Corrective Action Plans

Finding 45176 (2022-003)

Significant Deficiency 2022

KS

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2022-003 Return of Title IV (R2T4) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the r...

2022-003 Return of Title IV (R2T4) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure the correct number days are used in all R2T4 calculations, including times when there are break days during the school term. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: This has begun with the 2022-23 school term

View Audit 44253

Finding 45175 (2022-002)

Significant Deficiency 2022

Tabor College, Inc.

KS

Eligibility Reporting Significant Deficiency

2022-002 Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR ...

2022-002 Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: April 2, 2023

View Audit 44253

Finding 45152 (2022-001)

Significant Deficiency 2022

Unified School District Number 494

KS

Reporting School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Child Nutrition Cluster Federal Assistance Listing Numbers: 10.553; 10.582; 10.559 Finding 2022-001 ? Internal Controls Recommendations: The District should have an...

FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Child Nutrition Cluster Federal Assistance Listing Numbers: 10.553; 10.582; 10.559 Finding 2022-001 ? Internal Controls Recommendations: The District should have an employee compare the District Treasurer?s supporting documentation and the Child Nutrition report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2022.

View Audit 50283

Finding 45146 (2022-001)

Significant Deficiency 2022

Housing and Redevelopment Authority of Fergus Falls

MN

Internal Control / Segregation of Duties

Item 2022-001. Inadequate Segregation of Duties Recommendation ? Although it may not be economically feasible for the Organization to attain an ideal segregation of duties environment, the Organization can periodically observe and evaluate its current structure so as to make improvements when consi...

Item 2022-001. Inadequate Segregation of Duties Recommendation ? Although it may not be economically feasible for the Organization to attain an ideal segregation of duties environment, the Organization can periodically observe and evaluate its current structure so as to make improvements when considered necessary. Action Planned ? The Organization has determined the benefit of adequately segregating duties is less than the cost. Based on the assessment, the Organization is accepting the risk posed by the deficiency while also evaluating mitigating controls that will help reduce the risk of material misstatement of the financial statements. Management attempts to mitigate the associated risks by doing the following: 1. Identifies areas where lack of segregation of duties exists and where there are higher risks of errors or fraud occurring. 2. Implements limited segregation to the extent possible to reduce risks without impairing efficiency. 3. Uses the knowledge that management and the Board of Directors have of operations by having them review certain accounting records and reports. 4. Monitors the effectiveness of the above actions and makes changes as considered appropriate. (2) Findings ? Major Federal Awards Programs Audit Department of Housing and Urban Development Significant deficiency 2022-001 above applies to the major federal awards programs.

View Audit 47849

Finding 45136 (2022-004)

Material Weakness 2022

South Dearborn Community School Corporation

IN

Special Tests & Provisions Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses ar...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses are incurred and paid by the district instead of reimbursing the private schools their expenses. This will be reviewed by the Director of Curriculum to ensure compliance. Anticipated Completion Date: March 2023

View Audit 45261

Finding 45098 (2022-002)

Significant Deficiency 2022

North Olympic Healthcare Network

WA

Subrecipient Monitoring Reporting Significant Deficiency

U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost reven...

U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost revenue amounts on any subsequent filings, if applicable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will design and implement procedures of review ensuring the appropriate option is selected for how lost revenue is reported for any future reporting periods and on any subsequent filings. Name(s) of the contact person(s) responsible for corrective action: Beau Brown, CFO Planned completion date for corrective action plan: September 30, 2023.

View Audit 40455

Finding 45097 (2022-001)

Significant Deficiency 2022

North Olympic Healthcare Network

WA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Health and Human Services 2022-001 Health Center Program Cluster? Assistance Listing No. 93.224 & 93.527 Recommendation: Management should review their policies and procedures with the personnel responsible for providing the sliding fee discount. We also recommend that management ...

