Corrective Action Plans

Finding 382282 (2023-002)

Material Weakness 2023

Ascension Health Alliance D/b/a Ascension

MO

Allowable Costs / Cost Principles Cash Management Period of Performance

Finding 2023-002 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Thr...

Finding 2023-002 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA000420 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Views of responsible officials: Ascension Living management acknowledges that internal controls were not working effectively regarding review of the calculated limitations and allocations. Ascension has reserved the questioned costs and has communicated with the State on their desired method of repayment. For future grants, Ascension Living will implement controls for appropriate review and approval and to have a secondary review to validate calculations. St. Agnes Healthcare, Inc., Maryland - This finding pertains to retroactive grants where expenses were incurred in previous periods but were subsequently eligible for grant reimbursement. Management is working on creating a report to identify timecards lacking manager approval for exclusion as allowable grant expenses. Grant Accounting is incorporating Time and Effort tracking features a separate approval control to mitigate the issue of timecards lacking manager approval. Responsible Official: July Turley, Director of Accounting and Reporting; Rob Madsen, Director of Accounting and Reporting Anticipated completion date: May 31, 2024, and July 01, 2024

View Audit 295994

Finding 382277 (2023-002)

Significant Deficiency 2023

Bowling Green Independent School District

KY

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

In regard to the 2023-002 COVID-19 Education Stabilization Fund, a payroll record failed to be updated to the new rate per the FY2023 salary schedule and, as a result, extraduty performed by this employee was underpaid by $91 throughout the entirety of FY2023. Management had already identified the i...

In regard to the 2023-002 COVID-19 Education Stabilization Fund, a payroll record failed to be updated to the new rate per the FY2023 salary schedule and, as a result, extraduty performed by this employee was underpaid by $91 throughout the entirety of FY2023. Management had already identified the internal control error in August of 2023, identified the root cause of the error, and had implemented both preventative and detective controls as of August 2023. The controls will be adhered to with the strictest of oversight. If the Kentucky Department of Education has questions regarding this plan, please call Shaunna Cornwell

View Audit 295993

Finding 382274 (2023-002)

None 2023

Landmark College, INC

VT

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

FINDING 2023-002: Timely Reporting to NSLDS The Registrar and the Landmark College Database / Application Systems Analyst met with the National Student Clearinghouse (NSC) to address this issue. This discussion surfaced the information about how NSC schedules their files and the revelation that Covi...

FINDING 2023-002: Timely Reporting to NSLDS The Registrar and the Landmark College Database / Application Systems Analyst met with the National Student Clearinghouse (NSC) to address this issue. This discussion surfaced the information about how NSC schedules their files and the revelation that Covid pushed the NSC submission schedule back. As a result of the meeting, the NSC first of term file will revert to preCovid. Planned Corrective Action: The correction to reports by NSC should correct this error going forward

View Audit 295992

Finding 382273 (2023-004)

Material Weakness 2023

Rensselaer Central School Corporation

IN

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

Finding 2023-004 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 Pass-Through Entit...

Finding 2023-004 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 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 did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the corrective action plan which will be implemented by June 30, 2024.

View Audit 295986

Finding 382265 (2023-003)

Material Weakness 2023

Rensselaer Central School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award...

Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative Schools Service has developed a written procedure of documenting expenditures related to the proportionated share earmarking requirement and validate the earmarking requirement to met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The correction action plan has been put into place for the 2023-24 school year. Treasurer, Dawn Claussen and Director of Cooperative School Services, Sarah Claton, will oversee the corrective action plan.

View Audit 295986

Finding 382253 (2023-004)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or de...

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports—a total of six reports. However, the School Corporation failed to submit all six required reports. We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: The transition in the Corporation’s Business Manager position resulted in a failure to properly identify and train the person responsible for submitting final expenditure reports for ESSER grants. The Business Manager will prepare the final expenditure reports, and the Grant Specialist will review and compare the report to the ledger to verify that it is correct. After the review, the Business Manager will submit the final expenditures reports. Additionally, the Business Manager and Grant Specialist have developed a shared calendar that includes all report due dates. Anticipated Completion Date: This corrective action plan was implemented beginning February 2024 and will be implemented moving forward.

