Corrective Action Plans

Finding 383909 (2023-001)

Material Weakness 2023

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The superintendent and encumbrance clerk will review all Davis-Bacon requirements before using federal funds on construction projects beginning immediately (10-20-23) and continuing with all construction projects in the future. The following will be monitored as part of the review/action plan: com...

The superintendent and encumbrance clerk will review all Davis-Bacon requirements before using federal funds on construction projects beginning immediately (10-20-23) and continuing with all construction projects in the future. The following will be monitored as part of the review/action plan: compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met, including collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance.

View Audit 296918

Finding 383888 (2023-004)

Significant Deficiency 2023

Municipality of Cayey

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 ...

Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Rolando Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Diaz, Finance and Budget Director Phone: (787) 738-3211 Original Finding Number: 2023-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: In this case, for the year 2023-2024, it has already been verified that ACUDEN complies with the provisions of the contract. As an internal control and prevention measure, the budget sent by the Agency will be verified with the percentages (%) established in the contract. If they do not match, ACUDEN will be asked to amend the budget. Implementation Date: During fiscal year 2023-2024. Responsible Person: Mrs. Natasha Vásquez Federal Programs Director

View Audit 296900

Finding 383852 (2023-001)

Significant Deficiency 2023

Bay Path University

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan The University reviewed the student in this finding and feel this is an isolated instance for not returning funds within the 45 requirements. The University conducted a sample review of students with a R2T4 calculation which resulted in a return of federal aid funds. The Univ...

Corrective Action Plan The University reviewed the student in this finding and feel this is an isolated instance for not returning funds within the 45 requirements. The University conducted a sample review of students with a R2T4 calculation which resulted in a return of federal aid funds. The University did not find any additional instances of this situation. The University is reviewing current process and procedures to ensure unearned aid is returned within 45 days. Timeline for Implementation of Corrective Action Plan Fiscal year 2023 Contact Person Stephanie King Executive Director of Student Financial Services

View Audit 296870

Finding 383846 (2023-004)

Significant Deficiency 2023

Indigenous Peoples Task Force

MN

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.430

2023-004: Lack of Payroll Documentation Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.939 Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Name of contact person – Sharon Day, Executive Direc...

2023-004: Lack of Payroll Documentation Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.939 Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Name of contact person – Sharon Day, Executive Director Corrective action – Management will review policies and procedures to ensure information is complete and up-to-date. Completion date – Management and the Board of Directors implemented the above as of January 2024.

View Audit 296866

Finding 383836 (2023-005)

Material Weakness 2023

Metropolitan School District of Washington Township

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund – Special Test and Provisions Summary of Finding: Test Provisions – Wage Requirements Contact Person Responsible for Corrective Action: Jim Boots Contact Phone Number and Email Address: 317-845-9400 jboots@msdwt.k12.in.us Views ...

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund – Special Test and Provisions Summary of Finding: Test Provisions – Wage Requirements Contact Person Responsible for Corrective Action: Jim Boots Contact Phone Number and Email Address: 317-845-9400 jboots@msdwt.k12.in.us Views of Responsible Officials: We disagree with the finding Explanation and Reasons for Disagreement: The need for Wage Rate Requirements, i.e. Davis Bacon was not contemplated at the time the contracts for Construction Management services and contracting services were created, with the assistance of our legal team, and approved by the Board of Education. When it became known that Federal Assistance Funds were available to fund these existing projects, the District and our CM partners crafted language and incorporated it into the future project specific bidding documents for the appropriate projects and scopes of work that qualified for Federal Assistance Funds. The bidding documents are in the Operations Department files. The District, along with our Capital Projects Team and CM partners, developed a system of tracking, verification, reporting and internal controls to ensure the required documentation and supporting information was filed timely and accurately. Each Pay Application (invoice) contains individual line items in the project specific Schedule of Values for the scope of work that was for Federal Assistance Funding. Our established internal controls and review process pulled that information from each Pay App and identified it to be funded by Federal Assistance Funds. This information is retained in the Operations Department files. In the event our design team (Schmidt) assisted the District with additional services that were funded from Federal Assistance Funds, we are unable to determine how to document this as professional services are compensated on a lump sum/percentage complete basis. Any documentation can be provided in response to a specific request containing the specific information being requested (contractor or scope of work) and the specific project.

