under the GLBA, the Institute did have six written and formally documented safeguards, one is not applicable (assess apps developed by institution) and one had safeguards designed (dispose of customer information securely) but not a written policy in place. Corrective Action Plan A comprehensive formal Information Security Policy that addresses all required safeguards under the GLBA has been drafted, and as of March 2024 is in its final institutional review with approval expected in April 2024. Contact Person Ed Baker IT Director ebaker@erikson.edu Anticipated Completion Date April 2024

View Audit 297439

Finding 384307 (2023-002)

Significant Deficiency 2023

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.

View Audit 297438

Finding 384306 (2023-001)

Significant Deficiency 2023

Desert Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.

View Audit 297438

Finding 384299 (2023-004)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagr...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As noted above, the Authority has contracted the services of a third-party vendor and hired a Senior Quality Control Inspector to assist with the completion of inspections. As part of the Quality Control Plan the Authority tracks failed inspections. In addition to monitoring failed inspections, The Authority has required trainings or HCVP Department staff and partner agency staff, including HQS standards and HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384296 (2023-003)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has contracted the services of a third-party vendor to assist with completing overdue inspections. The Authority has also hired a Senior Quality Control Inspector to assist with the completion of overdue inspections. The Senior Quality Control Inspector will develop a Quality Control Plan by [date]. The Authority is currently making software upgrades to align with HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). In addition, the Authority is assessing technology needs of inspectors and considering possible technological improvements. Currently, The Authority PCOs have begun to monitor late inspections monthly. PCOs work with the LHAs to develop a plan to address late inspections and include a due date. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024.

View Audit 297428

Finding 384293 (2023-002)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/HAP Contract Amendment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has developed a checklist system for each step in the process for determining and documenting rent reasonableness. The checklist includes each step of the process, along with due dates, and responsible entities. As part of the development and implementation of the quality control process for the HAP process, noted above, the Authority will also include a process for ensuring approved rent reasonableness match contract rents on all supporting documentation. The Authority will implement monthly reviews of HUD-50058 forms, HAP contracts and rent reasonableness documentation by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or HCVP’s accounting staff will work closely together, coordinate and follow the procedures for correcting any issues identified during the reviews. The Authority will also develop and implement a monitoring plan to ensure Local Housing Agencies (LHAs) are correctly following all the Authority established policies and procedures and adhering to Federal Regulations. The monitoring plan will outline how The Authority will conducts a risk analysis to target monitoring resources to the highest risk LHAs. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384290 (2023-001)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Eligibility

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review t...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review their internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend the Authority review their process for uploading data to PIC to ensure each recertification gets submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has begun the assessment, development and implementation of several internal controls to address recertification documentation, HAP processes, and PIC data submission to ensure compliance with Federal regulations. The Authority will develop and implement a quality control process on or before June 30, 2024, to ensure all documentation is maintained, signed and dated by all required parties at the time of certification. Currently, the Authority has developed a checklist system for each step of the recertification process. The checklist includes each step of the recertification process, along with due dates, and responsible entities. While not a Federal Requirement, the Authority did establish the discretionary policy to require housing specialists sign and date the Housing Information Forms. This policy was implemented after this audit finding and would not have been a requirement of the one file reviewed by the audit team. However, this step is included in the checklist process. The Authority is actively working to modify the electronic documentation and record retention system and process. Planned implementation of new electronic documentation and record retention processes is contingent on system updates managed by third party venders, however new written internal procedures are under development. The Authority will develop and implement a quality control process for the HAP process on or before June 30, 2024. This will include procedures for Program Compliance Officers (PCOs) and HCVP’s Accounting Team to work closely and coordinate to ensure each responsible person fully understands their roles and responsibilities. The Authority will implement monthly reviews of HAP payments, by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or accounting staff will follow the procedures for correcting any issues identified during the reviews. Over the past year, the Authority has created a System and Reporting Team that is now responsible for timely PIC submissions and addressing discrepancies and/or errors in the PIC and/or EIV system. By having a dedicated team, the Authority now exceeds the HUD requirement of submitting PIC data within 60 days of the effective date of any action. The Authority submits PIC monthly, performs monthly reviews of PIC data, and ensures staff addresses all fatal errors. In addition to these processes, the System and Reporting Team receives one on one training to address specific and challenging errors and discrepancies. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384289 (2023-002)

None 2023

Trinity Bible College and Graduate School

ND

Questioned Costs Student Financial Aid Reporting

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporti...

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.

View Audit 297426

Finding 384251 (2023-002)

Significant Deficiency 2023

Manhattan School of Music

NY

Subrecipient Monitoring Internal Control / Segregation of Duties

During the spring 2023, the Interim SVP and CFO recognized the School’s Trial Balance needed to better distinguish between Net Assets without Donor Restrictions and Net Assets with Donor Restrictions. That enhanced viewing was accomplished during the spring 2023 and the Interim SVP and CFO believes ...

During the spring 2023, the Interim SVP and CFO recognized the School’s Trial Balance needed to better distinguish between Net Assets without Donor Restrictions and Net Assets with Donor Restrictions. That enhanced viewing was accomplished during the spring 2023 and the Interim SVP and CFO believes that effort and Management’s Response to Finding 2023-001 will improve the accounting and reporting of net assets including the endowment.

View Audit 297400

Finding 384240 (2023-001)

Significant Deficiency 2023

Santa Ana Unified School District

CA

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

1) The HR Master is the source report that will be used to report FTEs. The report is accessible through the Human Resources module as a download request, and has been modified to reflect a column for actual FTEs with a disclaimer of what positions to exclude from that report to generate the correct...

1) The HR Master is the source report that will be used to report FTEs. The report is accessible through the Human Resources module as a download request, and has been modified to reflect a column for actual FTEs with a disclaimer of what positions to exclude from that report to generate the correct count and/or sum of FTE totals. This revised HR Master reports is being shared with staff who are responsible for fulfilling FTE count requests. Having everyone informed of what source document to use for FTE reporting ensures that errors in FTE reporting are averted and minimized. 2) Requests for FTE counts should come directly to the Position Control office. The request must include specific instructions as to what FTE counts are being requested and what the purpose for the request is. Where applicable, the requesting department must provide the Position Control office with an excerpt of the report delineating the type of FTE counts request for the pertinent figures to be provided. 3) If the Position Control office staff is out, Human Resources is responsible for providing FTE counts to the requesting department by generating the HR Master report above, for the date range being requested; a copy of that report must be saved in a centralized electronic repository (Business Shared drive) with the corresponding program label and date range of the data requested. The downloaded reports serving as supporting documentation will then be accessible for providing to auditors, upon request, and the source documentation must be retained in compliance with federal/state/local program retention policies (in this instance, for subsequent 3 years. 4) As an added preventative measure, the department tasked with filing reports should always seek supporting documentation (if not already provided), and save it on the designated shared drive. This practice ensures accessibility for new staff members responsible for a particular program, allowing them to review past actions. It is essential to consistently attach supporting documentation to the filed report to preserve the audit trail and record-keeping procedures. Management understands the importance of addressing these issues promptly and effectively to ensure the integrity of our internal controls and compliance processes. Our team is fully committed to implementing the corrective actions above.

View Audit 297392

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