View Audit 295985

Finding 382246 (2023-003)

Material Weakness 2023

Plymouth Community School Corporation

IN

School Nutrition Programs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023 - 003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or de...

FINDING 2023 - 003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance over eligibility and suspension and debarment. We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: As part of month-end procedures and the documents sent to the Business Manager, the Food Services Director will include the list of students newly certified for free or reduced meals from CNPweb, Indiana’s portal for the Child Nutrition Program. The Food Services Director will also include the list of students newly certified for free or reduced meals from NutriKids. The Business Manager will review and verify the list when balancing the food program’s monthly receipts, expenditures, and reimbursements. Before contracts are awarded to vendors, the Food Services Director shall use SAM.gov to verify that vendors have not been suspended or disbarred from contracting with Indiana public schools. The Business Manager shall review and verify that the vendors have not been suspended or disbarred, and once verified, contracts will be awarded. Anticipated Completion Date: The Food Services Director and Business Manager have collaboratively reviewed and modified the month-end procedures to ensure that they prevent, detect, and correct eligibility errors, and the new procedures were implemented for February 2024 and will be used for subsequent months.

View Audit 295985

Finding 382243 (2023-005)

Material Weakness 2023

The University of Chicago

IL

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s w...

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s website. Implementation Date: March 6, 2024 Contact Person: Amanda Fijal

View Audit 295975

Finding 382241 (2023-003)

Material Weakness 2023

The University of Chicago

IL

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

Finding No. 2023-003: Failure to Notify Recipients of Federal Direct Loan Disbursement CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University added a monitoring report to identify any communication failures for disbursement notifications. Implementati...

Finding No. 2023-003: Failure to Notify Recipients of Federal Direct Loan Disbursement CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University added a monitoring report to identify any communication failures for disbursement notifications. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

View Audit 295975

Finding 382240 (2023-004)

Material Weakness 2023

The University of Chicago

IL

Reporting Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Finding No. 2023-004: Untimely and Inaccurate Reporting of Pell and FDL Data CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: A control will be added to loan set-up. Additional training was provided to staff monitoring loan reports. Implementation Date: June 10,...

Finding No. 2023-004: Untimely and Inaccurate Reporting of Pell and FDL Data CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: A control will be added to loan set-up. Additional training was provided to staff monitoring loan reports. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

View Audit 295975

Finding 381257 (2023-002)

Material Weakness 2023

The University of Chicago

IL

Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding No. 2023-002: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: As noted in the ﬁnding, in January 2024, the University conducted a full federal equipment inventory to update property records to ensure accuracy of fe...

Finding No. 2023-002: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: As noted in the ﬁnding, in January 2024, the University conducted a full federal equipment inventory to update property records to ensure accuracy of federally funded equipment. Process Improvements: - The University will update its Equipment Disposal Form to align with the University’s Property Management System Manual. - The Central Accounting team will create and publish equipment tagging, disposal guidance and standards to coincide with the updated Equipment Disposal Form. - Annual federal equipment inventory process will be updated to include escalation procedures. This will require outstanding reports are escalated to the appropriate divisional designee. Expected Implementation: June 30, 2024 Training: - All departments of the University will be sent a memo outlining the updated Equipment Disposal Form and process guide, and inventory escalation procedure. - The Central Accounting team will schedule virtual training with all equipment coordinators. Expected Implementation: October 31, 2024 System Improvement: - The University is researching equipment tagging software alternatives that will enhance tracking capabilities and enable asset tagging at a more granular level. Expected Implementation: March 31, 2025 Contact: Kathy Conrad and Craig Elmore

View Audit 295975

Finding 381233 (2023-004)

Significant Deficiency 2023

County of Orange, California

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency § 200.303

2023-004 Program: COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Federal Financial Assistance Listing Number: 93.391 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 2022 Com...

