Corrective Action Plans

Finding 517632 (2024-003)

Significant Deficiency 2024

WI

Student Financial Aid Reporting Significant Deficiency § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College rebuilds the ‘Primary Program GT eForm’ to include a check that verifies all programs are not designated as Secondary. Explanation of disagreement with audit finding: There is no disa...

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College rebuilds the ‘Primary Program GT eForm’ to include a check that verifies all programs are not designated as Secondary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Records staff now individually review each form submission to ensure a Primary program is appropriately assigned. In addition, a fix is being implemented to the District’s NSC file submission to verify students who have Primary and Secondary programs appear accurately. A cross-functional team has been established to create an audit report to scale NSC file submissions, as well. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2025

View Audit 335670

Finding 517598 (2024-001)

Significant Deficiency 2024

Jevs Human Services and Affiliates

PA

Internal Control / Segregation of Duties Student Financial Aid Reporting

JEVS HUMAN SERVICES AND AFFILIATES CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 FINDINGS – FEDERAL AWARD PROGRAM AUDITS U.S. Department of Education 2024-001 Significant Deficiency in Internal Control over Compliance Student Financial Aid Cluster: 84.063 – Federal Pell Grant Program 84....

JEVS HUMAN SERVICES AND AFFILIATES CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 FINDINGS – FEDERAL AWARD PROGRAM AUDITS U.S. Department of Education 2024-001 Significant Deficiency in Internal Control over Compliance Student Financial Aid Cluster: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition: Certain students’ enrollment information was not reported accurately or timely to the National Student Loan Data System (NSLDS). Recommendation: We recommend the College to review its procedures for transmitting accurate information to the NSLDS. Furthermore, we suggest that the College establish a process to enhance oversight of the submissions completed by the third-party servicer. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated policies and procedures on reporting enrollment. A new procedure had been added to the process, requiring a designated employee to check and review on a weekly basis the Student Status Confirmation Report (SSCR) on the National Student Clearinghouse (NSC) SSCR Error Correction Platform. The designated employee will document the review and resolution of items identified on the error report. This ensures that any errors are resolved within ten days of receipt, as required by the Department of Education for all schools receiving and distributing Title IV Aid. Planned completion date for corrective action plan: December 31, 2024

View Audit 335626

Finding 517588 (2024-003)

None 2024

Thomas College

ME

Procurement, Suspension & Debarment Student Financial Aid Matching / Level of Effort / Earmarking

Thomas College will ensure that there are dual controls relating to the programs like the Perkins Loan Program going forward to ensure that both the CFO and the Controller are able to access and make deposits. The CFO position was vacant at the time and the Controller was filling both positions, whi...

Thomas College will ensure that there are dual controls relating to the programs like the Perkins Loan Program going forward to ensure that both the CFO and the Controller are able to access and make deposits. The CFO position was vacant at the time and the Controller was filling both positions, which led to the oversight. When the new CFO started, they determined that there was no lost interest due to the timing of the cash deposit and going forward they would work in collaboration to ensure this was not missed in the future.

View Audit 335602

Finding 517587 (2024-002)

Significant Deficiency 2024

Thomas College

ME

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

Thomas College has refined internal reporting policies and procedures to confirm that student enrollment is reported accurately and in a timely manner. The College uses the National Student Clearinghouse as a data vendor for reporting to NSLDS. The College agrees the students were incorrectly report...

Thomas College has refined internal reporting policies and procedures to confirm that student enrollment is reported accurately and in a timely manner. The College uses the National Student Clearinghouse as a data vendor for reporting to NSLDS. The College agrees the students were incorrectly report to NSLDS. However, the student records were regularly updated with the National Student Clearinghouse, according to policies and procedures, NSC was not then transmitting some student records to NSLDS due to a conflict in data reported by a prior instituition concerning name and mismatched SSN. The College has identified the error within the National Student Clearinghouse (NSC). The following findings and corrective actions have been adopted: 1) Additional one on one training with the NSC has been completed to better understand the cause of the finding. The error that is preventing the release of information to NSLDS has been identified and steps required to resolve the error have been communicated. This training will expand to all Thomas College employees who oversee and process enrollment reporting. 2) Thomas College is closely monitoring the processing details from each submission file sent from the college to NSC to identify students not being sent from NSC to NSLDS. Thomas College is submitting the necessary, required paperwork for verification to the NSC, as needed; to verify the student's identify and information, an example of this documentation is an ISIR recorded provided by SFS. The NSC send an automated email to enrollment reporting staff when changes are made and a follow up email requesting additional information if needed. Once resolved, student are no longer shown on the transmission rejection list and are being sent to NSLDS.