View Audit 296858

Finding 383823 (2023-002)

Material Weakness 2023

Metropolitan School District of Washington Township

IN

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.208 § 200.302 § 200.303 § 200.328

FINDING 2023-002 Finding Subject: Special Education Cluster (IDEA) - Reporting Summary of Finding: Expenditures not agreeing with ledgers Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Respons...

FINDING 2023-002 Finding Subject: Special Education Cluster (IDEA) - Reporting Summary of Finding: Expenditures not agreeing with ledgers Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The finding was due to amounts that could not be claimed timely for reimbursement because of funds needing to be moved within grant buckets. Per a discussion with the auditors we need to tie the expenses not claimed back to a specific employee/employees or a specific purchase. beginning with our March reimbursements all adjustments to the funds ledger will have backup documents showing what items were omitted from reimbursement because of need for a budget amendment. Anticipated Completion Date: March 2024

View Audit 296858

Finding 383822 (2023-003)

Significant Deficiency 2023

Walhalla Community Hospital Association

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra Fraser, Administrator...

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra Fraser, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program’s reserve fund is completed with formal documentation noting the review. Anticipate Completion Date: 9/27/2023

View Audit 296855

Finding 383819 (2023-001)

Significant Deficiency 2023

Stevens Institute of Technology

NJ

Student Financial Aid Special Tests & Provisions Reporting

Management agrees with the recommendation. The University understands the importance of accurate and timely reporting of enrollment status and immediately resolved the issues of correcting student records in the NSLDS system and configured the system generated file to correct the status that is repo...

Management agrees with the recommendation. The University understands the importance of accurate and timely reporting of enrollment status and immediately resolved the issues of correcting student records in the NSLDS system and configured the system generated file to correct the status that is reported for students who graduate with a bachelor’s degree and continue in school to pursue a master’s degree. The University will also add a control to review processing errors from the National Student Clearinghouse submissions. The Associate Provost and Registrar will ensure that processes are in place to comply with the recommendation.

View Audit 296842

Finding 383800 (2023-001)

None 2023

University of Notre Dame Du Lac

IN

Student Financial Aid Matching / Level of Effort / Earmarking

Finding No. 2023-001 – E-Sign Act Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Loan Award Year: FY2023 Assistance Listing Number: 84.007,...

Finding No. 2023-001 – E-Sign Act Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Loan Award Year: FY2023 Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Management’s views and corrective action plan: Management agrees with the recommendation to establish a process prompting students to voluntarily consent to participate in electronic transactions in advance of receiving federal student financial assistance. On November 21, 2023, email notifications were sent to undergraduate and graduate students who applied for financial aid for the 2023/2024 academic year. We informed them of the requirement and asked them to complete a consent form. As of March 2024, we have received a 97% response rate. For those who did not respond (and those who declined electronic notifications), paper notifications were sent. Beginning with the 2025-2026 aid year, the process for receiving consent from students will be incorporated into the admission application as a separate question for undergraduate and graduate students. Appropriate Contact: Mary Nucciarone Director, Student Financial Aid, email: mnucciar@nd.edu

View Audit 296825

Finding 383784 (2023-002)

Significant Deficiency 2023

Catholic Community Services of Western Washington

WA

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303 § 200.403 § 200.414

Type of Finding: Significant Deficiency in Internal Control over Compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over...

Type of Finding: Significant Deficiency in Internal Control over Compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the allocation of indirect costs exceeding the de minimis cost rate of 10%, which can be attributed to a lack of communication and review of the total expenditures being charged to the federal program. Program managers were accidentally invoicing before reconciling adjustments made. More thorough training of staff, along with careful supervisory review of total expenditures being charged to the federal program, and invoicing would likely have prevented this error. Corrective Action: An annual training of all grant accountants is being developed and will cover indirect and allowable costs. In addition, a process for secondary review of all invoices is being developed.

