Corrective Action Plans

Finding 518143 (2023-013)

Material Weakness 2023

Mental Health Association of Columbia-Greene Counties Inc.

NY

On the 15th of each month the Residential Division Director will meet with the Director of Finance to review the prior months match and year to date match and sign off on the report. This will assist in ensuring all match (cash/inkind) are accounted for accurately and that MHACG meets the required ...

On the 15th of each month the Residential Division Director will meet with the Director of Finance to review the prior months match and year to date match and sign off on the report. This will assist in ensuring all match (cash/inkind) are accounted for accurately and that MHACG meets the required 25% match.

View Audit 336457

Finding 518136 (2023-004)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

Special Tests & Provisions Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2023-004: Annual Security Report and Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit, and states that the College had failed to provide clear evidence that it had gathered the correct data fr...

Finding 2023-004: Annual Security Report and Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit, and states that the College had failed to provide clear evidence that it had gathered the correct data from the local authorities, however, the College had not confirmed that the document was readily available to all students and prospective students upon the completion of the Annual Security Report on October 3, 2024. Actions Taken or Planned: The College has published the 2024 Annual Security Report on the web page as identified here. Disclosures – Dragon Rises College of Oriental Medicine The 2022 statistics for the Gainesville FL location have been provided to all students, and the College will be completing the required updates for the 2023 statistics and incorporating the findings into an updated Annual Security Report for publications in April of 2025. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 518135 (2023-003)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2023-003: Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College has complied with the requirement. Actions Taken or Planned: Dragon Rises Colleg...

Finding 2023-003: Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College has complied with the requirement. Actions Taken or Planned: Dragon Rises College of Oriental Medicine has completed the requirements and published the Information Security Program Compliance with Gramm-Leach-Bliley Act (GLBA). The College is committed to the preservation and security of personal data and is dedicated to adhering to regulations pertaining to the safeguarding of personal, sensitive, and other protected data within its purview. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 518134 (2023-002)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2023-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated at two separate locations with...

Finding 2023-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated at two separate locations within Florida. The College incurred additional losses in tuition revenue and services revenue as it restructured how to operate both locations appropriately during 2023. The College had additional interest expense in 2023 during the restructuring of the administration and the facilities of the College. Actions Taken or Planned: The College acted in 2024 to reduce the academic footprint to the facility it owned in Bradenton FL, while reporting the Gainesville FL location as no longer offering instruction, but maintaining a clinical facility to allow students to complete the requirements of their academic program. The College also removed and replaced the Executive Director and other members of administration that contributed to the financial issues faced by the College. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 517955 (2023-012)

Material Weakness 2023

Unified Government of Wyandotte County and Kansas City, Kansas

KS

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083 Management’s Response: During 2024, management worked with the Fire Department and Payroll to ensure only straight time was coded to this grant and no overtime was charged to this grant. This was a...

U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083 Management’s Response: During 2024, management worked with the Fire Department and Payroll to ensure only straight time was coded to this grant and no overtime was charged to this grant. This was a finding in 2022 but we were not aware until the audit was completed in 2024 there was an issue the existing payroll system was not flagging. This has been corrected in in 2024 and should not be a recurring issue. Views of Responsible Officials and Corrective Action: The reason for recurrence is the finding was communicated late in the prior year. Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

View Audit 336226

Finding 517953 (2023-010)

Significant Deficiency 2023

Unified Government of Wyandotte County and Kansas City, Kansas

KS

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

U.S Department of Treasury COVID 19 – Coronavirus State and Local Fisal Recovery Funds – 21.027 Management’s Response: There was a change in the position of CFO and the Unified Government did not have access to the US Treasury system for a period of time to upload the report. The UG finance team wor...