2023-004 Program: COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Federal Financial Assistance Listing Number: 93.391 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 2022 Compliance Requirements: Allowable Activities and Allowable Costs and Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the Health Care Agency’s (HCA) compliance with allowable activities and allowable costs and cost principles requirements, we noted for one (1) of forty-seven (47) transactions HCA did not retain evidence of the review and approval over the transaction. Cause: The transaction was with a specific vendor that requires orders to be placed on the vendor’s portal. At the time the order was placed, the vendor’s portal did not have a system control set up to require a separate approver for the order and HCA did not retain any other evidence to document the order’s review and approval. The vendor portal was later updated during the year to add the segregation of duties system control. Effect: The County’s control was not consistently followed, which requires transactions to be reviewed and approved by a separate individual prior to payment. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of forty-seven (47) of two hundred thirty-six (236) transactions were selected for HCA. The condition above was identified during our testwork of the HCA’s internal controls over allowable activities and allowable costs and cost principles. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of transactions are clearly documented prior payment. Management Response and Corrective Action: Health Care Agency: 1. Person Responsible: Hieu Nguyen, HCA Office of Population Health and Equity Director 2. Corrective Action Plan: HCA Office of Population Health and Equity will implement procedures that ensure review/approval of the e-commerce transactions are documented prior to payment. 3. Anticipated Implementation Date: April 1, 2024

View Audit 295958

Finding 381232 (2023-003)

Significant Deficiency 2023

County of Orange, California

CA

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

2023-003 Program: COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health and Healthcare Crises Federal Financial Assistance Listing Number: 93.391 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 2022 Co...

2023-003 Program: COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health and Healthcare Crises Federal Financial Assistance Listing Number: 93.391 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the Health Care Agency’s (HCA) compliance with reporting requirements, we noted for four (4) of four (4) reports the department did not retain evidence of the review and approval over the performance report. Cause: HCA personnel prepared program required performance reports and submitted the reports without retaining documented evidence that the reports were reviewed and approved by a separate individual prior to submission. Effect: The County did not document their review and approval of the report. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of four (4) reports were selected for reporting testwork from HCA. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA to implement policies that ensure the review and approval of reports are clearly documented prior to the report’s submission. Management Response and Corrective Action: Health Care Agency: 1. Person Responsible: Hieu Nguyen, HCA Office of Population Health and Equity Director 2. Corrective Action Plan: HCA Office of Population Health and Equity will implement procedures that ensure review/approval prior to report submission to the Center for Disease Prevention and Control. 3. Anticipated Implementation Date: April 1, 2024

View Audit 295958

Finding 381230 (2023-001)

Significant Deficiency 2023

Whittier College

CA

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

The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally was not in compliance. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whitti...

The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally was not in compliance. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whittier College Financial Aid Office has calendared a monthly reconciliation report to be sent to the Accounting Department to meet the guidelines set forth by the Department of Education. This reconciliation report will be sent monthly through out the calendar year. In the summer months of June and July we may not have any funds to reconcile, however, a report will be sent regardless for compliance. Person Responsible: Jesse Marquez, Associate Director and Information Specialist of Financial Aid Anticipated Completion Date: Implemented as of September 2023

View Audit 295948

Finding 381228 (2023-003)

Significant Deficiency 2023

Whittier College

CA

Student Financial Aid Reporting Significant Deficiency

The Office of the Registrar concurs with the audit finding of delayed reporting which noted that while there is now a process to submit enrollment and graduation information to NSLDS in a timely manner, the team noticed that three students’ information was not reported to NSLDS within the 60 days re...

The Office of the Registrar concurs with the audit finding of delayed reporting which noted that while there is now a process to submit enrollment and graduation information to NSLDS in a timely manner, the team noticed that three students’ information was not reported to NSLDS within the 60 days required to transmit status change. Due to staffing changes and challenges, Whittier College failed to meet the reporting window indicated in the NSLDS November 2022 Enrollment Reporting Guide, which states, “At a minimum, schools are required to certify enrollment [status change] every 60 days[.]” As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance. Person Responsible: Brianna Mendez, Student Data Specialist, Office of the Registrar Anticipated Completion Date: Implemented as of September 2023

View Audit 295948

Finding 381227 (2023-005)

Significant Deficiency 2023

Municipality of Vega Baja

PR

Matching / Level of Effort / Earmarking 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 Fiscal Year: 2022-2023 Principal Exe...