View Audit 296797 Questioned Costs: $1

Finding 383771 (2023-003)

Material Weakness 2023

Catholic Community Services of Western Washington

WA

Allowable Costs / Cost Principles Cash Management Subrecipient Monitoring § 200.303 § 200.329

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the ...

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the documentation of secondary review of financial reports, timely filing, and disclosed demographics contained within the reports, which can be attributed to a lack of documentation of review and controls in place for submission of a report when responsible employee is out of office during the due date. Authorized personnel review was not documented, and a performance report was not filed timely and was filed with incorrect demographics. More thorough training of staff, along with careful supervisory review and documentation of review of report submissions prior to filing would likely have prevented these errors. Corrective action: A process for secondary review of all financial and programmatic reports will be developed in each region.

View Audit 296797

Finding 383753 (2023-001)

Significant Deficiency 2023

Massachusetts College of Art and Design

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan Each week, the Director receives information from the Registrar about students who are withdrawing. The Director reviews the student’s financial aid packages within 7 days. The Director will work with the Bursar and the Associate Director of Student Financial Assistance to ens...

Corrective Action Plan Each week, the Director receives information from the Registrar about students who are withdrawing. The Director reviews the student’s financial aid packages within 7 days. The Director will work with the Bursar and the Associate Director of Student Financial Assistance to ensure that federal Title IV funds are returned within 30 days. The Director will keep track of this information on a spreadsheet which will be shared with the Associate Vice President for Fiscal Affairs, the Bursar and the Associate Director of Student Financial Assistance.

View Audit 296776

Finding 383750 (2023-001)

Significant Deficiency 2023

Bunker Hill Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2023-001 Federal agency: U.S. Department of Education (“ED”) Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College has added an Assistant Director of Financial Aid position to oversee weekly reconciliat...

Finding number: 2023-001 Federal agency: U.S. Department of Education (“ED”) Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College has added an Assistant Director of Financial Aid position to oversee weekly reconciliation of Title IV and state financial aid. This position was hired in December 2023 and training started in January of 2024. The College has also put additional reconciliation procedures in place with nightly review of rejected files via the CODE error report by the financial aid counselors. Timeline for Implementation of Corrective Action Plan: January 2024 Contact Person Jillian Glaze, Senior Director of Student Financial Services

View Audit 296768

Finding 383748 (2023-002)

Significant Deficiency 2023

Bunker Hill Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: The College has added an Assistant Director of Financial Aid position to oversee weekly reconciliation of Title IV a...

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: The College has added an Assistant Director of Financial Aid position to oversee weekly reconciliation of Title IV and state financial aid. This position was hired in December 2023 and training started in January of 2024. The College has also put additional reconciliation procedures in place with nightly review of rejected files via the CODE error report by the financial aid counselors. Timeline for Implementation of Corrective Action Plan: January 2024 Contact Person Jillian Glaze, Senior Director of Student Financial Services

View Audit 296768

Finding 383747 (2023-003)

Significant Deficiency 2023

Bunker Hill Community College

MA

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

Finding number: 2023-003 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster AL #’s: 84.007, 84.063, 84.268 Award year: 2023 Corrective Action Plan: The initial R2TIV for both students was completed an...

Finding number: 2023-003 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster AL #’s: 84.007, 84.063, 84.268 Award year: 2023 Corrective Action Plan: The initial R2TIV for both students was completed and funds were returned within the established timeframe. Through the College’s internal procedure, an error was found in the initial calculation, which resulted in a very small additional return for both students that fell outside the established time frame. The College is adding three new positions to the financial aid staff to allow for additional people to do initial R2TIVs and review calculations more quickly. Timeline for Implementation of Corrective Action Plan: Two additional financial aid counselor positions have been added to the staff in February 2024 to assist with the additional workload in the office. Contact Person Jillian Glaze, Senior Director of Student Financial Services

View Audit 296768

Finding 383707 (2023-001)

Significant Deficiency 2023

Cairn University

PA

Reporting Student Financial Aid Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: The University agrees with this recommendation and will ensure that staff with reporting compliance responsibilities are appropriately trained during periods of transition.

