Corrective Action Plans

Finding 382968 (2023-010)

Material Weakness 2023

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problemat...

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problematic for HHSC to commit to the specific designation of CAPPS-Financials as the improvement solution, actions will be taken to improve compliance. HHSC will implement a quality review of selected programs to assess FFATA compliance on an annual basis. Implementation date: September 1, 2025 Responsible person: Racheal Kane, Director, Federal Funds

View Audit 296491

Finding 382966 (2023-001)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Eligibility Internal Control / Segregation of Duties Questioned Costs § 200.303

Corrective action plan: To rectify the discrepancies in the EA Eligibility Application/Determination section of the IMPACT system, DFPS is implementing the following measures: 1. Research and Analysis: DFPS IT initiated research on 12/12/2023 to investigate the root cause of why the child became eli...

Corrective action plan: To rectify the discrepancies in the EA Eligibility Application/Determination section of the IMPACT system, DFPS is implementing the following measures: 1. Research and Analysis: DFPS IT initiated research on 12/12/2023 to investigate the root cause of why the child became eligible upon recertification. This research will be ongoing to comprehensively understand the underlying factors. 2. Database Audit: A database audit table was added in early October 2023 to expedite the identification of similar issues in the future. This enhancement aims to facilitate a quicker determination of the root cause for any inaccuracies related to EA eligibility. 3. Batch Analysis: The EA eligibility batch process will undergo a thorough analysis to ensure it accurately identifies children who should or should not be deemed EA eligible. Insights from this analysis will help optimize the batch process and prevent similar occurrences. 4. Project Review: A review of Project 65700, completed in August 2021, will be conducted to assess if any gaps in the re-certification batch allowed a child to be incorrectly considered EA eligible. The data fix performed during this project will also be scrutinized to ensure it adhered to accurate eligibility criteria. 5. Communication and Training: DFPS commits to ongoing communication and training for INV/AR staff regarding EA and the correct method of answering questions within the IMPACT system. This aims to enhance staff awareness and compliance with federal guidelines and internal policies. 6. Internal Quality Assurance: DFPS will strengthen its internal quality assurance reviews of cases eligible for EA. This proactive approach ensures ongoing compliance with federal guidelines and internal policies, thereby minimizing the likelihood of eligibility-related errors. 7. In Fiscal Year 2023, DFPS Investigations/Alternative Response personnel underwent supplementary training sessions and received revised policy and resource guides pertaining to Emergency Assistance (EA). These initiatives were implemented to address the concerns identified, specifically related to inaccuracies in responding to questions within the EA Eligibility Application/Determination. DFPS remains committed to these corrective actions to address the identified issues and continually improve the accuracy and reliability of the EA eligibility determination process. The effectiveness of these measures will be regularly assessed to uphold the integrity of the system and prevent improper payments. Citizenship: To rectify this situation and to ensure that a child that is not a U.S. citizen, qualified alien, or permanent resident does not receive EA benefits, DFPS is implementing the following measures: 1. DFPS Finance will work with program and IT to determine the best practices when answering citizenship and the Emergency Assistance (EA) eligibility questions and ensure the IMPACT system is reading the responses and applying the logic properly resulting in EA eligibility determination that is in compliance with United States Codes, Chapter 8 Aliens and Nationality, Chapter 14 – Restricting Welfare and Public Benefits of Aliens, §1611. 2. DFPS will review the list of non-citizens and update their eligibility if they are incorrectly deemed EA eligible. 3. DFPS will review the payments issued to non-citizens and process adjustments to ensure EA funds are used only for eligible activities. Implementation dates: IMPACT IT research begun on 12/12/2023 and will be ongoing to determine the root cause of the issue. Ongoing communication to staff. Citizenship: The first item will require a coordination with IT and programs and it’s completion date will be dependent on the efforts required to make the agreed upon changes. Item 2 and 3 is anticipated to be completed by May 31, 2024. Responsible persons: Jerome Green, CPI Deputy Director of Field; Citizenship: Scott Greer, Budget Director

View Audit 296491 Questioned Costs: $1

Finding 382959 (2023-003)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

Corrective action plan: DSHS TVFC compliance site visits are now separated into two stages: Process & Documentation and Oversight & Verification. During 2023, internal controls and role assignments were established for each phase to ensure appropriate entry into PEAR, review activities, and follow-u...