U.S Department of Treasury COVID 19 – Coronavirus State and Local Fisal Recovery Funds – 21.027 Management’s Response: There was a change in the position of CFO and the Unified Government did not have access to the US Treasury system for a period of time to upload the report. The UG finance team worked with our outside contractor to gain access; and upon getting access to the system, immediately uploaded the form. This was caused by turnover in staff and is not reoccurring. Views of Responsible Officials and Corrective Action: The reason for recurrence is the finding was communicated late in the prior year. In concert with our ARPA consultant, we were able to combine the City & County on the portal and report timely quarterly since this initial issue in the reporting portal will ensure this is addressed by December 31, 2025. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

View Audit 336226

Finding 517950 (2023-008)

Material Weakness 2023

Unified Government of Wyandotte County and Kansas City, Kansas

KS

Questioned Costs Matching / Level of Effort / Earmarking § 200.303

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster – ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 – Special Programs for the Aging_Title III, Part C_Nutrition...

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster – ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 – Special Programs for the Aging_Title III, Part C_Nutrition Services – 2301KSOAHD Management’s Response: The department of aging is reviewing its current process to track spending and earmarking. A new system for compliance monitoring is planned for early 2025. Views of Responsible Officials and Corrective Action: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Management will put controls and processes in place to ensure earmarking is being monitored for compliance. Management will ensure this is addressed by December 31, 2025. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

View Audit 336226 Questioned Costs: $1

Finding 517902 (2023-005)

Significant Deficiency 2023

Hips

DC

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials: This deficiency was noted internally even before the auditors flagged it in April 2024. Effective April 2024 the allocation of salaries and wages to different grants was transferred back to the Finance Manager who has more information regarding the grants timing, empl...

Views of Responsible Officials: This deficiency was noted internally even before the auditors flagged it in April 2024. Effective April 2024 the allocation of salaries and wages to different grants was transferred back to the Finance Manager who has more information regarding the grants timing, employees involved, % of time spent et al. In addition, the salaries and wages allocation is now a prerequisite for the invoicing process every month. HIPS have already seen significant improvements in both accuracy in seeking salaries and wages reimbursement as well as in wages reconciliations against paychex reports. COLA adjustments will be recorded more accurately and approval documented. As of 2024, HIPS has also updated our HR policy to provide written documentation by the Operations Manager of COLA increases to each staff member when they are implemented.

View Audit 336157

Finding 517887 (2023-003)

Material Weakness 2023

Tuscarawas County

OH

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Every quarter, Income Maintenance and Social Services will each get a minimum of 354 RMS hits. Each participant will get an e-mail 2-5 minutes before the time of the RMS hit. The participant will have only 48 hours to complete the RMS hit before it expires. After 12 hours of no response, the par...

Every quarter, Income Maintenance and Social Services will each get a minimum of 354 RMS hits. Each participant will get an e-mail 2-5 minutes before the time of the RMS hit. The participant will have only 48 hours to complete the RMS hit before it expires. After 12 hours of no response, the participant and the observer (their supervisor) will get a reminder e-mail. After 36 hours of no response, the participant, the observer, and the RMS Coordinator (business office) will get a reminder e-mail. Once the participant gets the e-mail, the participant will open the e-mail, click the link, log into the system, and fill out the RMS hit as accurately as possible. The RMS hit will have a comment box; this is where the participant will put what they were doing and the case number if applicable. Any other documentation needed to support the hit should be kept in a folder or scanned and kept on the computer. It is also good practice to note in running record that the participant received an RMS hit at that specific time. Once the RMS hit is complete, it is sent either to the Observer or the RMS Coordinator for approval. If the RMS hit is a Control Member, the RMS will be sent to the Observer for their approval. If it is accurate, the Observer will approve the RMS hit and it will be sent to the RMS Coordinator for approval. If the RMS hit is not a control member, the Observer step will be skipped. If the participant is not available at the time of the RMS hit because that person is in the field, the coordinator may contact the supervisor to find out what the participant is doing. The RMS Coordinator may then fill out the RMS hit and document that he/she has talked to the supervisor and confirmed the activity the participant was doing. Once the RMS hit has been submitted to the RMS Coordinator, the hit can be approved or invalidated. The RMS Coordinator has 72 hours of the observation time to complete this step. The Fiscal Supervisor and the Coordinator will meet, as needed, to go over these hits and check for accuracy.