U.S. Department of Health and Human Services 2022-001 Health Center Program Cluster? Assistance Listing No. 93.224 & 93.527 Recommendation: Management should review their policies and procedures with the personnel responsible for providing the sliding fee discount. We also recommend that management implement, monthly or quarterly, a self-audit process of newly approved sliding fee discount applicants and their associated patient record. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has designed and implemented continuous training regarding the sliding fee discount program policies and procedures, and monthly internal audit reviews of approved sliding fee discount applicants and their associated patient record. Name(s) of the contact person(s) responsible for corrective action: Beau Brown, CFO Planned completion date for corrective action plan: September 30, 2023.

View Audit 40455

Finding 45031 (2022-001)

Significant Deficiency 2022

Paladin, Inc.

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.475

Audit Finding Number: 2022-01 Finding Details: An effective internal control system was not in place to ensure compliance with the requirements related to the Cost Principles/compliance requirements. Recommendation: We recommend that Paladin Inc.?s management revise a system of in...

Audit Finding Number: 2022-01 Finding Details: An effective internal control system was not in place to ensure compliance with the requirements related to the Cost Principles/compliance requirements. Recommendation: We recommend that Paladin Inc.?s management revise a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Taken or to be Taken: Revision of the Paladin Travel Reimbursement procedure was made to the procedure already in place. If already taken, date of completion: Paladin has revised detailed procedures for processes involved with the Head Start grant. Staffing processes have been modified to accommodate the additional review of travel reimbursement prior to draws from the grant. If to be taken, estimated date of completion: Revised procedure completed 11-1-2022. Accounting staff completed a review of Head Start draws for travel reimbursement back to 7/1/22 (FY23) to be sure that draws from the grant were correct. Additional Comments: Paladin CFO stated that Paladin did have a procedure in place for processing travel reimbursements; however, it did not have a secondary procedure review in place prior to draws from the federal grant. Paladin contact person(s) responsible for findings. Name and title: Evelyn Marvel, Financial Officer

View Audit 40407

Finding 45027 (2022-001)

Significant Deficiency 2022

Chespenn Health Services, Inc.

PA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Servi...

Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Services, Inc.'s Compliance Officer and Chief Operating Officer will conduct random monthly audits of sliding fee applications at all three locations. Results from the audits will be presented to the site Office Manager who will then conduct staff training sessions with the Patient Service Representatives. The audit and subsequent training will include a review of the following parameters for proper documentation and sliding fee scale determination: Identification: o State issued driver's license o State issued or state recognized identification card o School identification o Government issued passport o If married, a copy of spouse's identification as well Social Security Cards: o For the applicant o For the spouse, if married o For all dependents 18 years of age or younger o For a college student, up to 23 years of age with college documentation o If a social security card is not available for a child, a birth certificate will be accepted Paystubs: o One recent pay stub, if married a copy from spouse as well o Benefits statement from social security, if married from husband and wife o Awards letter for unemployment, if married from husband and wife o Self-employed - Last year's income tax statement o If paid in cash, a letter from the employer, on company letter head that states the hourly rate and hours worked o If the letter is handwritten, the letter must be notarized o When an individual has no source of income and has no insurance, they are required to fill out the information on the front and the back of the sliding fee scale form. Photo identification and social security cards are required Responsible Party: Susan Harris-McGovern, President/CEO Susan.harris@chespenn.org, 610-485-3800 Estimated Time of Completion: March 31, 2023

View Audit 40406

Finding 45026 (2022-001)

Significant Deficiency 2022

Village Cooperative of Marshalltown

IA

Internal Control / Segregation of Duties Significant Deficiency

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

View Audit 40405

Finding 44951 (2022-001)

Material Weakness 2022

Scotts Bluff County Nebraska

NE

Internal Control / Segregation of Duties

The County has assessed the benefits and costs associated with proper segregation of duties for all County departments and offices and has determined that cost would outweigh any benefits received. The County understands the inherent risks associated with improper segregation of accounting functions...