Corrective action plan: DSHS TVFC compliance site visits are now separated into two stages: Process & Documentation and Oversight & Verification. During 2023, internal controls and role assignments were established for each phase to ensure appropriate entry into PEAR, review activities, and follow-up activities. These controls are in place and expected to be used throughout fiscal year 2024. Implementation date: February 20, 2024 Responsible person: Denise Reeder, MPH, MA, Immunization Section, Vaccine Operations Group Manager

View Audit 296491 Questioned Costs: $1

Finding 382928 (2023-021)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly bas...

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly basis for all active grants. The OOG will ensure accuracy of Agency submissions by reconciling data between the eGrants Financial Status Reports (FSRs) and the Reconcilers. Should a variance exist, the OOG will document any changes made, and the reason therefore, with concurrence from the Agency. The OOG will update the reporting processes and institute new internal controls. For each reporting period, the ARPA Reporting Administrator will take the quarterly data provided for each grant and reconcile that information with the eGrants FSR data. The Public Safety Office (PSO) Grants Administration Director will verify the data. The PSO Executive Director will review and Administration Director will approve the reporting information prior to submission in to the ARPA Portal. Prior to final submission, the data will receive a quality assurance check. Implementation date: Full implementation by April 1, 2024 Responsible persons: Suzanne Johnson, Director of Administration and Aimee Snoddy, Executive Director Public Safety Office

View Audit 296491

Finding 382926 (2023-019)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

Corrective action plan: The OOG updated and documented the Change Management Procedures for Portal systems for all Portals subsequent to TTIR. The OOG began using Super Clio (the internally developed Change Management tracking system) for new projects and Portals, subsequent to TTIR, in accordance w...

Corrective action plan: The OOG updated and documented the Change Management Procedures for Portal systems for all Portals subsequent to TTIR. The OOG began using Super Clio (the internally developed Change Management tracking system) for new projects and Portals, subsequent to TTIR, in accordance with the new Change Management Procedure. Please see attached Change Management Procedure for OOG Information Services Division Portal systems. TTIR is a portal system that was created for a limited purpose and will decommission in the summer of 2024. The OOG will include the TTIR decommissioning project under the Change Management Procedure and mandate use of Super Clio. OOG Management does not anticipate further changes will be done to TTIR code, hotfixes applied, or content changes will be made. Any exceptions to this will be documented, approved, and signed by Management and put in the TTIR Program file for future evidence. Implementation date: Full implementation March 1, 2024 Responsible persons: Suzanne Johnson, Director of Administration, and Lars Hjaltman, Director of Information Services Division

View Audit 296491

Finding 382924 (2023-028)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.303

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will...

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will not only receive reports on totals for each budget, obligation, and expenditure field, but will also require the submission of backup documentation from the sending party. This additional step ensures that the team can independently verify the accuracy of reported figures. Furthermore, DRT will check the calculations within the backup documentation to confirm that the aggregate amounts align with the reported figures. These measures are designed to ensure that the HAF program's reporting is both accurate and reflective of activities. Implementation date: February 12, 2024 Responsible persons: David Johnson, HAF/TRR Data and Reporting Manager; Lizet Hinojosa, Director of HAF; Grace Timmons, Assistant Director of HAF; Lanette Johndrow, Director of HAF Subrecipient Activities; and Teri- Ann Parise, HAF Financial Analyst. Corrective action plan: For legal and counseling services, a report has been created that pulls all costs from the Housing Contract System and separates the data by Intake, Housing and Legal to allow for an appropriate report of all costs. This report is to be run weekly and updated by the Director of HAF Subrecipients, and then given to the finance department to verify against paid invoices for validation. Any discrepancies are to be discussed immediately and resolved. Implementation date: July 17, 2023 Responsible persons: Lanette Johndrow, Director of HAF Subrecipient Activities; Teri-Ann Parise, HAF Financial Analyst; and Mariah Tamayo, Financial Analyst

View Audit 296491

Finding 382923 (2023-027)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Corrective action plan: Yardi and AmeriNat Case auditors and supervisors have been reminded that the original loan amount and origination date must be verified before approving a case. The CDF portal should have these columns completed. If the CDF does not include the original loan amount and origin...