View Audit 335602

Finding 517553 (2024-007)

Material Weakness 2024

Washington Parks Academy

MI

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • We have brought on a State and Federal Grants Consultant to ensure all required grant related paperwork is completed and saved in a shared location with the Finance Team.

View Audit 335565

Finding 517552 (2024-006)

Material Weakness 2024

Washington Parks Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.501 § 200.512 § 200.514

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy’s side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the fut...

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy’s side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the futur

View Audit 335565

Finding 517551 (2024-005)

Material Weakness 2024

Washington Parks Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.

View Audit 335565

Finding 517550 (2024-004)

Material Weakness 2024

Washington Parks Academy

MI

Cash Management Subrecipient Monitoring Material Weakness § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

View Audit 335565

Finding 517541 (2024-009)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.

View Audit 335561

Finding 517539 (2024-007)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.

View Audit 335561

Finding 517538 (2024-005)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Cash Management Subrecipient Monitoring Material Weakness § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.

View Audit 335561

Finding 517528 (2024-008)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.501 § 200.512 § 200.514

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy’s side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the fut...

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy’s side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the future.

View Audit 335561

Finding 517527 (2024-006)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.

View Audit 335561

Finding 517526 (2024-004)

Material Weakness 2024

Lincoln-King Adams-Young Academy

MI

Cash Management Subrecipient Monitoring Material Weakness § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

View Audit 335561

Finding 517500 (2024-005)

Material Weakness 2024

One City Schools, Inc.

WI

School Nutrition Programs Material Weakness Internal Control / Segregation of Duties

MATERIAL WEAKNESS 2024-005 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Nonprofit school food service fund Recommendation: Internal controls for accounting for nonprofit school food services funds should be implemented. A separate class in the accounting software should be u...

MATERIAL WEAKNESS 2024-005 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Nonprofit school food service fund Recommendation: Internal controls for accounting for nonprofit school food services funds should be implemented. A separate class in the accounting software should be utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One City Schools did improve their accounting procedures in 2023-24 to begin using separate classes for food expenses and revenues. To further implement best practice One City Schools is utilizing guidance from DPI to identify and account for program versus nonprogram foods to ensure there is no unallowed profit made off the program. Written policies and procedures are being drafted and will be implemented. Name(s) of the contact person(s) responsible for corrective action: Janel Vertz, Finance Director Planned completion date for corrective action plan: June 2025 (with all fiscal year 2024-25 revenues and expenses retroactively evaluated and appropriately accounted for).

View Audit 335506

Finding 517499 (2024-004)

Material Weakness 2024

One City Schools, Inc.

WI

Material Weakness School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

MATERIAL WEAKNESS 2024-004 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Claiming Review Recommendation: One City Schools should implement appropriate internal controls for reviewing funding claims prior to submission. Explanation of disagreement with audit finding: There is ...

MATERIAL WEAKNESS 2024-004 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Claiming Review Recommendation: One City Schools should implement appropriate internal controls for reviewing funding claims prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One City Schools did improve their claims procedures in 2023-24. To further implement best practice, policies related to federal claims reviews were incorporated into the Federal Grants Procedural Manual. One City Schools also utilized guidance from DPI to implement meal counting and claiming policies and procedures including counting reimbursable meals, performing edit checks of counts, submitting site-based claims, and retaining appropriate documentation. Name(s) of the contact person(s) responsible for corrective action: Janel Vertz, Finance Director Planned completion date for corrective action plan: Completed

View Audit 335506

Finding 517497 (2024-002)

Material Weakness 2024

One City Schools, Inc.