The County has assessed the benefits and costs associated with proper segregation of duties for all County departments and offices and has determined that cost would outweigh any benefits received. The County understands the inherent risks associated with improper segregation of accounting functions. The County requires monthly reporting to the Board of Commissioners for various department officials to ensure transactions are recorded, and potential errors and irregularities are identified on a timely basis.

View Audit 44587

Finding 44896 (2022-001)

Significant Deficiency 2022

Housing Authority of the City of Raleigh

NC

HUD Housing Programs Eligibility Significant Deficiency

Fiscal Year Ending (?FYE?) 2022 Audit Response Corrective Action Plan Finding 2022-001 ?Housing Choice Voucher Program Tenant Files ?Eligibility-Internal Control over Tenant Files-Noncompliance and Significant Deficiency? RHA Response The Raleigh Housing Authority and Leased Housing Department ack...

Fiscal Year Ending (?FYE?) 2022 Audit Response Corrective Action Plan Finding 2022-001 ?Housing Choice Voucher Program Tenant Files ?Eligibility-Internal Control over Tenant Files-Noncompliance and Significant Deficiency? RHA Response The Raleigh Housing Authority and Leased Housing Department acknowledge and accept that there were a significant number (27 files of 120 reviewed) of past due annual recertifications during the FYE 2022 review period. The abundance of outstanding annual re-exams started mid-2020. During the height of the Coronavirus pandemic, we changed our process for in-person appointments for completing the Annual Re-exam paperwork to mailing the packets to the families. This caused us problems with obtaining the necessary documentation for processing the recertifications. Also, other agencies that provided the required income/household verifications were closed and families were unable to obtain the required information. The Leased Housing Department modified its procedures and accepted what was minimally allowable based on HUD?s guidance. The staff worked diligently with the families that had outstanding documents to avoid terminating the families which would have likely resulted in homelessness during a national pandemic. There was a moratorium in place that prevented evictions of tenants during that time also. The Leased Housing Department also had a number of vacant positions during this review period. The Client Manager worked a large portion of the previous review period FYE 2021 with two full-time staff person and 2 temporary employees during part of that time. In a department that normally worked with 4 full-time trained employees, this staff reduction and having to train temporary employees slowed the process down. The Leased Housing staff has put the following plan in place to catch up on our annual recertifications and to complete timely moving forward: ? Additional Staffing positions to hire and train o one (1) client specialist ? this team gathers all the required documents and confirms completed properly o two (2) account specialist ? this team calculates the annual recertification income and generates the 50058s transmitted to HUD ? Current staffing positions reassigned to assist including: o 2 Temporary employees o Compliance Officer o Contract Specialist o 2 File Review Specialist ? from Finance Compliance team o Client Manager ? Contract with an outside service provider to help with the volume - We have received quotes from both Nan McKay and Quadel and will look to procure within the next few weeks to help us move through the volume of past due files ? A new tracking system for Annual recertification has been implemented to ensure the number of Annual Re-exams that need to be processed weekly are meet to meet our monthly goals. ? The Client Manager and the Assistant Director of Leased Housing will meet weekly to discuss the progress and work together to meet the monthly lease-up goal. ? Voucher families will be scheduled to come-into the office to pick-up the annual recertification packet and speak to their assigned specialist if needed. ? Voucher families are notified 90-days prior to their annual recertification date and given a time and date to submit the requested documents. If requested documents are not received, the voucher family will receive a pre-term letter with a scheduled appointment to come into the office and meet with the assigned Client Specialist. They will only be given 7-business days to return requested documents after this meeting. If not received the family will be issued a letter of termination. Anticipated Completion: 12/31/22 Person Responsible: Liz Edgerton Respectfully, Liz Edgerton Interim Director

View Audit 46840

Finding 44889 (2022-005)

Significant Deficiency 2022

University of Miami

FL

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking § 200.303

2022-005 Reporting Management Views and Opinion UM management agrees that the PRF Period 1 reporting submission was subseq...