Corrective action plan: Yardi and AmeriNat Case auditors and supervisors have been reminded that the original loan amount and origination date must be verified before approving a case. The CDF portal should have these columns completed. If the CDF does not include the original loan amount and origination date, case auditors will ask the loan servicer for a corrected record which includes the original loan amount and origination date in order to confirm conforming loan limits. For non-traditional loan servicers, a deed of trust or settlement statement will continue to be requested from the homeowner. As it relates to the specific case in question, the Reinstatement (R program) plus Monthly Payment Assistance (U Program) case was originally a HAF Contribution to Modification case (P Program.) The case was transferred from the P Program to the R Program on 8/23/2022 and due to a technical issue, the Yardi portal did not add the U Program to the existing R Program. On 1/17/2024, the U Program was manually added to the R Program and payment was made to the homeowner’s loan servicer for the three additional monthly payments. Implementation date: January 17, 2024 Responsible persons: Lizet Hinojosa, Director of HAF and Grace Timmons, Assistant Director of HAF

View Audit 296491

Finding 382922 (2023-026)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs § 200.302 § 200.303

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corre...

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corrected. Implementation date: March 31, 2024 Responsible person: David Johnson, HAF/TRR Data & Reporting Manager

View Audit 296491

Finding 382919 (2023-023)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and...

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. TDA FND provided correspondence emails and incident reports documentation with screenshots for the FSRS technical issues to CLA:  CNC_NSLP grant: TDA FND informed CLA auditors that agency has been experiencing significant technical difficulties uploading the FFATA data into FSRS. During these attempts, the system shows the following error message: "Sub-awardee Awardee Address - Congressional District could not be validated/matched from the provided address and zip+4." Unfortunately, this occurred on numerous uploads (300-400) every time an attempt was made. As a disclaimer, a single error will prevent an entire report from being uploaded into the system. TDA FND staff has contacted the FSRS helpdesk many times to no avail, resulting in reports not being uploaded and causing TDA FND to be behind on the FFATA reporting.  FFVP grant: TDA allocates FFVP funds to CEs during two periods of operation. If CEs do not spend the funds, then TDA must either (1) reallocate or (2) let the funds lapse and return to USDA. Considering the nature of the grant allocation and USDA requirements of maximizing grant spending to benefit schools during this process, it might cause a discrepancy between what was reported on the FFATA report and what was adjusted after the fact. As of today, the system error continues to occur with TDA FND staff having little to no control over it. TDA would like to emphasize that the help desk process with FSRS is not expedient and would cause the loss of employee productivity if the burden to remedy the systems issues (beyond recording unsuccessful attempts) was delegated to the state. TDA FND staff will continue to prepare the reports and attempt to submit them as required. TDA FND Staff will document instances where the upload is unsuccessful. CDBG – TDA will ensure that all FFATA reports are submitted timely. For CDBG, program staff has implemented procedures to ensure that FFATA reports are prepared, reviewed by the Director of CDBG Programs, and submitted on a monthly basis. Implementation dates: CDBG: January 2024 CNC: March 1, 2024 Responsible persons: CDBG: Suzanne Barnard, Director for CDBG Programs CNC: Anwar Sophy, Administrator, TDA FND Business Management

View Audit 296491

Finding 382918 (2023-022)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs HUD Housing Programs Reporting § 200.303

Corrective action plan: TDA has completed the noted adjustments and submitted a corrected PR-28 for Program Year 2022 to HUD. Implementation date: February 1, 2024 Responsible person: Suzanne Barnard, Director for CDBG Programs

View Audit 296491

Finding 382909 (2023-003)

Significant Deficiency 2023

Southern Oregon University

OR

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

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of Education when required....