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. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2023-005 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The implementation of the Corrective Action Plan 2023-004 will ensure that complete reports are submitted for the validation of the compliance with this finding. Additionally, we will analyze our approved budget by ACUDEN to meet supplemental the terms and conditions of the Child Care and Development Fund Program. Implementation Date: Fiscal Year 2023-2024. Responsible Person: José A. Mathews Maisonet Accountant

View Audit 295939

Finding 381224 (2023-003)

Significant Deficiency 2023

Municipality of Vega Baja

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.328 § 200.329

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 Exe...

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. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2023-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The QPR Reports for the months from January to March 2023, were completed by the previous POC Recovery Office. We understand that expenses were reported in the QPR on the date when the certification with the contractor´s invoice was received at the Secretary of Engineering and Conservation of Infrastructure and not on the date of payment or disbursement of the invoice. For example, if the invoice was received in the month of February, the expense was recorded in the QPR from January to March even though it was not paid until the month of April. We are verifying each project reported in the QPR against the amount reported at the SIMA System. We expect to have updated and correct information for all the Quarterly Progress Reports for the period from January to March 2024. Implementation Date: Fiscal Year 2023-2024. Responsible Person: Dafne L. Claudio Sánchez Accountant

View Audit 295939

Finding 381210 (2023-002)

Significant Deficiency 2023

San Diego Community College District

CA

Student Financial Aid Reporting Significant Deficiency

We concur. The enrollment file reported to NSLDS is submitted on behalf of the District by the National Student Clearinghouse (NSC). Contact will be made to ensure NSC accurately reports these entries on our behalf.

View Audit 295932

Finding 381202 (2023-003)

Material Weakness 2023

Borden-Henryville School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Yea...

FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY22, SY23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP), Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness Condition and Context The School Corporation had not established effective internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. Eligibility The School Corporation's policy is to have the Treasurer review and initial paper applications processed by the individual school treasurers to ensure that the eligibility determination was correct. However, six of the ten applications tested lacked documentation of this review. In addition, there was no internal control in place over applications submitted online. INDIANA STATE BOARD OF ACCOUNTS 18 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Treasurer performed the verification of free and reduced price applications without a documented review or oversight process in place to ensure that applications selected for verification were in compliance with requirements related to the program. Special Tests and Provisions - Non-Profit School Food Service Accounts The School Corporation did not have an internal control in place to ensure that reimbursements for meals served were properly credited to the School Lunch fund. The lack of internal controls for Eligibility and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) was isolated to the second year of the audit period. The lack of internal controls over Special Tests and Provisions - School Food Accounts was systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 19 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

View Audit 295924

Finding 381194 (2023-002)

Material Weakness 2023

The Phalen Leadership Academy - Indiana, Inc.

MA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

Special Tests and Provisions Education Stabilization Fund: Assistance Listing No. 84.425 Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with a...

Special Tests and Provisions Education Stabilization Fund: Assistance Listing No. 84.425 Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PLA will train operations and business office staff on the compliance requirements under Davis-Bacon to ensure construction contracts are entered into with qualified contractors and obtain and retain appropriate certified payroll documentation during the construction period. Name(s) of the contact person(s) responsible for corrective action: Carlo Hershberger, Director of Finance and Accounting; Javier Dimas, Vice-President of Operations; Martha Arellano, Procurement Manager and Buyer Planned completion date for corrective action plan: April 1, 2024 If the United States Department of Education has questions regarding this plan, please call Eva Spilker, Chief Financial Officer, at 410-598-3087.

View Audit 295918 Questioned Costs: $1

Finding 381188 (2023-005)

Material Weakness 2023

Noblesville Schools

IN

Questioned Costs School Nutrition Programs Material Weakness § 200.303

FINDING 2023-005 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Req...