View Audit 296734

Finding 383701 (2023-001)

Significant Deficiency 2023

Kalamazoo College

MI

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Finding Number: 2023-001 Condition: The College did not report certain students' status to the NSLDS in an accurate manner during the fiscal year. Planned Corrective Action: The College has implemented a secondary review of the data transmissions related to students who have withdrawn from the Colle...

Finding Number: 2023-001 Condition: The College did not report certain students' status to the NSLDS in an accurate manner during the fiscal year. Planned Corrective Action: The College has implemented a secondary review of the data transmissions related to students who have withdrawn from the College prior to being sent to NSLDS to ensure the student enrollment status is properly reflected in the data transmission. Contact person responsible for corrective action: Nicole Kragt, Registrar Anticipated Completion Date: Completed September 15, 2023

View Audit 296728

Finding 383699 (2023-002)

Material Weakness 2023

South Gibson School Corporation

IN

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

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not s...

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not support the amounts reported for expenditures in either ESSER II annual data report. It was recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are supported by the School Corporation’s underlying accounting records. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning with the annual data report submissions for these funds due in April 2024, the Assistant Superintendent will audit the reports as prepared by the Treasurer in order to ensure the spreadsheets are correct and reflect the financial statements’ of the school corporation. Anticipated Completion Date: 5 March 2024

View Audit 296724

Finding 383695 (2023-001)

Material Weakness 2023

South Gibson School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Summary of Finding: The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal g...

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Summary of Finding: The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. There were two contracted vendors paid in excess of $2,000 with Education Stabilization Fund grant award funds during the audit period for construction related projects. Both contracts, totaling $2,296,300, were selected for testing. Neither of the contracts included the required prevailing wage rate clause. In addition, certified payrolls were not submitted to the School Corporation by either contractor. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This need had been communicated to the school corporation by the Indiana Department of Education in their monitoring of our ESSER funds, which are reported on a quarterly basis. This requirement was not adequately explained to school corporations but has been now. In the future, any Federal dollars used in construction over $2,000 will have this monitored by the Director of Operations, the Assistant Superintendent, as well as the Treasurer and their assistant to ensure compliance with this requirement. Anticipated Completion Date: 5 March 2024

View Audit 296724

Finding 383673 (2023-001)

Significant Deficiency 2023

Tallahassee Housing Authority

FL

HUD Housing Programs Eligibility Significant Deficiency

Finding No. 2023-001 Eligibility – Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Repeat finding from June...

Finding No. 2023-001 Eligibility – Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Repeat finding from June 30, 2022 as Finding 2022-002 (initially reported June 30, 2010) Condition: Out of a total tenant population of approximately 2,179 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 1 error where the signed lease agreement in the file had the wrong rent amount, however HAP and tenant rent payments being made were correct. • 1 error where file had wrong date of birth for a family member, however this had no effect on HAP rent. • 1 error where lease agreement in file did not state the monthly rent amount, however HAP and tenant rent payments being made were correct. • 1 error where a disability and dependent allowance that family qualified for was not deducted from their income. This increased HAP rent by $21. • 1 error where the utility allowance was calculated using the prior year schedule. This increased HAP rent by $18. • 1 file where data entry error on the 50058 caused wage income to be reported incorrectly. This decreased HAP rent by $10. • 1 error where the HAP contract in the file had the wrong rent amount, however the correct rent was reported on 50058. • 1 error where the utility allowance was calculated using 3 bedrooms when it should have been 2 bedrooms. This had no effect on HAP rent. • 1 file with math errors on calculating both wage and child support income. This increased HAP rent by $28. • 2 files with math errors on calculating child support income. This had no effect on HAP rent for one file and decreased HAP rent by $8 on the other. • 1 error where EIV report did not include one member of the household, however file did contain the member of the household’s social security card and birth certificate. • 1 file where Authority did not properly verify reported change in income from loss of job for one member of the household. As a result, tenant’s income was not calculated correctly, however the impact on HAP rent is undeterminable. In addition to the above, we noted the following during our new admissions testing (19 new admissions tested out of a population of 190 new admissions): • 1 error where the 214 affidavit was not properly checked to indicate member of household was an eligible citizen. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding and has implemented a robust file review process, enhanced quality control procedures, and provided training on errors noted along with annual program training for all staff. The cited files were corrected. Effective Date: March 18, 2024 Contact Information Brenda Williams, Executive Director Tallahassee Housing Authority 2940 Grady Road Tallahassee, Florida 32312 (850) 385-6126