View Audit 336127

Finding 517886 (2023-002)

Material Weakness 2023

Tuscarawas County

OH

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking

TCJFS will evaluate draws every week when a draw is available to do. Draws can be done anytime during the week but must be completed by Friday at 2:00pm. TCJFS will pull in vouchers to the CFIS system from the ledger system that TCJFS anticipates being paid by the Auditor’s Office. TCJFS will th...

TCJFS will evaluate draws every week when a draw is available to do. Draws can be done anytime during the week but must be completed by Friday at 2:00pm. TCJFS will pull in vouchers to the CFIS system from the ledger system that TCJFS anticipates being paid by the Auditor’s Office. TCJFS will then run a cost allocation with the most current RMS numbers and then use the Over/Under Report to determine the draw amount. Draws should be taken from those allocations where expenses have hit or from an allocation where we are under-drawn. TCJFS should never have more than 10 days cash on hand at the end of a quarter.

View Audit 336127

Finding 517882 (2023-003)

Significant Deficiency 2023

Gay City Health Project

WA

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

Finding 2023‐003 Significant deficiency in internal control over compliance with the level of effort requirements applicable to the major program. Corrective Action Plan: We will implement internal control processes to identify and then track any level of effort metrics, and deliverables, noted in o...

Finding 2023‐003 Significant deficiency in internal control over compliance with the level of effort requirements applicable to the major program. Corrective Action Plan: We will implement internal control processes to identify and then track any level of effort metrics, and deliverables, noted in our federal awards. Anticipated Completion Date: December 31, 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Elle Brooks, Health Services Director and Francis Slaughter, Data Scientist

View Audit 336089

Finding 517594 (2023-002)

None 2023

Miracle Square, Inc. Dba Miracle Square 054-Hd111-Wpd

SC

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking § 200.512

MIRACLE SQUARE, INC. Sumter, South Carolina CORRECTIVE ACTION PLAN October 29, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Miracle Square, Inc. respectfully submits t...

MIRACLE SQUARE, INC. Sumter, South Carolina CORRECTIVE ACTION PLAN October 29, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Miracle Square, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended December 31, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended December 31, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.

View Audit 335617

Finding 517509 (2023-001)

None 2023

St Lukes Senior Housing, INC

CT

HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan September 27, 2024 U.S. Department of Housing & Urban Development 20 Church Street, 10th floor Hartford, CT 06103 St Luke's Senior Housing Inc. respectfully submits the following corrective action plan for St Luke's Senior Housing (Project #Ol 7-EE086) year ended December 31, ...

Corrective Action Plan September 27, 2024 U.S. Department of Housing & Urban Development 20 Church Street, 10th floor Hartford, CT 06103 St Luke's Senior Housing Inc. respectfully submits the following corrective action plan for St Luke's Senior Housing (Project #Ol 7-EE086) year ended December 31, 2023, which was audited by: Bailey, Moore, Glazer, Schaefer & Proto LLP 16 Lunar Drive Woodbridge, CT 06525 The findings from the 12/31/2023 schedule of findings and questions costs are discussed below and numbered consistently with the numbers assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AW ARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Finding number 2023-001: 14.157 Supportive Housing for the Elderly Condition: The Project failed to make the December deposit to the replacement reserve and did not catch up the deposits when the December voucher was deposited in early January. Recommendation: Care should be taken to catchup any missing deposits and return approved loans when the missing vouchers are eventually deposited. Action Taken: The Project made the required deposit to get current. Also, the project will make the required reserve deposit as part of its monthly review of financials to ensure this account is adequately funded.

View Audit 335512

Finding 517395 (2023-005)

Material Weakness 2023

Tennessee Pharmacists Research and Education Foundation

TN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Management's Response: We concur. View of Responsible Officials and Conective Action: The CEO has reviewed the timesheet policy with all staff attributed to grant work. These timesheets are reviewed by CEO. TPREF will review the findings with the State and identify mechanisms to properly capture sta...