2022-005 Reporting Management Views and Opinion UM management agrees that the PRF Period 1 reporting submission was subsequently revised to remove $14,854,235 of Other Provider Relief Fund Expenses. The Other Provider Relief Fund Expenses removed from the Period 1 submission were allowable. However, given the dynamic reporting guidance and best practices circulated subsequent to the Period 1 reporting submission, it was determined by management to utilize lost revenues to support the PRF funding rather than expenses incurred. Corrective Action Plan UM management believes this to be an isolated incident due to the novel COVID-19 virus. While management will work to avoid the need for revised reporting submissions, management will continue to ensure the reports align with the latest guidance and best practices. Timeline for Action Plan UM management identified the need for a revised report and has already completed the revised submission. Responsible Individuals Charity Fannin, Chief Accounting Officer Craig McAllister, Assistant VP Risk Management

View Audit 46839

Finding 44885 (2022-001)

Significant Deficiency 2022

State Theatre Center for the Arts, Inc.

PA

Internal Control / Segregation of Duties

State Theatre Center for the Arts, Inc. respectively submits the following corrective action plan for the year ended May 31, 2022. Name and Address of Independent Public Accounting Firm: Campbell, Rappold & Yurasits LLP, 1033 S. Cedar Crest Blvd., Allentown, PA 18103 Audit Period: Year Ended May 3...

State Theatre Center for the Arts, Inc. respectively submits the following corrective action plan for the year ended May 31, 2022. Name and Address of Independent Public Accounting Firm: Campbell, Rappold & Yurasits LLP, 1033 S. Cedar Crest Blvd., Allentown, PA 18103 Audit Period: Year Ended May 31, 2022 Section II Findings ? Financial Statement Audit Significant Deficiencies 2022-001 Recommendation: Management and the Board of Directors should remain involved in the financial affairs of the Organization to provide additional oversight controls. Action Taken: Management agrees with the recommendation. Management and the Board of Directors will continue to be involved in the financial affairs of the Organization. The Organization does not believe it would be feasible or fiscally responsible to hire enough individuals to achieve proper segregation of duties.

View Audit 46832

Finding 44881 (2022-001)

Significant Deficiency 2022

Alight

MN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken ...

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.

View Audit 44660

Finding 44873 (2022-002)

Significant Deficiency 2022

West Virginia Perinatal Partnership, Inc.

WV

Reporting Internal Control / Segregation of Duties

2022-002 CONTROLS OVER GRANT REPORTING (93.788, 93.912, and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) The Executive Director is currently cc?d on all grant report filings when they are submitted to the granting agency. Starting in 2023, the Financial Director shares all grant reports wi...

2022-002 CONTROLS OVER GRANT REPORTING (93.788, 93.912, and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) The Executive Director is currently cc?d on all grant report filings when they are submitted to the granting agency. Starting in 2023, the Financial Director shares all grant reports with the Executive Director for review and approval prior to their submission.

View Audit 40204

Finding 44830 (2022-004)

Material Weakness 2022

Lee County

IA

Internal Control / Segregation of Duties

2022-004 Segregation of Duties over Federal Revenues Each official will review office procedures and attempt to maximize the best internal control. With limited staff, we will attempt to segregate duties as much as possible. We will consider using other officials as necessary. We will explore having...

2022-004 Segregation of Duties over Federal Revenues Each official will review office procedures and attempt to maximize the best internal control. With limited staff, we will attempt to segregate duties as much as possible. We will consider using other officials as necessary. We will explore having state reimbursements directly deposited at the County Treasurer. Cindy Renstrom Budget Director (319) 372-3705 June 30, 2023

View Audit 47922

Finding 44829 (2022-002)

Significant Deficiency 2022

Communidad Del Retiro (a Project of the Municipality of San Juan)

PR

HUD Housing Programs Eligibility Significant Deficiency

Finding Number: 2022-002 Title and Program Name: HUD Title 24 Part 982 - Section 8 Housing Choice Vouchers Program -CFDA No. 14.871 Category and Award No.: Internal Controls-Eligibility Form HUD-92006, Supplement to Application for Federally Assisted Housing. Section 8 - Award # RQ006 Management...

