Corrective Action Plans

Finding 382928 (2023-021)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly bas...

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly basis for all active grants. The OOG will ensure accuracy of Agency submissions by reconciling data between the eGrants Financial Status Reports (FSRs) and the Reconcilers. Should a variance exist, the OOG will document any changes made, and the reason therefore, with concurrence from the Agency. The OOG will update the reporting processes and institute new internal controls. For each reporting period, the ARPA Reporting Administrator will take the quarterly data provided for each grant and reconcile that information with the eGrants FSR data. The Public Safety Office (PSO) Grants Administration Director will verify the data. The PSO Executive Director will review and Administration Director will approve the reporting information prior to submission in to the ARPA Portal. Prior to final submission, the data will receive a quality assurance check. Implementation date: Full implementation by April 1, 2024 Responsible persons: Suzanne Johnson, Director of Administration and Aimee Snoddy, Executive Director Public Safety Office

View Audit 296491

Finding 382927 (2023-020)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

Corrective action plan: The Office of the Governor, Public Safety Office (PSO) has Policy 8.60 User Accounts that includes the periodic review of internal and external users in eGrants every six (6) months. This eGrants User Account Review is the responsibility of the PSO eGrants Help Desk. In Novem...

Corrective action plan: The Office of the Governor, Public Safety Office (PSO) has Policy 8.60 User Accounts that includes the periodic review of internal and external users in eGrants every six (6) months. This eGrants User Account Review is the responsibility of the PSO eGrants Help Desk. In November 2022, the lead System Support Specialist for the PSO retired from state service with over 20 years of service to the OOG. Due to her knowledge of the eGrants system, she was assigned the responsibility of completing the eGrants User Access Review; and, prior to her departure she completed a review that covered the January – June 2022 review period. After her departure, the eGrants User Access Review responsibility was assigned to the eGrants Help Desk but was not placed on the Master Tasklist used by the Desk to track compliance and reporting deadlines. This led to the July – December 2022 User Access Review not being completed. To ensure the eGrants User Access Review is completed in a timely manner and in accordance with our internal policy, this task has been added to the PSO Master Tasklist with a due date of July 31 for the January – June review period and January 31 for the July – December review period. In December 2023, the eGrants Help Desk completed the January 2023 – June 2023 user account review; the July 2023 – December 2023 review was completed on February 1, 2024. In December 2023 the PSO’s Grants Administration Director trained two PSO Help Desk staff on the User Account Review processes to mitigate issues with staff vacancies. This task will be monitored by the PSO’s Grants Administration Director. Implementation date: December 18, 2023 Responsible persons: Angie Martin, Public Safety Office Grants Administration Director, and Public Safety Office eGrants Help Desk Staff

View Audit 296491

Finding 382926 (2023-019)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

Corrective action plan: The OOG updated and documented the Change Management Procedures for Portal systems for all Portals subsequent to TTIR. The OOG began using Super Clio (the internally developed Change Management tracking system) for new projects and Portals, subsequent to TTIR, in accordance w...

Corrective action plan: The OOG updated and documented the Change Management Procedures for Portal systems for all Portals subsequent to TTIR. The OOG began using Super Clio (the internally developed Change Management tracking system) for new projects and Portals, subsequent to TTIR, in accordance with the new Change Management Procedure. Please see attached Change Management Procedure for OOG Information Services Division Portal systems. TTIR is a portal system that was created for a limited purpose and will decommission in the summer of 2024. The OOG will include the TTIR decommissioning project under the Change Management Procedure and mandate use of Super Clio. OOG Management does not anticipate further changes will be done to TTIR code, hotfixes applied, or content changes will be made. Any exceptions to this will be documented, approved, and signed by Management and put in the TTIR Program file for future evidence. Implementation date: Full implementation March 1, 2024 Responsible persons: Suzanne Johnson, Director of Administration, and Lars Hjaltman, Director of Information Services Division

View Audit 296491

Finding 382924 (2023-028)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will...

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will not only receive reports on totals for each budget, obligation, and expenditure field, but will also require the submission of backup documentation from the sending party. This additional step ensures that the team can independently verify the accuracy of reported figures. Furthermore, DRT will check the calculations within the backup documentation to confirm that the aggregate amounts align with the reported figures. These measures are designed to ensure that the HAF program's reporting is both accurate and reflective of activities. Implementation date: February 12, 2024 Responsible persons: David Johnson, HAF/TRR Data and Reporting Manager; Lizet Hinojosa, Director of HAF; Grace Timmons, Assistant Director of HAF; Lanette Johndrow, Director of HAF Subrecipient Activities; and Teri- Ann Parise, HAF Financial Analyst. Corrective action plan: For legal and counseling services, a report has been created that pulls all costs from the Housing Contract System and separates the data by Intake, Housing and Legal to allow for an appropriate report of all costs. This report is to be run weekly and updated by the Director of HAF Subrecipients, and then given to the finance department to verify against paid invoices for validation. Any discrepancies are to be discussed immediately and resolved. Implementation date: July 17, 2023 Responsible persons: Lanette Johndrow, Director of HAF Subrecipient Activities; Teri-Ann Parise, HAF Financial Analyst; and Mariah Tamayo, Financial Analyst

View Audit 296491

Finding 382923 (2023-027)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: Yardi and AmeriNat Case auditors and supervisors have been reminded that the original loan amount and origination date must be verified before approving a case. The CDF portal should have these columns completed. If the CDF does not include the original loan amount and origin...