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of Education when required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding. At the time of the audit, management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed in February 2024. Names of the contact persons responsible for corrective action: Agnes Maina Planned completion date for corrective action plan: Completed

View Audit 296487

Finding 382908 (2023-002)

Significant Deficiency 2023

Southern Oregon University

OR

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding as it was identified and rectified during an internal audit earlier this year. Effective Fall 2023 a new process is in place that incorporates all Title IV funding into the current stale-dated refund check process. The Bursar and the Student Financial aid office will closely monitor aging checks and reissue or return funds to the Department of Education. Names of the contact persons responsible for corrective action: Stephanie Hanigan and Karinda Decker Planned completion date for corrective action plan: Completed

View Audit 296487 Questioned Costs: $1

Finding 382907 (2023-001)

Significant Deficiency 2023

Southern Oregon University

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure ...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Action taken in response to finding: The Student Records Specialist will increase monitoring of Clearinghouse data. SOU will also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Issues that are identified will be communicated to the Director of Financial Aid and University Registrar for reconciliation. Name(s) of the contact person(s) responsible for corrective action: Karinda Decker and Matt Stillman Planned completion date for corrective action plan: Immediately

View Audit 296487

Finding 382884 (2023-001)

Material Weakness 2023

School Town of Speedway

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

The Superintendent, Corporation Treasurer and Director of Facilities will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities will tag the equipment and notify the company when the Fixed Asset Inventory is completed. Responsible party and timeline ...

The Superintendent, Corporation Treasurer and Director of Facilities will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities will tag the equipment and notify the company when the Fixed Asset Inventory is completed. Responsible party and timeline for completion: Superintendent, Corporation Treasurer and Director of Facilities. Fixed Asset Inventory is completed once every 2 years. Next inventory will be completed in June, 2025 and the equipment not listed will be added at that time.

View Audit 296461

Finding 382880 (2023-003)

Significant Deficiency 2023

Housing and Redevelopment Authority of Chisholm, Minnesota

MN

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

The Authority will budget for CFP funds for operations in their operating budget to ensure compliance with the special test and provisions of CFP compliance requirements

View Audit 296455

Finding 382878 (2023-001)

Significant Deficiency 2023

Housing and Redevelopment Authority of Chisholm, Minnesota

MN

Internal Control / Segregation of Duties Reporting

Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size.

View Audit 296455

Finding 382869 (2023-004)

Material Weakness 2023

Northeast School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.328

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II),...

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II), and Elementary and Secondary School Emergency Relief (ESSER III) Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Number: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have a review control in place to ensure the annual data report was reviewed by someone other than the preparer and that the report was submitted timely. Context: The Annual Data Report for the period of July 1, 2021 to June 30, 2022 was due to the Indiana Department of Education (IDOE) by April 7, 2023. The School Corporation did not submit the report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will submit future reports in a timely manner. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer Effective for the 2023-2024 school year

View Audit 296449

Finding 382857 (2023-007)

Material Weakness 2023

Northeast School Corporation

IN

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

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Fe...

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

View Audit 296449

Finding 382835 (2023-005)

Material Weakness 2023

Northeast School Corporation

IN

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

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Pre...

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. The lack of internal controls was a systemic issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: The Superintendent and Treasurer of Northeast School Corporation will review the documentation for the Cooperative at least semi-annually. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

View Audit 296449

Finding 382830 (2023-005)

Material Weakness 2023

North White School Corporation

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Finding 2023-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls over Equipment Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Year...

Finding 2023-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls over Equipment Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation expended $2,354,885 during the audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building. Equipment acquisitions were charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. During the testing of equipment acquisitions, it was noted the School Corporation had not update the capital asset ledger as of June 30, 2023 for equipment acquisitions made during the period under audit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. When the capital asset inventory is completed, the Corporation Treasurer and the Building/Maintenance Director will verify the inventory is up to date and accurate. Responsible Party and Timeline for Completion: The Corporation Treasurer, Emma Conwell, and Building/Maintenance Director, Dean Cook, will oversee the corrective action plan which will be implemented by June 30, 2024.