Finding Number: 2022-002 Title and Program Name: HUD Title 24 Part 982 - Section 8 Housing Choice Vouchers Program -CFDA No. 14.871 Category and Award No.: Internal Controls-Eligibility Form HUD-92006, Supplement to Application for Federally Assisted Housing. Section 8 - Award # RQ006 Management Response and/or Corrective Action: The Municipality of San Juan concurs with the finding. As part of the corrective action plan, the Housing Department incorporated the Form HUD-92006 into the system so that it could be included as part of the recertification documents kit. The forms can be filed on the participants case on paper and in a digital form.. Assigned Responsibility: Isamar Pina Rivera (787)480-5500 Director of Housing Department Status: June 30, 2023

View Audit 46034

Finding 44828 (2022-001)

Significant Deficiency 2022

Communidad Del Retiro (a Project of the Municipality of San Juan)

PR

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Finding Number: 2022-001 Title and Program Name: HUD Title 24 Part 982 - Section 8 Housing Choice Vouchers Program -CFDA No. 14.871 Category and Award No.: Internal Controls ? Special Test - Housing Quality Standards Inspection - Housing Quality Standards Enforcement. Section 8 - Award # RQ006 M...

Finding Number: 2022-001 Title and Program Name: HUD Title 24 Part 982 - Section 8 Housing Choice Vouchers Program -CFDA No. 14.871 Category and Award No.: Internal Controls ? Special Test - Housing Quality Standards Inspection - Housing Quality Standards Enforcement. Section 8 - Award # RQ006 Management Response and/or Corrective Action: The Municipality of San Juan concurs with the finding. As part of the corrective action plan, the Housing Department appointed an Area Supervisor in January 2023, to oversee the Compliance of Eligibility requirements. The department established as internal control procedures to monthly issue the inspections report to: - verify any backload case of recertifications to be able to reschedule on the recertification term period. -or cases suspended due to deficiencies (HQS) and enforce the repairs or give a new voucher to the affected families. Assigned Responsibility: Isamar Pina Rivera (787)480-5500 Director of Housing Department Status: June 30, 2023

View Audit 46034

Finding 44827 (2022-003)

Significant Deficiency 2022

Communidad Del Retiro (a Project of the Municipality of San Juan)

PR

HUD Housing Programs Eligibility Significant Deficiency

Finding Number: 2022-003 Title and Program Name: Section 8 Project Based Cluster-CFDA No. 14.856 Category and Award No.: Internal Controls-Eligibility - Notice of Re-certification sent within 90 to 120 days Awards No. RQ006MR0001, RQ006MR0003 & RQ006MR0004 Management Response and/or Corrective Ac...

Finding Number: 2022-003 Title and Program Name: Section 8 Project Based Cluster-CFDA No. 14.856 Category and Award No.: Internal Controls-Eligibility - Notice of Re-certification sent within 90 to 120 days Awards No. RQ006MR0001, RQ006MR0003 & RQ006MR0004 Management Response and/or Corrective Action: The Municipality of San Juan concurs with the finding. As part of the corrective action plan, the Housing Department reemphasized its technicians and staff in writing on the importance of filing copies of recertification letters once submitted and documenting in the case file any type of communication with the participant. Also, as part of the internal controls the Department will require quality control inspection on a weekly basis once the technicians perform their scheduled recertifications. Assigned Responsibility: Isamar Pina Rivera (787)480-5500 Director of Housing Department Status: June 30, 2023

View Audit 46034

Finding 44819 (2022-001)

Material Weakness 2022

Fulton Theatre Company

PA

Internal Control / Segregation of Duties Reporting

Management's Response The Theatre has received, reviewed and accepted all journal entries, prior period adjustments, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Management expects that it wi...