Management's Response: We concur. View of Responsible Officials and Conective Action: The CEO has reviewed the timesheet policy with all staff attributed to grant work. These timesheets are reviewed by CEO. TPREF will review the findings with the State and identify mechanisms to properly capture staff time allocations. Anticipated Completion Date: Effective January 1, 2024, all current and new staff have been retrained on the process for submitting their monthly time sheets. TPREF will follow-up with the State by December 31, 2024.

View Audit 335362 Questioned Costs: $1

Finding 517394 (2023-004)

Material Weakness 2023

Tennessee Pharmacists Research and Education Foundation

TN

Cash Management Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Management's Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the finance team have implemented a process to submit reimbursement for prior month's work by conclusion of the following month. The CEO has implemented a process to aggressively follow-up with the sta...

Management's Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the finance team have implemented a process to submit reimbursement for prior month's work by conclusion of the following month. The CEO has implemented a process to aggressively follow-up with the state accounting team to ensure the state is holding true to a proper timeline of reimbursement. The CEO utilizes this follow-up messaging to the state to ensure all proper documentation has been assessed properly at each stage of the state's review process. Anticipated Completion Date: TPREF has implemented this new process as of January 1, 2024.

View Audit 335362

Finding 517393 (2023-003)

Material Weakness 2023

Tennessee Pharmacists Research and Education Foundation

TN

Questioned Costs Allowable Costs / Cost Principles Cash Management

Management's Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the Project Manager have created a tracking document to closely monitor the utilization of marketing services completed and accounted for within the requested reimbursement. The CEO will review the ass...

Management's Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the Project Manager have created a tracking document to closely monitor the utilization of marketing services completed and accounted for within the requested reimbursement. The CEO will review the assessment tracker to account for only those marketing services completed in 2023-year end financials. Anticipated Completion Date: The tracking documentation has been deployed at the start of services with subcontractor. With new accounting software completely implemented in 2024, the correction to this accounting of services has been corrected by June 30, 2024.

View Audit 335362 Questioned Costs: $1

Finding 517199 (2023-003)

Significant Deficiency 2023

Springfield Housing Authority

MA

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking § 200.512

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2023-003 (a...

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2023-003 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.

View Audit 335173

Finding 517143 (2023-003)

Significant Deficiency 2023

Big Sky Economic Development Corporation

MT

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC failed to comply with Davis-Bacon wage requirements for a loan disbursed to one entity due to a lack of awareness of Davis-Bacon wage requirements. Davis-Bacon wages are a requirement of the Federal EDA and apply to a...

Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC failed to comply with Davis-Bacon wage requirements for a loan disbursed to one entity due to a lack of awareness of Davis-Bacon wage requirements. Davis-Bacon wages are a requirement of the Federal EDA and apply to any Federal funds to ensure the prevailing wage is paid to workers on federally funded construction-related projects. The regulations apply to any loans that are used to fund directly or indirectly projects that cost over $2,000 involving construction and/or renovation. BSEDC received a grant from the U.S. Federal EDA in April 2021. BSEDC drafted an EDA-RLF Plan that was approved by the Federal EDA and BSEDC’s Board of Directors. Within the plan was a section on Environmental Issues and Davis Bacon. Within this section of the Plan, there was discussion and direction pertaining to Environmental Issues, but nothing pertaining to Davis-Bacon. Therefore, BSEDC’s Director of Business Finance/Program Finance Director was unaware of the specific requirements related to Davis-Bacon wages and construction/renovation projects funded by the EDA-RLF loans. Not having had any experience with this, it was thought Davis-Bacon requirements only applied to financing of public projects, and not to any project funded by Federal funds. The Director of Business Finance/Program Finance Director and BSEDC’s Senior Director of Finance are now aware of, and better educated on, the Davis-Bacon requirements. The specific cause of Big Sky Finance not requiring Davis-Bacon wages on its initial loans that fit the criteria was solely based on the Director of Business Finance/Program Finance Director’s lack of knowledge of this requirement, or any previous experience having had worked with Federal loan construction projects. Planned Corrective Actions: BSEDC’s Director of Business Finance/Program Finance Director has amended the organization’s EDA-RLF Plan, including details on the Davis-Bacon requirements for any loan funding construction or renovations of more than $2,000. It will be the responsibility of Big Sky Finance to notify the borrower as soon as possible regarding the Davis-Bacon requirements for wages paid. The borrower will in turn notify their contractor of the requirement. Big Sky Finance will require evidence from the general contractor of the prevailing wages being paid prior to loan funds being disbursed. Timeline for Completion: The Davis-Bacon requirement for funds disbursed through BSEDC’s Federal EDARLF loan fund will be immediately implemented for all EDA-RLF loans funded going forward. BSEDC’s EDARLF Plan will be amended and approved by its Board of Directors within a reasonable amount of time. A draft of this change is in place. However, as a matter of practice, Davis-Bacon requirements will be adhered to from this date forward. Responsible Person or Party: BSEDC’s Director of Business Finance/Program Finance Director, will be responsible for making the changes to the plan, presenting to the Board and adhering to the plan going forward.

