Corrective Action Plans

Finding 539024 (2024-003)

Material Weakness 2024

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed/Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425...

FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed/Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Context: During the testing of vendor and payroll disbursements charged to Education Stabilization Fund grant awards during the audit period, the following exceptions were noted:  Management was unable to provide an approved accounts payable voucher and supporting invoice for one vendor disbursement in a sample of 12 vendor disbursements.  For one salaried employee selected out of a sample of 40 payroll disbursements, the employee was charged to Education Stabilization Fund grants for 50% of their time worked in a pay period. The School Corporation did not maintain any time-and-effort logs to support the employee’s partial allocation to Education Stabilization Fund grants. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement control processes surrounding expenditures of federal funds to ensure documents are retained to support expenditures and their allocations to federal grants. Responsible Party and Timeline for Completion: Gretchen Berger, Corp Treasurer - 6-1-2025

View Audit 349745 Questioned Costs: $1

Finding 539012 (2024-003)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Update policies and procedures ensuring performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Explanation of disagreement with audit finding: There is...

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Update policies and procedures ensuring performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will create internal control policies and procedures to ensure performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood and Joe Ciccarello Planned completion date for corrective action plan: June 30, 2025

View Audit 349740

Finding 539007 (2024-002)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with ...

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

View Audit 349740

Finding 539002 (2024-001)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Questioned Costs Subrecipient Monitoring Reporting § 200.308 § 200.309 § 200.403

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit f...

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

View Audit 349740 Questioned Costs: $1

Finding 539001 (2024-001)

Significant Deficiency 2024

School District of Philadelphia

PA

Matching / Level of Effort / Earmarking

Assistance Listing 84.334 Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Contact Person – Dr. Aja Holden, Ed. D., Office of Postsecondary Readiness The School District of Philadelphia, 215-400-5145 Views of Responsible Officials and Corrective Action Plan: The responsi...

Assistance Listing 84.334 Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Contact Person – Dr. Aja Holden, Ed. D., Office of Postsecondary Readiness The School District of Philadelphia, 215-400-5145 Views of Responsible Officials and Corrective Action Plan: The responsible School District of Philadelphia (SDP) officials agree with the deficiencies identified regarding matching contributions, level of effort, and earmarking for the GEAR UP program. To address this finding, the following corrective actions will be implemented expeditiously to ensure the matching requirements are met by the end of the grant period in 2027: ● Training for Program Staff: Targeted training will be provided for the program staff to ensure a full understanding of the GEAR UP matching requirements, including the necessity for accurate recordkeeping and compliance with the level of effort and earmarking rules. ● Review and Strengthen Documentation Procedures: Complete a comprehensive review of all records and documentation related to matching contributions (including Years 1-3 to recoup unclaimed internal matches that may have been overlooked), and level of effort. A team (including both the School District’s GEAR UP Program Office and Grants Compliance Office) will oversee the collection and verification of all supporting documentation moving forward. This will include a detailed tracking system for in-kind and cash contributions. Lastly, the comprehensive plan will add school-level match requirements for each high school to identify other matching contributions at the school level. ● Monitoring and Oversight: Implement a quarterly leadership review process to ensure that all matching and level of effort requirements are being met and documented in accordance with program guidelines. Any concerns will be immediately addressed and corrected. ● Timeline: These corrective actions will be fully implemented by September 2025, with ongoing monitoring by the GEAR UP Program Office to ensure sustained compliance. We are confident that these actions will remedy the deficiencies that were identified and prevent future occurrences.

View Audit 349725

Finding 538994 (2024-003)

Significant Deficiency 2024

Holyoke Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification pro...

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification process, department managers hiring FWS students will submit both the student's work schedule and class schedule to the Financial Aid Office. A report has been developed to compare FWS student work hours with their class schedules during each pay period. Any instances of students working during scheduled class time will be communicated to both the student and their supervisor for correction, if the hours were reported in error. If the hours are accurate, the department must provide documentation of a class schedule change, cancellation, or the fund and organization codes to be charged, crediting the FWS funds accordingly. Timeline for Implementation of Corrective Action Plan: This policy will be implemented immediately and applied retroactively to July 1, 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

View Audit 349701

Finding 538991 (2024-001)

Significant Deficiency 2024

Holyoke Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report...