Management's Response The Theatre has received, reviewed and accepted all journal entries, prior period adjustments, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Management expects that it will continue to outsource the preparation of the annual financial statements to its audit firm as this is the most cost effective manner to produce this information.

View Audit 44233

Finding 44798 (2022-001)

Significant Deficiency 2022

McCook Public School District No 17

NE

Internal Control / Segregation of Duties

The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concer...

The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concern for the School District and the Board.

View Audit 40193

Finding 44783 (2022-027)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.303

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Ye...

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

View Audit 45093

Finding 44763 (2022-061)

Significant Deficiency 2022

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award N...

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021, AA36341LA0; 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 170; 2 CFR 200.303 The WIOA Cluster is subject to subaward reporting under the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires the department to submit information for any subaward action that equals or exceeds $30,000 in the FFATA Subaward Reporting System (FSRS). Reports should be submitted no later than the end of the month following the month in which the subawards were made. Federal regulations also require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Upon inquiry of the department, we determined it had not submitted any subaward information to the FSRS during fiscal year 2022. Department management stated FFATA reporting was not completed due to staff turnover. We also reviewed information the department had submitted at USAspending.gov and determined the department had not submitted any subaward information to FSRS since 2017. The agency is not in compliance with FFATA reporting requirements. Additionally, the department is not transparent in the spending decisions of these federal awards. We recommend department management implement controls to timely prepare and submit the monthly FFATA reports as required by federal regulations. The department should also work with the federal awarding agency to determine what actions it should take for older reports not submitted. MANAGEMENT RESPONSE: We agree with this recommendation. According to the findings, the HECC didn?t submit any subaward information to the FSRS during fiscal year 2022. Furthermore, the Department had not submitted any subaward information to FSRS since 2017. The HECC acknowledges these findings are correct. Due to these findings, HECC has implemented procedures to ensure timely entry into the FFATA Subaward Reporting System (FSRS) of all awards that equal or exceed $30,000. In addition, HECC has granted FSRS access to several high-level accountants to ensure that there is always staff on hand to make these entries. The procedures include a checkbox on the cover page of every agreement that delineates when a FSRS entry is required. Anticipated Completion Date: May 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

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Finding 44757 (2022-020)

Material Weakness 2022

State of Oregon

OR

Special Tests & Provisions Subrecipient Monitoring Material Weakness

2022-020 Oregon Housing and Community Services Controls are needed to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: ...

2022-020 Oregon Housing and Community Services Controls are needed to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 24 CFR 576.102(c) Federal regulations require that buildings renovated with ESG-CV funds for use as emergency homeless shelters must be maintained as shelters for not less than a period of 3 or 10 years, depending on the type of renovation and value of the building. Initial inquiries with program staff determined that the department was not aware whether its subrecipients were using program funds to renovate buildings for use as emergency homeless shelters. Subsequently, program staff indicated the information may be contained in subrecipient implementation reports. However, there were no known procedures or processes in place to monitor the use of funds during the fiscal period. Therefore, it is possible buildings renovated with program funds may not be maintained as emergency shelters for the minimum required time period. We recommend agency management develop internal controls to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required. MANAGEMENT RESPONSE: We agree with this recommendation. Program monitoring for all ESG recipients is on track to be completed for State FY23. Our program manuals state the restrictive use period requirements for any rehabilitation, renovation, conversion, or maintenance of real property. OHCS? program manuals clearly define and outline the requirements for approval of acquisition-renovation-rehabilitation, expectations regarding restrictive use periods based on project type, as well as a requirement for an annual certificate of continuing program compliance. The continuing program compliance requirement allows subrecipients to self-certify that a property is meeting the required restrictive use requirement and that all populations being served meet eligibility criteria of the program(s) funding the project. These requirements will be verified and reviewed as part of program monitoring. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

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