View Audit 335033

Finding 517142 (2023-002)

Significant Deficiency 2023

Big Sky Economic Development Corporation

MT

Matching / Level of Effort / Earmarking Eligibility Period of Performance § 200.303 § 200.307

Financial Reporting and Review Process Description of the Finding: BSEDC did not have a secondary review process over the required financial reporting to Federal EDA. The lack of a secondary review process allowed for errors and omissions to go undetected, thus resulting in omission of $3,614 of loa...

Financial Reporting and Review Process Description of the Finding: BSEDC did not have a secondary review process over the required financial reporting to Federal EDA. The lack of a secondary review process allowed for errors and omissions to go undetected, thus resulting in omission of $3,614 of loan origination fee income and interest income from federal program income calculations. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director have implemented processes for the Senior Director of Finance to perform a secondary review of the required reporting to Federal EDA before it is submitted. Timeline for Completion: BSEDC implemented the secondary review process in October 2024 with the completion and submission of the FY24 annual report to Federal EDA. Responsible Person or Party: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director are both responsible for ensuring that the secondary review is complete before submitting reporting to Federal EDA.

View Audit 335033

Finding 517141 (2023-001)

Significant Deficiency 2023

Big Sky Economic Development Corporation

MT

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Eligibility § 200.501 § 200.512

Finding No. 2023-001: Compliance with Single Audit Requirements Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the p...

Finding No. 2023-001: Compliance with Single Audit Requirements Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Planned Corrective Actions: BSEDC’s Senior Director of Finance engaged with an independent auditor to complete the single audit for FY23 and re-issue the financial statement audit which was missed during the performance of the FY23 financial statement audit due to the Senior Director of Finance and the parties they engaged to perform the audit not having a clear understanding of the calculation for federal expenditures for the federal revolving loan fund. The Senior Director of Finance now has a clear understanding of the requirements for the calculation and reporting of federal expenditures in the Schedule Expenditures of Federal Awards as it relates to the federal revolving laon fund. Timeline for Completion: BSEDC engaged with an independent auditor to complete the single audit for FY23 and reissue the FY23 financial statement audit in June 2024. Expected completion is November 2024. Responsible Person or Party: BSEDC’s Senior Director of Finance is responsible for implementing the corrective action.

View Audit 335033

Finding 517098 (2023-015)

Material Weakness 2023

Guam Department of Education

GU

Matching / Level of Effort / Earmarking

Finding No.: 2023-015 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425 Education Stabilization Fund - State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Matching, Level of Effort, Earmark...

Finding No.: 2023-015 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425 Education Stabilization Fund - State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE disagrees with the finding. The final 2023 data for the Maintenance of Effort (MOE) will based on the audited financials for FY 2023 as approved in GDOE’s communication with USEd. Since the audits for GDOE and the Government of Guam were both delayed, the final data needed to complete the MOE calculation was not available. GDOE was proactive in providing USEd with preliminary calculations using appropriated amounts for elementary and secondary education which indicated that the MOE fell within the acceptable one percent of the baseline. GDOE believes that it cannot be held to an audit finding for an MOE when the MOE calculation has yet to be finalized. Additionally, GDOE was approved for waivers in FY 2022. Upon completion of this year’s audit and calculation of MOE, GDOE is still subject to a waiver request approval which would negate the MOE finding identified. Plan of action and completion date: Once the financial audits for GDOE and GovGuam are complete, the final FY 2023 MOE will be calculated. Should the FY 2023 MOE fall short of the baseline, a waiver request will be submitted to USEd. The submission of final data and waiver request, if needed, will be completed by December 30, 2024. Plan to monitor and responsible officials: The Internal Audit Office will ensure that the final MOE data is calculated and, if needed, a waiver request is prepared and submitted.