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report all graduates. Upon review of the data transmission process, it has been determined that students enrolled in simultaneous degree programs require specific evaluation of their graduate status due to the NSC's unique parameters for these programs. Consequently, manual updates to NSLDS will be necessary for cases that fall outside the NSC's automated reporting guidelines. To address this systematically, a working group will be established to review and revise campus policies and procedures. This group will collaborate with the IT Enterprise Operations team to develop refined reporting mechanisms that accurately identify and address students in simultaneous degree programs, ensuring timely and accurate NSLDS reporting. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Allison Wrobel, Registrar Curt Foster, Comptroller

View Audit 349701

Finding 538990 (2024-003)

Significant Deficiency 2024

Berkshire Community College

MA

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

Corrective Action Plan:. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Additional reports at the end of each semester have been created to assist with identifying st...

Corrective Action Plan:. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Additional reports at the end of each semester have been created to assist with identifying students who fail to complete at least half-time attendance. Policy and procedures have been updated to insure proper Exit Counseling notifications. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie M. Trautman

View Audit 349691

Finding 538978 (2024-003)

Significant Deficiency 2024

Morehouse School of Medicine, Inc., Subsidiary and Affiliate

GA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.430

Finding 2024-003 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting ...

Finding 2024-003 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025. Anticipated Completion Date: June 30, 2025

View Audit 349645

Finding 538975 (2024-001)

Significant Deficiency 2024

Morehouse School of Medicine, Inc., Subsidiary and Affiliate

GA

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

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also imple...

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025. Anticipated Completion Date: March 31, 2025

View Audit 349645

Finding 538974 (2024-002)

Material Weakness 2024

Peru Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

The School Corporation will implement a formal process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations. The Treasurer and the Deputy Treasurer will be responsible for overseeing the implementation of the correction...

The School Corporation will implement a formal process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations. The Treasurer and the Deputy Treasurer will be responsible for overseeing the implementation of the correction action plan which will go into effect immediately.

View Audit 349644

Finding 538970 (2024-003)

Material Weakness 2024

Peru Community Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

The School Corporation will establish an internal control process to esnure detailed records are maintained and an audit trail is evident to comply with federal compliance requirements. The Treasuer and the Deputy Treasurer will oversee the implementation of the corrective action plan, which will go...

The School Corporation will establish an internal control process to esnure detailed records are maintained and an audit trail is evident to comply with federal compliance requirements. The Treasuer and the Deputy Treasurer will oversee the implementation of the corrective action plan, which will go into effect immediately.

View Audit 349644 Questioned Costs: $1

Finding 538862 (2024-001)

Material Weakness 2024

North Judson -- San Pierre School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future projects, NJ-SP will make sure documentation for both wage requirements and weekly certif...

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future projects, NJ-SP will make sure documentation for both wage requirements and weekly certified payroll reports are obtained from the contractor. An internal control system will be put into place that ensures the Business Manager receives proper documentation or payments will not be issued for work performed in order to stay in compliance. Anticipated Completion Date: March 31, 2025

View Audit 349621

Finding 538861 (2024-003)

Material Weakness 2024

North Judson -- San Pierre School Corporation

IN

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

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both revi...

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both reviewed and signed off on before submitting. The procedure will be that the Business Manager prepares the report and then reviews the report with the Superintendent. Once the Superintendent approves of the report he or she will sign of on the report and the report can be submitted. Documentation will be recorded to ensure the School Corporation stays in compliance with the requirements related to grant agreements and reporting requirements. Anticipated Completion Date: June 30, 2025

View Audit 349621

Finding 538857 (2024-001)

Significant Deficiency 2024

Erikson Institute

IL

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

Finding 2024-001: Return of Title IV Funds For one out of three students tested (33%) who withdrew from the Institute, the Institute could not provide evidence that Institute reviewed the return of Title IV funds calculation. Further, the calculation that was originally performed failed to identify ...

Finding 2024-001: Return of Title IV Funds For one out of three students tested (33%) who withdrew from the Institute, the Institute could not provide evidence that Institute reviewed the return of Title IV funds calculation. Further, the calculation that was originally performed failed to identify $480 of aid to be disbursed as post-withdrawal. Corrective Action Plan The Director of Financial Aid, Registrar and Student Affairs have instituted a communications protocol for all student withdrawals that include the notification of all required institutional constituents. In addition, as a control practice the Director of Financial Aid reviews a daily enrollment change report to ensure all withdrawals are processed on a timely basis. Contact Person Monique Foster Director of Financial Aid mfoster@erikson.edu Anticipated Completion Date October 2024

View Audit 349584 Questioned Costs: $1

Finding 538849 (2024-001)

Material Weakness 2024

Seiling Independent School District #8

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

In the future Seiling Public Schools will ensure all construction projects funded by federal awards comply with the Davis-Bacon Act requirements. Action Steps: * Develop internal processes to ensure federal wage rates and fringe benefits are met on construction projects. * Ensure all construction...