View Audit 296431

Finding 382825 (2023-001)

Significant Deficiency 2023

Delta Sigma Theta Sorority Inc.

DC

Questioned Costs Procurement, Suspension & Debarment Reporting

The Board approved a new Credit Card Policy of the Sorority in May 2021. Credit cards are an integral part of the mix of instruments available for managing payment relationships with vendors. At present, the Sorority maintains six (6) sponsored credit cards and we recognize and acknowledge that a m...

The Board approved a new Credit Card Policy of the Sorority in May 2021. Credit cards are an integral part of the mix of instruments available for managing payment relationships with vendors. At present, the Sorority maintains six (6) sponsored credit cards and we recognize and acknowledge that a material risk of exposure is present. While Delta Sigma Theta has a formal credit card policy in place, it has not been consistently following to ensure that assets of the organization are safeguarded. We are implementing a number of new processes and procedures to ensure that future credut card expenditures are documented with the following: 1. Valid business purpose; 2. Vendor receipts included as documentation and support, and; 3. Evidence of proper approval. This will ensure tht the credit card expenses are properly accounted for and reconciled within the general ledger. To achieve the stated objectives, the finance and accounting department has begun implementing a number of internal controls. Payment processes and procedures are being developed for transactions beginning January 1, 2024. They are as follows: 1. Develop a Credit Card Expense Request document that must be completed by those requesting expenditures that includes and discusses the business prupose of the expense. 2. Continuous training with those charged with making purchases with credit cards and those completing reports on the how to utilize the reports developed, how to properly code items to the general ledger and the documentation needed to substantiate the request. 3. New hirings, including new CFO and Director, that started in 2023. Restructuring the team to include higher level accounting staff that have greater education and experience with GAAP accounting. 4. Enforcement by management of its formal credit card policy throughout the year. 5. Monthly reconciliations that highlight compliance and allows for timely enforcement and correction of non-compliance.

View Audit 296427

Finding 382799 (2023-003)

Material Weakness 2023

Nettle Creek School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting 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 an...

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting 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 following compliance requirements: Reporting The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for ESSER II, Year 1, annual report tested the School Corporation could provide supporting documentation that did not agree with the ESSER II, Year 1, annual report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated from ESSER 1I, Year 1 report. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will prepare annual reports for grants and the Director of Learning and/or Superintendent will review and sign-off reports before submission. Anticipated Completion Date: June 30, 2024

View Audit 296407

Finding 382767 (2023-005)

Material Weakness 2023

Lakeland School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had a lack of internal controls over the ESSER reporting to the IDOE. There was no review process in place to prevent, or detect and correct, errors. Contact Person Responsi...

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had a lack of internal controls over the ESSER reporting to the IDOE. There was no review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The Director of Business Operations and Director of Staff and Student Success will meet to review the annual data reports for accuracy before they are submitted to the IDOE. The meeting will be logged and reports signed off by both individuals. Anticipated Completion Date: Immediately

View Audit 296373

Finding 382765 (2023-004)

Material Weakness 2023

Lakeland School Corporation

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303 § 200.313

FINDING 2023-004 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation has a lack of internal controls over the asset records. Two floor scrubbers purchased during the audit period were missing from the asset list. ...

FINDING 2023-004 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation has a lack of internal controls over the asset records. Two floor scrubbers purchased during the audit period were missing from the asset list. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 29 Description of Corrective Action Plan: The Director of Business Operations will maintain a spreadsheet of assets purchased and disposed. The spreadsheet will then be compared to the list completed by the outside asset management company to ensure assets are recorded properly in the records. Anticipated Completion Date: Immediately

View Audit 296373

Finding 382761 (2023-003)

Material Weakness 2023

Lakeland School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee t...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee to ensure compliance. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Claims for Reimbursement will be prepared by the Food Service Director and the Director of Business Operations will review the claims for compliance. The claims will then be initialed signaling they have been reviewed. Anticipated Completion Date: Immediately

View Audit 296373

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