View Audit 334970

Finding 517097 (2023-014)

Significant Deficiency 2023

Guam Department of Education

GU

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management

Finding No.: 2023-014 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425 Education Stabilization Fund - State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Allowable Costs/Cost Principles Qu...

Finding No.: 2023-014 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425 Education Stabilization Fund - State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Allowable Costs/Cost Principles Questioned Costs: $378,118 Views of Auditee and Corrective Actions: GDOE disagrees with the condition related to Simon Sanchez High School (SSHS) as the units were used prior to the school’s closure. The units for SSHS were received and installed in October 2022. According to the school principal, all units were utilized in classrooms and offices. Following Typhoon Mawar, the school was deemed unsafe for occupancy, prompting the relocation of all units to a secured location. GDOE agrees with the condition related to F.B. Leon Guerrero Middle School (FBLGMS). However, GDOE would like to clarify that the units for FBLGMS were initially delivered to JP Torres for staging and assembly in December 2022, which coincided with the closure of the school. In February 2023, the unused units were transferred to Tiyan High School for secure storage. The units will continue to be securely stored until the new school facilities have completed construction in school year 2025-2026 and 2026-2027. Plan of action and completion date: GDOE plans to utilize the HEPA filtration systems across other federal awards from the same granting agency, to include the Consolidated Grant and Special Education programs. GDOE will also utilize the units as replacements for other schools as needed. Plan to monitor and responsible officials: Program Coordinator, Cellini Higa, will coordinate the use of the HEPA units for other federal awards and replacements for other schools.

View Audit 334970 Questioned Costs: $1

Finding 517094 (2023-011)

Significant Deficiency 2023

Guam Department of Education

GU

Questioned Costs Period of Performance Procurement, Suspension & Debarment

Finding No.: 2023-011 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Areas Area: Period of Performance Questioned Costs: $11,004 Views of Auditee and Corrective Actions: GDOE disagrees with condition 1 related to FY 2024 purchase orders (PO). GDOE ...

Finding No.: 2023-011 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Areas Area: Period of Performance Questioned Costs: $11,004 Views of Auditee and Corrective Actions: GDOE disagrees with condition 1 related to FY 2024 purchase orders (PO). GDOE PO 20240171 is a copy over of the third-party fiduciary agent (TPFA) PO 20230010 which was issued in December 2022, within the CG 21 period of performance. GDOE acknowledges that the re-issued GDOE purchase order was not timely processed, however the purchase order which encumbered the funds occurred in the appropriate performance period. Additionally, relative to payroll, FPD requests a list (i.e. Staffing Pattern) of all Federally funded personnel from HR. FPD distributes the list to CG Project Leads to validate and compare to the Federal Roster as approved in the Consolidated Grants (CG) Application. The list is updated to make any corrections necessary. Once validated by Project Leads and FPD, HR is given a memo requesting to change/correct the funding year to the new grant award. In GDOE’s Munis system, if the Human Resources (HR) employee salary records are not accurately updated, GDOE payroll will reflect dated pay tables until such time HR makes the appropriate updates based on project lead requests to update accounts to current grant year. GDOE recorded journal entries to transfer the improperly charged payroll expenditure to the appropriate grant year. Plan of action and completion date: The GDOE will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will work with the HR and Business Office any changes to accounts charged for federally funded payroll expenditures. IAO now provides an independent review of drawdown requests - a control that will help prevent liquidation after applicable period of performance Plan to monitor and responsible officials: Financial Affairs under the leadership of the Deputy of Finance and Administrative Services, Morgan W. Paul, and the GDOE Comptroller (vacant), will ensure an accountant is monitoring the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers and Federal Compliance review team will also provide timely communication for changes in grant year funding to HR relative to federal payroll.