In the future Seiling Public Schools will ensure all construction projects funded by federal awards comply with the Davis-Bacon Act requirements. Action Steps: * Develop internal processes to ensure federal wage rates and fringe benefits are met on construction projects. * Ensure all construction contracts funded by federal awards include the required Davis-Bacon wage clauses. * Collect and review weekly certified payroll reports from contractors to confirm wages are correct. * Ensure that all necessary wage information is visibly posted at construction sites. * Train contractors and District staff on the Davis-Bacon Act requirements. * Perform audits to verify compliance and indentify any issues early.

View Audit 349571

Finding 538846 (2024-003)

Significant Deficiency 2024

County of Loudoun, Virginia

VA

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding: 2024-003: Significant Deficiency in Internal Control Over Compliance and Non- Material Noncompliance Responsible Person: Brian Reagan, Assistant Director, Department of Housing and Community Development Estimated Completion: April 30, 2025 Corrected Action: 1. The County will develop a solu...

Finding: 2024-003: Significant Deficiency in Internal Control Over Compliance and Non- Material Noncompliance Responsible Person: Brian Reagan, Assistant Director, Department of Housing and Community Development Estimated Completion: April 30, 2025 Corrected Action: 1. The County will develop a solution with the software company that supports the Department of Housing and Community Development’s (DHCD) current client management to provide standardized reports that can be used by managers to monitor properties that have upcoming inspection due dates. The County will address current limitations within the software that does not allow for a fully automated workflow, which then necessitates a highly manual process and more likelihood of human error. 2. Staff will continue to utilize the monthly Section Eight Management Assessment Program (SEMAP) Indicators Report in HUD’s Public and Indian Housing Information Center (PIC) database and provide that information to the inspectors monthly so that all inspections will be planned in advance of the due date. 3. The HCV Program is currently in the process of transitioning the client management software to a new software provider and staff is diligently working to ensure that notifications and reports are available for the tracking of initial, biennial, and special inspection due dates. 4. DHCD currently employs only one full-time Inspector to conduct all initial, biennial, and special inspections for the HCV Program. The number of initial inspections increased by 180% during 2023 and 2024. As part of the Fiscal Year 2026 budget process, DHCD requested an additional full-time Inspector position that will conduct HCV inspections as well as inspections for other DHCD programs, which will further ensure that all inspections are completed in a timely manner and subject to quality control, especially during periods of program growth. 5. Additionally, the Inspector and HCV Program Manager will attend Inspection training, to enhance their knowledge of inspection requirements and compliance.

View Audit 349563

Finding 538845 (2024-002)

Material Weakness 2024

County of Loudoun, Virginia

VA

Eligibility Material Weakness Matching / Level of Effort / Earmarking

Finding 2024-002: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Responsible Person: Chris Slagle, Program Manager; Allison Gregg, Program Manager Estimated Completion: January 31, 2026. Corrected Action: 1. The Department will conduct a thorough assessment of c...

Finding 2024-002: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Responsible Person: Chris Slagle, Program Manager; Allison Gregg, Program Manager Estimated Completion: January 31, 2026. Corrected Action: 1. The Department will conduct a thorough assessment of current redetermination reports and state policies to identify approaching deadlines and overdue items and create a structured monitoring system for supervisory staff. Standardized verification checklists will be introduced to confirm that all necessary documentation is collected, and incoming materials will be reviewed promptly to improve decision-making accuracy. The agency will collaborate with technical teams to correct the VaCMS programming error so that auto-renewals cannot occur without verification of crucial information such as social security numbers. 2. The Department will strengthen its workforce by enhancing training for new and existing employees. Requests will be submitted to the Board of Supervisors to support hiring additional staff, thereby mitigating the burden on each employee by reducing the caseload of 1,000 cases per worker to a more manageable caseload, allowing staff to process cases more efficiently. Training sessions will emphasize state and federal standards for timeliness, along with best practices for case documentation and adherence to the updated Medicaid Unwinding and Public Health Emergency guidelines. Regular professional development opportunities will be offered to ensure that all staff members remain informed about policy changes and evolving procedures. 3. The Public Benefits Unit Program leadership will conduct quarterly reviews to measure compliance with redetermination deadlines and track indicators such as workload volume, pending actions, and overdue items. Quarterly reviews will be documented and submitted to Department leadership. These reviews will highlight redetermination outcomes, caseload trends, and staffing considerations. 4. The Department will onboard the Public Benefits Program Administrator, who will be tasked with overseeing compliance across all Benefit Programs. The agency will implement a Corrective Action Plan aimed at ensuring timely and accurate completion of Medicaid redeterminations.