View Audit 296715

Finding 383652 (2023-001)

Material Weakness 2023

Mount Mary University, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

For the Year Ended June 30, 2023 Finding 2023-001 Condition 1: Management's review of the enrollment reporting did not detect errors on certain student data elements that were not timely filed. Certain student records within the NSLDS were identified with inaccurate data elements and others that wer...

For the Year Ended June 30, 2023 Finding 2023-001 Condition 1: Management's review of the enrollment reporting did not detect errors on certain student data elements that were not timely filed. Certain student records within the NSLDS were identified with inaccurate data elements and others that were not timely reported. Corrective Action Planned: Registrars will work with our IT department to ensure data retrieved from Jenzabar for NSLDS reporting is pulling all the correct information including student’s status and all effective dates.  Prior to the report being uploaded to NSLDS, the Registrar will review a sample of students to ensure the accuracy of data.  Once the reports are updated to NSLDS Financial Aid and Veterans Services will review a sample of students and review data provided by NSLDS, again to confirm the accuracy of data at all stages. Name(s) of Contact Person(s) Responsible for Corrective Action: Angela Sarni, Director of Financial Aid & Veterans Services and Jonathan Hertig, Registrar Anticipated Completion Date: Registrar is currently working with IT to review report script and resolve any prior reporting’s. Student updates will continue to be monitored prior to NSLDS submissions and confirmed by Financial Aid and Veterans Services. We anticipate a revised report to be completed with accuracy to NSLDS no later than April 30, 2024.

View Audit 296692

Finding 383646 (2023-002)

Material Weakness 2023

Washington College

MD

Student Financial Aid Subrecipient Monitoring Material Weakness § 200.303

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement wi...

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A CIO who has extensive experience in regulatory compliance as well as cyber security has been hired. The CIO has set forth a plan to get us in full regulatory compliance. A new information security plan has been crafted and is being published on the website. That plan will be put into practice over the next few months. Name(s) of the contact person(s) responsible for corrective action: Irving Bruckstein Planned completion date for corrective action plan: June 30, 2024

View Audit 296682

Finding 383645 (2023-001)

Material Weakness 2023

Washington College

MD

Student Financial Aid Eligibility Material Weakness § 200.303

Student Financial Aid Cluster – NSLDS Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with...

Student Financial Aid Cluster – NSLDS Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure continuity of operations, Jennifer Gallagher will be temporarily assuming responsibility for Enrollment Reporting until a new Registrar is hired and trained. She is committed to addressing any outstanding issues and improving the efficiency of our processes during this transitional period. Name(s) of the contact person(s) responsible for corrective action: Jennifer Gallagher Planned completion date for corrective action plan: June 30, 2024

View Audit 296682

Finding 383638 (2023-006)

Material Weakness 2023

Southwest School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding 2023-006 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: 84.425U Federal Award Numb...

Finding 2023-006 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: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion 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 Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $556,865 during the audit period on a construction project to expand the cafeteria which was charged to the ESSER III grant award (84.425U) and approved through the grant application with the Indiana Department of Education. The construction contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts. The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from the construction company and its subcontractors, as applicable, for the construction project to verify prevailing wages were being paid during the project period. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The construction payments represented approximately 22.5% of the Education Stabilization Fund disbursements for the period under audit. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 - The Southwest School Corporation will ensure that Davis Bacon rules are included in any RFP using federal funds. The Development Team will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 2024

View Audit 296662

Finding 383627 (2023-005)

Material Weakness 2023

Southwest School Corporation

IN

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

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X...

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

View Audit 296662

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