Corrective Action Plans

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

Finding 383612 (2023-003)

Significant Deficiency 2023

Southwest School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Number...

FINDING 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Context: The School Corporation is a member of the Greene Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, 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 Matching, Level of Effort, Earmarking compliance requirement. Although the Cooperative has a separate object code to identify expenditures for the purpose of proportionate share, there is no identifier or separate way to track which member school the funding was expended for. As such, the Non-Public Proportionate Share expenditures for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards could not be verified for the individual member schools. Additionally, the Cooperative did not obtain a waiver from the Indiana Department of Education for the amount unspent for the requirement on the 19611-022-PN01 and 20611-022-PN01 grant awards. For the 21611-022-PN01 grant award, a waiver was obtained from the IDOE which was used to cover a portion of the member school's required proportionate share amount; however, the remaining amount, which the Cooperative claimed to have expended, could not be traced to documentation that indicated which member school the expenditure was applied to. For the 22611-022-PN01 grant award, no waiver was obtained, and the amounts spent could not be traced to documentation that indicated which member school the expenditure was applied to. Also, the total amount expended for proportionate share was less than the total amount required when all member school proportionate share requirements were totaled. The lack of internal controls and noncompliance were isolated to the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards. The minimum earmarking requirement for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards were $1,931, $3,486, $6,832, and $1,794, respectively. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Southwest School Corporation will establish a system of internal controls and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retailed for audit. 2 – Greene Sullivan Special Education Cooperative will require all staff to complete the appropriate google form following the completion of each session with Non-Public students. An example of this documentation is the Proportionate Share Service Log. This document will allow for ease of tracking funds per provider/school district. This will allow for successful usage of funds. In the event that funds are not successfully used, a waiver will be requested barring board approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent, April 1, 2024

View Audit 296662

Finding 383601 (2023-002)

Material Weakness 2023

Southwest School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Educ...

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance 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 Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. The lack of internal controls was a systemic issue 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 – All invoices, as well as receipts, will be documented upon receipt by the Director of Special Education at Greene Sullivan Special Education Cooperative. After this takes place, The Director of Finance at Greene Sullivan Special Education Cooperative will then create vouchers and receipts accordingly. Prior to submission, the Director of Special Education of Greene Sullivan Special Education Cooperative will verify all documents for accuracy. The Superintendent and Treasurer of Southwest School Corporation will review the documentation for the Cooperative at lease semi-annually. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

View Audit 296662

Finding 383587 (2023-003)

Significant Deficiency 2023

Nevada Community School District

IA

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

Response and Corrective Action Plan: The District will review current processes for grant reconciliation.

View Audit 296631

Finding 383557 (2023-003)

None 2023

Cairo School District No. 1

IL

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

Name of Contact Person: Ronald Ferrell, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: The auditors discussed the issue with the Dist...

Name of Contact Person: Ronald Ferrell, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: The auditors discussed the issue with the District, and the auditors will ensure timely submission for the 2023 fiscal year. Proposed Completion Date: Immediately.

View Audit 296611

Finding 383545 (2023-005)

Material Weakness 2023

Community Schools of Frankfort

IN

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

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact P...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

View Audit 296610

Finding 383533 (2023-003)

Material Weakness 2023

Community Schools of Frankfort

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-003 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to reporting. Contact Person Responsible for Corrective Action: Scott Weltz, Michelle Wolfe Contact Phone Numbe...

FINDING 2023-003 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to reporting. Contact Person Responsible for Corrective Action: Scott Weltz, Michelle Wolfe Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, wolfem@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

View Audit 296610

Finding 383526 (2023-003)

Significant Deficiency 2023

Royall School District

WI

Questioned Costs Subrecipient Monitoring Cash Management

2023-003 - #84.425U COVID-19 Elementary and Secondary School Emergency Relief Fund III Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-291673-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were Education Stabilizati...

2023-003 - #84.425U COVID-19 Elementary and Secondary School Emergency Relief Fund III Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-291673-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were Education Stabilization Fund construction projects performed by contractors. Grant expenditures for the projects paid by the Education Stabilization Fund totaled $556,368. There was not a prevailing wage clause in the contracts and certified payrolls were not received. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts, subject to wage rate requirements, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: The District was not aware that wage rate requirements applied to the construction projects. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $556,368 Auditor’s Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District has implemented additional procedures to ensure prevailing wage rate requirements are included in all contracts funded by federal programs. Contact Person: Mary Prielipp Anticipated Completion: June 30, 2024

View Audit 296603 Questioned Costs: $1

Finding 383525 (2023-001)

Material Weakness 2023

Rush Springs School District I-68

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Rush Springs Public Schools will develop internal controls to meet the requirements of the Davis-Bacon Act. The District will make sure that any federal awards used on construction projects are in compliance with the Act by not only including the prevailing wage clauses in the construction contract...

Rush Springs Public Schools will develop internal controls to meet the requirements of the Davis-Bacon Act. The District will make sure that any federal awards used on construction projects are in compliance with the Act by not only including the prevailing wage clauses in the construction contract , but also ensuring that federal wage rates and fringes are met. The District will ensure these wages are met by collecting and reviewing weekly certified payroll reports supplied by either the contractor or subcontractor. To ensure complance with the Davis-Bacon Act, Rush Springs Public Schools will post all required items at the work site. This Corrective Action Plan will be implemented immediately beginning on January 10, 2024.

View Audit 296600

Finding 383523 (2023-001)

Significant Deficiency 2023

Community College of Philadelphia

PA

Student Financial Aid Special Tests & Provisions Eligibility

Finding 2023-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Award Year: 2022-2023 Views of Responsible Officials and Planned Corrective Action: Responsible Of...

Finding 2023-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Award Year: 2022-2023 Views of Responsible Officials and Planned Corrective Action: Responsible Officials: Dr. Raye Thompson, Executive Director of Enrollment Management Operations and Compliance; Tarsha D. Washington Director, Office of Student Records and Registration Corrective Action: 1. The Associate Director of Academic Records will certify enrollment every 30 days to ensure timely submission to NSLDS. 2. The Associate Director of Academic Records will identify and resolve all errors identified by NSLDS, which will be resolved within ten days. 3. Winter graduates will be placed on a schedule to ensure timely submission and reporting to NSLDS. 4. The Associate Director of Academic Records will be responsible for completing all National Clearinghouse training and providing training to staff members involved in the reporting submission to ensure that all information is collected and reported promptly. 5. Regular internal audits will be scheduled and conducted to identify improvement areas to ensure enrollment reporting compliance. Individual Responsible for Corrective Action: Charletha C. Porter, Associate Director Academic Records Anticipated Completion Date for Corrective Action: Completed - Process corrected as of January 2024

View Audit 296598

Finding 383483 (2023-006)

Material Weakness 2023

State of Utah

UT

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

2023-006. Lack of Controls over Food Benefit Payments State Agency: Department of Health and Human Services Federal Agency: Department of Health and Human Services The Division of Family Health (DFH) will continue efforts to ensure proper management of the WIC program. The department and DFH will co...

2023-006. Lack of Controls over Food Benefit Payments State Agency: Department of Health and Human Services Federal Agency: Department of Health and Human Services The Division of Family Health (DFH) will continue efforts to ensure proper management of the WIC program. The department and DFH will consider possible improvements for managing third party food benefit redemptions. Contact Person: Mykio Saracino, Assistant Office Director, 385-228-4798 Anticipated Correction Date: December 31, 2024

View Audit 296545

Corrective Action Plans

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