View Audit 349563

Finding 538840 (2024-003)

Material Weakness 2024

Knox Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Information on the federal program: Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Yea...

Information on the federal program: Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements 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): S425D210013, S425U210013 PassThrough Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Condition and Context: 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 Special Tests and Provisions - Wage Rate Requirements compliance requirements. The School Corporation had five construction and improvement projects which were funded with ESSER II (84.425D) and ESSER Ill (84.425U) grant awards. For 1 of 2 contracts selected for testing, the School Corporation did not include the Davis-Bacon wage rate requirements in the vendor contract. For this same vendor contract for floor replacement in a junior/senior high school, the School Corporation did not obtain the weekly payroll report certification from the construction vendor to monitor compliance with Davis-Bacon wage rate requirements. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements for this project. The total project cost disbursed for the flooring project during the audit period was $342,822 which included materials and labor. Total contract expenditures subject to Davis-Bacon wage rate requirements, including material and labor, during the audit period were $1,386,275. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: North Knox School Corporation will comply with the Davis-Bacon wage rate requirements in all future projects using federal funds. Responsible Party for Corrective Action: Darrel Bobe, Superintendent, and Terri Roesler, Treasurer, will oversee the corrective action plan. Timeline for Completion: Immediately.

View Audit 349540

Finding 538836 (2024-004)

Material Weakness 2024

Knox Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying ...

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Material Noncompliance, Qualified Opinion Condition and Context: 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 eligibility compliance requirement. During the testing of internal controls over eligibility determinations via the application process and related compliance, we noted the School Corporation was not able to provide the application or any documentation to support the eligibility status for 6 out of the 8 applicant students selected for tested for the 2022-2023 school year. There were no issues identified for students selected for testing whose eligibility was directly certified. Additionally, for the 2023-2024 school year, for 2 out of 30 students selected for the testing, the income eligibility determinations were not properly implemented. One student was determined to be eligible for "Free" meals per their free/reduced application but, the School Corporation incorrectly entered the eligibility as "Reduced" within the food service software. Another student was eligible for "Reduced" benefits per the direct certified download file but was entered into the food service software as eligible for "Free" benefits. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, the corporation will take more time in reviewing free and reduced applications to ensure student free or reduced status is listed correctly and supporting documentation is maintained. Applications are now completed online limiting paper copies. A review of applications by another member of the corporation staff will also be conducted. Responsible Party for Corrective Action: Terri Roesler, Treasurer, will oversee the implementation of the corrective action plan. Timeline for Completion: Immediately.

View Audit 349540

Finding 538829 (2024-004)

Material Weakness 2024

Workforce Development Board Work4wv Region 1, Inc.

WV

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2024-004 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ...

2024-004 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board will be moving forward by using consistent effective and cut-off dates for each allocation period. Between the time the allocation period ended and was compared to the time sheets, there were periods the previous month allocations were put in effect anywhere between the 5th and the 15th of the month. This change in procedure will benefit the Board by giving the allocation process a due date for review and approval. By changing the effective and cut-off date this will give the allocations the same period of time every month. This new process will give the Board more consistency. Each grant expenditure is reconciled to the cash request every month. All expenditures with the exception of payroll are actual monthly expenditures. Before they are put on the cash request, the Board will have approval (by both the Executive Director and Fiscal Manager) as allowed cost for either the purchase order or invoice on hand. Payroll is estimated up to 4 weeks ahead including transitional jobs. (We are paid bi-weekly). The following cash request that covers the actual payroll will have the difference between the actual and estimated on the cash request.

View Audit 349534

Finding 538828 (2024-003)

Material Weakness 2024

Workforce Development Board Work4wv Region 1, Inc.

WV

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

2024-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: As of today, all the reportin...