FINDING 2023-005 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness 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 Reporting compliance requirements. Context: During testing of reporting, we identified a control breakdown in the claim submission process. Although student meal data is summarized at the school level and reviewed by both the Food Services Bookkeeper and the Food Services Director, there is not a review of the actual claim submission prior to being submitted to the portal. Due to the breakdown in controls, we identified that the October 2022 revision claim overstated breakfasts served by 10 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Food Services will input the monthly claims into the state reporting system. This will be checked by the bookkeeper prior to submission to ensure data was entered correctly. Responsible Party and Timeline for Completion: Beginning January 2024

View Audit 295916 Questioned Costs: $1

Finding 381185 (2023-004)

Material Weakness 2023

Noblesville Schools

IN

School Nutrition Programs Eligibility Material Weakness § 200.303

FINDING 2023-004 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Req...

FINDING 2023-004 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness 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 Eligibility compliance requirements. Context: During testing of eligibility, we noted that a formal documented control for the review of online student applications was not in place. Management indicated that the free and reduced parameters are updated annually in the Titan system, however, there was no documented review that the updated parameters were reviewed. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will document a formal review of student applications for free/reduced lunch. Management will also document a review over the thresholds for free/reduced meals within the Titan system to ensure they accurately input into the system this will be done by way of signature on the state published eligibility guidelines. This will be kept for record keeping. Responsible Party and Timeline for Completion: Beginning July 2024

View Audit 295916

Finding 381182 (2023-003)

Material Weakness 2023

Noblesville Schools

IN

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

FINDING 2023-003 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Req...

FINDING 2023-003 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During our testing of the School Corporation’s compliance with the allowable costs requirements for CNC, we noted the following exceptions in our testing of 120 disbursements (60 vendor and 60 payroll): 1. The School Corporation paid $233 of sales tax across three vendor food purchases. 2. For two employee payroll selections, we were unable to trace their rate of pay to a Board approved wage rate ordinance or contract. The total amount paid out to the two employees was $2,635. FINDING 2023-003 (Continued) 3. We identified one employee that the School Corporation incorrectly paid one hour more than what the timecard stated, resulting in an overpayment of $14. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. All Food Service employee wages will align with the board approved rates. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

View Audit 295916 Questioned Costs: $1

Finding 381179 (2023-002)

Material Weakness 2023

Noblesville Schools

IN

Allowable Costs / Cost Principles School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303 § 200.403

FINDING 2023-002 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Req...

FINDING 2023-002 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During testing of vendor disbursements for the CNC program, we identified 9 disbursements in a sample of 60, for which there was no evidence of a formal documented review of the disbursement taking place prior to the disbursement. Additionally, during testing of CNC payroll disbursements, we selected 8 pay periods for controls testing and noted that none of the 8 pay periods had proof of a formal review of the payroll distribution prior to remittance. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

View Audit 295916

Finding 381157 (2023-003)

Significant Deficiency 2023

Catholic Charities, Archdiocese of San Antonio, Inc.

TX

Procurement, Suspension & Debarment Reporting Significant Deficiency § 200.303

Criteria: 2 CFR Section 200.303 of the Uniform Guidance requires the non-Federal entity to establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regul...

Criteria: 2 CFR Section 200.303 of the Uniform Guidance requires the non-Federal entity to establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: During testing of credit card purchases, we noted that supervisor approvals of expense reports were not timely obtained. Cause: Lack of timely review of credit card expense reports and transactions by supervisors for approval. Agency Response: Program directors/approvers of expense reports must go in by the 5th of the month after month end to approve/reject all employee expense reports assigned to them. The Financial Data Clerk will go in by the 6th of the month note the staff who has not approved their expense reports. The clerk will then communicate with the Director of Finance who in turn will send notification to the staff who is listed as approver. Once the staff is notified they will be given a 48 hour turn around to approve/reject, in the event they do not comply disciplinary action will be taken. After the 48 hours if report is not approved, Finance leadership will go into the system and review the report for approval or rejection. Responsible parties will be Alejandra Nunez, Financial Data Clerk and Lisette DeLeon, CFO, Cynthia Timm, Director of Finance, and Program designated expense report approvers. This will be implemented by February 2024.

View Audit 295879

Corrective Action Plans

Filters