View Audit 334970 Questioned Costs: $1

Finding 517090 (2023-009)

Material Weakness 2023

Guam Department of Education

GU

Questioned Costs Period of Performance Procurement, Suspension & Debarment

Finding No.: 2023-009 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $80,983 Views of Auditee and Corrective Actions: GDOE agrees with Condition 1 questioned costs of $560. The questioned charges are re...

Finding No.: 2023-009 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $80,983 Views of Auditee and Corrective Actions: GDOE agrees with Condition 1 questioned costs of $560. The questioned charges are related to TPFA purchase orders issued in fiscal year 2019, which falls outside of the period of performance. The expenditure for the 2019 purchase order was transferred from the TPFA Munis and recorded in the incorrect GDOE Munis account. GDOE disagrees with Condition 2 questioned costs of $18,041. In line with federal regulations, GDOE paid (liquidated) the obligations in question on January 4 and 26, 2024, which is before the liquidation end date of January 28, 2024.E&Y auditors are citing GDOE for the issued checks clearing the bank after the liquidation end date, however, liquidation occurs when the recipient draws funds from the grants management system and pays obligations and not specifically when checks clear the bank. GDOE agrees with Condition 2 $62,382 questioned costs. While GDOE Munis system has recorded expenses of $62,382 related to Special Education (SPED) obligations, funds were not drawn for these expenditures. In GDOE’s federal review process, drawdowns are reviewed in alignment with specific conditions for allowability and in compliance with period of performance timelines. The identified funds were not expended from SPED grants. To correct this reporting deficiency, GDOE will record journal entries to transfer the expenditures to appropriate funding sources. Similarly, GDOE improperly charged $3.1 million in payroll expenditures to SPED grants after the period of performance. Subsequently, GDOE corrected this finding by making the appropriate journal entries to transfer the improperly charged payroll expenditure to the appropriate grant year. Plan of action and completion date: The GDOE will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will timely communicate to the Human Resources and Business Office any changes to accounts charged for federally funded payroll expenditures. The IAO now provides an independent review of drawdown requests - a control that will help prevent liquidation after applicable period of performance Plan to monitor and responsible officials: Financial Affairs under the leadership of the Deputy of Finance and Administrative Services, Morgan W. Paul, and the GDOE Comptroller (vacant), will ensure an accountant is monitoring the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers and Federal Compliance review team will also provide timely communication for changes in grant year funding to HR relative to federal payroll.

View Audit 334970 Questioned Costs: $1

Finding 517084 (2023-007)

Significant Deficiency 2023

Guam Department of Education

GU

Questioned Costs Subrecipient Monitoring Period of Performance

Finding No.: 2023-007 Federal Agency: U.S. Department of the Interior Pass-Through Entity: Government of Guam AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $113,767 Views of Auditee and Corrective Actions: GDOE agrees ...

Finding No.: 2023-007 Federal Agency: U.S. Department of the Interior Pass-Through Entity: Government of Guam AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $113,767 Views of Auditee and Corrective Actions: GDOE agrees with the finding. GDOE is in receipt of Department of Interior grants and manages said funds in coordination with BBMR and Guam Homeland Security. GDOE established projects that were allowable for the use of these funds on a reimbursement basis. In an effort to maximize federal funding, GDOE initiated a transfer of expenses which was tied to a purchase order in FY 2016. Plan of action and completion date: GDOE Financial Affairs has recorded an adjusting journal entry to record the expenditures under FY 2021 but will have to reclass the expenditure in to FY 2020. GDOE will assign an accountant to reconcile GDOE’s Department of Interior budget availability with BBMR and will monitor AS400 for proper recording of transactions. Plan to monitor and responsible officials: The Comptroller (vacant) will monitor on a quarterly basis expenditure from the Department of Interior grant and will prepare a progress report on a semi-annual basis to the Deputy of Finance and Administrative Services, Morgan W. Paul, for review and approval.

View Audit 334970 Questioned Costs: $1

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