2024-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: As of today, all the reporting to the State is in a timely manner. At present, the Board is working on obtaining approval every MACC report internally with either the Executive Director or the Fiscal Coordinator’s initials on a special form created that reflects they reviewed all the documents as backup for the monthly MACC report. In addition, the Board will be submitting all the backup for the reports to an email address set up by Workforce WV so they will receive all the information on the MACC report. The Board is taking further action to train the Fiscal Coordinator on how to prepare this report. This action is taken for them to help review the reports and take over if necessary. This is so repeat of the previous situation, if it happens, it will not interrupt the Board’s flow of reporting.

View Audit 349534

Finding 538827 (2024-002)

Material Weakness 2024

Workforce Development Board Work4wv Region 1, Inc.

WV

Matching / Level of Effort / Earmarking § 200.303

2024-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board wil...

2024-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will be practicing earmarking in several ways. When preparing the MACC report, several indicators are noted before filing the report. For the Youth funding stream, the earmark of the YI/YO of 25% to 75% are checked during the preparation of the Youth Report. Also, Youth Activity has to be 20% of the total Youth Grant (Programs only). If these guidelines are not met, the Board will review these issues with the Youth contractor and find ways to reach these earmarks. Concerning the Adult and DW, the Transitional Jobs cannot be more than 10% of the combined Adult and DW combined funding stream for the Fiscal Year. And the same for IWTs, the number reported for them cannot be more than 20% of the Adult and DW combined funding stream for the Fiscal Year. Also, as part of the reporting process, actual to budget report is included for each funding stream. This earmarks the administrative costs are 10% or less than the total funding amount and determines where our budget is during the Fiscal Year. The above information will be reviewed every month. If this or other earmarking are not being obtained, the Board will consult with Workforce WV with what changes or additions are recommended for transparency.

View Audit 349534

Finding 538823 (2024-004)

Material Weakness 2024

Wes-Del Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2024-004 (Auditor Assigned Reference Number) Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: As a part of the assessment security, any individual who administers, handles, or has access to secure te...

FINDING 2024-004 (Auditor Assigned Reference Number) Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: As a part of the assessment security, any individual who administers, handles, or has access to secure test materials at the school or school corporation shall complete assessment training and sign a testing security and integrity statement that remains on file in the appropriate building-level office each year. Everyone who is required to sign the testing integrity agreement shall sign the form by an established date. The School Corporation had a process to provide assessment system security training and to ensure each employee that attended training signed the agreement indicating training was received. However, documentation was not retained for audit that would provide evidence that training occurred during the 2022-2023 school year. Documentation was provided for audit for the 2023-2024 school year. Contact Person Responsible for Corrective Action: Jason Slopsema Contact Phone Number and Email Address: 765-358-8729/jslopsema@wes-del.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Moving forward, the Corporation Test Coordinator, who is the individual responsible for providing this training, and ensuring that staff members complete it, and sign the testing security and integrity statement, will keep these signed documents on file within his/her office for at least 5 years. The Corporation Test Coordinator will continue to ensure that the training and signing of said document will take place by the deadline set forth by the Indiana Department of Education. Anticipated Completion Date: This will be completed beginning with the 2024-2025 school year’s signed testing and integrity agreements that have already been completed.

View Audit 349526

Finding 538812 (2024-004)

Material Weakness 2024

Franklin County Community School Corporation

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

FINDING 2024-004 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-...

FINDING 2024-004 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Other Matters 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 cash management compliance requirement. Context: In a sample of 5 monthly claims for reimbursement selected for testing, the following compliance exceptions were noted: • Management failed to submit the April 2023 claim for reimbursement in a timely manner (within 90 days) to the IDOE and was not reimbursed for meals served as a result. • For the other 5 claims tested, the number of meals claimed did not agree to the supporting meal system reports. There was a gross overstatement of meals claimed of $21,189 and a gross understatement of meals claimed of $538.35 resulting in a net over-reimbursement of $20,650.47. We noted that the School Corporation has a secondary review control in place designed to review claims prior to submission to the IDOE. However, the control was not operating effectively to detect and prevent errors in the amount claimed for reimbursement. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management has revised and implemented a more thorough control process over the preparation and submission of the monthly claims for reimbursement. A reconciliation sheet has been created and implemented for verification and will be completed every month. Responsible Party and Timeline for Completion: Jessica Defossett and Kendra Franks, January 2025

View Audit 349523 Questioned Costs: $1

Corrective Action Plans

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