WI

Procurement, Suspension & Debarment Material Weakness School Nutrition Programs § 200.317 § 200.327

MATERIAL WEAKNESS 2024-002 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Procurement Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Explanation of disagreement with audit finding: There is n...

MATERIAL WEAKNESS 2024-002 Child Nutrition Cluster – Assistance Listing Number 10.553 and 10.555 Procurement Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One City Schools adopted a procurement policy in November 2023 that, if followed, resolves this finding. A new primary food vendor was selected in summer of 2024, and the selection did adhere to the new procurement policy. This policy and all procedures were edited to be comprehensive of all uniform grant requirements through the development and adoption of the Federal Funds Procedural Manual. Name(s) of the contact person(s) responsible for corrective action: Janel Vertz, Finance Director Planned completion date for corrective action plan: January 2025

View Audit 335506

Finding 517492 (2024-002)

Significant Deficiency 2024

Georgian Court University

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: The Office of the Registrar had a significant decrease in staff who were experienced in the required reporting during this period. Also, we asked Ellucian staff, who support our Power Campus Student Information System and who were responsible for setting up the report...

Views of Responsible Officials: The Office of the Registrar had a significant decrease in staff who were experienced in the required reporting during this period. Also, we asked Ellucian staff, who support our Power Campus Student Information System and who were responsible for setting up the report, to review the reporting process and the coding generating the report itself for accuracy. At one point, the staff assigned to us were changed by Ellucian and so the process and report review were not completed in a timely manner. All these factors contributed to delay in reporting and old information being included. With new staffing in place now and having had training from National Student Clearinghouse, as well as working with a new group of Ellucian consultants who have reviewed the process and coding for the report, we are back on track with reporting. We expect that coding changes to the report that are being completed by Ellucian consultants will remove any incorrect data.

View Audit 335503

Finding 517397 (2024-004)

Material Weakness 2024

Eastern Carver County Schools Independent School District No. 112

MN

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303

Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transact...

Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement and suspension and debarment to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025

View Audit 335365

Finding 517236 (2024-001)

Significant Deficiency 2024

Community Action of Greene County, Inc.

NY

Reporting Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.501

• The Fiscal Director position has not been continuously filled, and since COVID 19 it has proven difficult to hire qualified staff at the rate of pay offered by the Agency . The Fiscal Director is responsible for providing training and supervision to staff, and for completing such tasks as working ...

• The Fiscal Director position has not been continuously filled, and since COVID 19 it has proven difficult to hire qualified staff at the rate of pay offered by the Agency . The Fiscal Director is responsible for providing training and supervision to staff, and for completing such tasks as working with our Auditors and scheduling the annual audit. The Organization has hired a CFO for hire however, there are still sometimes difficulty in maintaining steady work flow, meeting deadlines and ensuring year end closing entries and reconciliations are completed timely. In addition, the Auditors contracted with the Agency have begun their reviews much later than they had pre-Covid, also lending to difficulty in meeting deadlines. • Community Action of Greene County Inc. will work to improve employee retention and engagement through coaching, training, wage equity, and improved Human Resource practices. • Community Action of Greene County Inc. will continue to incorporate automated accounting and payroll processes to improve the efficiency and accuracy of fiscal reporting. • A year end closing checklist and calendar has been developed and utilized by the fiscal staff as of Spring 2024. The completed checklist will be shared with the Executive Director following the close out period. • The Executive Director will schedule the Auditors to begin their reviews within 90 days of year end as a condition of their contract. • The Executive Director is responsible for ensuring this corrective action plan is implemented.

View Audit 335235

Finding 517230 (2024-002)

Significant Deficiency 2024

Believe Schools, Inc. and Affiliate

IN

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

To Whom it may concern: This document serves as the response to the 2023-2024 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and addressed the comments that were included in the Uniform Guidance Major Program Findings. Please review the corrective action items in response to the...

To Whom it may concern: This document serves as the response to the 2023-2024 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and addressed the comments that were included in the Uniform Guidance Major Program Findings. Please review the corrective action items in response to the Audit Results and Comments: Education Stabilization Fund (ESSER Grant): The school was unable to provide construction contracts to allow auditors to verify that the required Davis-Bacon Act wording was included. ● The Principal, Angel Jackson-Anderson, and Dean of Operations, Kayla Marshall, will ensure that the proper contracts are received and filed for all services conducted under ESSER grants. Child Nutrition: The school did not maintain tally sheets to support the number of meals served. ● The Dean of Operations, Kayla Marshall, will ensure that the proper physical files (tally sheets) are maintained and filed monthly, both in digital and paper form. The principal will review these files monthly to ensure documents are not lost or misplaced. If you have any questions, concerns, or comments, please feel free to contact me the school principal, Angel Jackson-Anderson, Aanderson@believeschools.org. Many thanks, Angel Jackson-Anderson Principal, BELIEVE Circle City High School Kayla Marshall Dean of Operations, BELIEVE Circle City High School www.believeschools.org @believeschoolsindy admin@believeschools.org 317-296-1954 Angel Jackson-Anderson 11/07/2024 02:25PM UTC

View Audit 335212

Finding 517228 (2024-001)

Significant Deficiency 2024

Believe Schools, Inc. and Affiliate

IN

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

To Whom it may concern: This document serves as the response to the 2023-2024 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and addressed the comments that were included in the Uniform Guidance Major Program Findings. Please review the corrective action items in response to the...

To Whom it may concern: This document serves as the response to the 2023-2024 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and addressed the comments that were included in the Uniform Guidance Major Program Findings. Please review the corrective action items in response to the Audit Results and Comments: Education Stabilization Fund (ESSER Grant): The school was unable to provide construction contracts to allow auditors to verify that the required Davis-Bacon Act wording was included. ● The Principal, Angel Jackson-Anderson, and Dean of Operations, Kayla Marshall, will ensure that the proper contracts are received and filed for all services conducted under ESSER grants. Child Nutrition: The school did not maintain tally sheets to support the number of meals served. ● The Dean of Operations, Kayla Marshall, will ensure that the proper physical files (tally sheets) are maintained and filed monthly, both in digital and paper form. The principal will review these files monthly to ensure documents are not lost or misplaced. If you have any questions, concerns, or comments, please feel free to contact me the school principal, Angel Jackson-Anderson, Aanderson@believeschools.org. Many thanks, Angel Jackson-Anderson Principal, BELIEVE Circle City High School Kayla Marshall Dean of Operations, BELIEVE Circle City High School www.believeschools.org @believeschoolsindy admin@believeschools.org 317-296-1954 Angel Jackson-Anderson 11/07/2024 02:25PM UTC

View Audit 335212

Finding 517212 (2024-002)

Significant Deficiency 2024

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, 2024 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2024-002 (a...

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2024 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2024-002 (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 335174

Finding 517198 (2024-002)

Significant Deficiency 2024

Big Sky Economic Development Corporation

MT

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC does not have internal controls in place to verify compliance with prevailing wage rates in the event that such loans are disbursed. Planned Corrective Actions: BSEDC’s Director of Business Finance/Program Finance Dir...

Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC does not have internal controls in place to verify compliance with prevailing wage rates in the event that such loans are disbursed. 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 335172

Finding 517197 (2024-001)

Significant Deficiency 2024

Big Sky Economic Development Corporation

MT

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Late Submission of Form ED-209 Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Errors were identified which require...

Late Submission of Form ED-209 Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Errors were identified which required correction and resubmission of the form. The final submission was completed on October 18, 2024, which was after the deadline. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director will implement stricter internal controls and monitoring procedures to ensure all federal reports, including Form ED-209, are prepared accurately and submitted within the required deadlines. A review process will be added to the monitoring procedures to promptly address and correct any errors identified by federal agencies. Timeline for Completion: BSEDC will implement the internal controls and monitoring procedures with the next reporting that is due 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 is responsible for implementing the corrective action. 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 335172

Corrective Action Plans

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