Corrective action plan: Yardi and AmeriNat Case auditors and supervisors have been reminded that the original loan amount and origination date must be verified before approving a case. The CDF portal should have these columns completed. If the CDF does not include the original loan amount and origination date, case auditors will ask the loan servicer for a corrected record which includes the original loan amount and origination date in order to confirm conforming loan limits. For non-traditional loan servicers, a deed of trust or settlement statement will continue to be requested from the homeowner. As it relates to the specific case in question, the Reinstatement (R program) plus Monthly Payment Assistance (U Program) case was originally a HAF Contribution to Modification case (P Program.) The case was transferred from the P Program to the R Program on 8/23/2022 and due to a technical issue, the Yardi portal did not add the U Program to the existing R Program. On 1/17/2024, the U Program was manually added to the R Program and payment was made to the homeowner’s loan servicer for the three additional monthly payments. Implementation date: January 17, 2024 Responsible persons: Lizet Hinojosa, Director of HAF and Grace Timmons, Assistant Director of HAF

View Audit 296491

Finding 382922 (2023-026)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Special Tests & Provisions Allowable Costs / Cost Principles § 200.302 § 200.303

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corre...

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corrected. Implementation date: March 31, 2024 Responsible person: David Johnson, HAF/TRR Data & Reporting Manager

View Audit 296491

Finding 382919 (2023-023)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and...

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. TDA FND provided correspondence emails and incident reports documentation with screenshots for the FSRS technical issues to CLA:  CNC_NSLP grant: TDA FND informed CLA auditors that agency has been experiencing significant technical difficulties uploading the FFATA data into FSRS. During these attempts, the system shows the following error message: "Sub-awardee Awardee Address - Congressional District could not be validated/matched from the provided address and zip+4." Unfortunately, this occurred on numerous uploads (300-400) every time an attempt was made. As a disclaimer, a single error will prevent an entire report from being uploaded into the system. TDA FND staff has contacted the FSRS helpdesk many times to no avail, resulting in reports not being uploaded and causing TDA FND to be behind on the FFATA reporting.  FFVP grant: TDA allocates FFVP funds to CEs during two periods of operation. If CEs do not spend the funds, then TDA must either (1) reallocate or (2) let the funds lapse and return to USDA. Considering the nature of the grant allocation and USDA requirements of maximizing grant spending to benefit schools during this process, it might cause a discrepancy between what was reported on the FFATA report and what was adjusted after the fact. As of today, the system error continues to occur with TDA FND staff having little to no control over it. TDA would like to emphasize that the help desk process with FSRS is not expedient and would cause the loss of employee productivity if the burden to remedy the systems issues (beyond recording unsuccessful attempts) was delegated to the state. TDA FND staff will continue to prepare the reports and attempt to submit them as required. TDA FND Staff will document instances where the upload is unsuccessful. CDBG – TDA will ensure that all FFATA reports are submitted timely. For CDBG, program staff has implemented procedures to ensure that FFATA reports are prepared, reviewed by the Director of CDBG Programs, and submitted on a monthly basis. Implementation dates: CDBG: January 2024 CNC: March 1, 2024 Responsible persons: CDBG: Suzanne Barnard, Director for CDBG Programs CNC: Anwar Sophy, Administrator, TDA FND Business Management

View Audit 296491

Finding 382918 (2023-022)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

HUD Housing Programs Reporting Significant Deficiency § 200.303

Corrective action plan: TDA has completed the noted adjustments and submitted a corrected PR-28 for Program Year 2022 to HUD. Implementation date: February 1, 2024 Responsible person: Suzanne Barnard, Director for CDBG Programs

View Audit 296491

Finding 382916 (2023-006)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Corrective action plan: The GLO will review the process and task notes templates to correct the language to ensure it differentiates between those that have TIGR access and those that do not, and properly reflects what was reviewed and completed with an offboarding request. In addition, the GLO will...

Corrective action plan: The GLO will review the process and task notes templates to correct the language to ensure it differentiates between those that have TIGR access and those that do not, and properly reflects what was reviewed and completed with an offboarding request. In addition, the GLO will review the account de-provisioning process in place to determine if it can be improved to address the account access that was available after this individual left the agency. The GLO will implement a semi-annual manual or automated account review process to identify accounts for former employees who were not properly disabled with their departure from the agency. This process will be documented as part of our overall user access review processes. Implementation date: May 15, 2024 Responsible persons: Robert Eason, Deputy Director, CDR, Pamela Mathews, Director Program Integration, CDR, Brad Kaufman, Senior Director of IT Operations.

View Audit 296491

Finding 382915 (2023-005)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Corrective action plan: The GLO will update the Active Directory password policy for GLOAD domain users to align it to the agency password policy as defined in GLO Identification and Authentication policy. We are unable to add the same password policy complexity and lockout settings to the on-premis...

Corrective action plan: The GLO will update the Active Directory password policy for GLOAD domain users to align it to the agency password policy as defined in GLO Identification and Authentication policy. We are unable to add the same password policy complexity and lockout settings to the on-premises, standalone MIP system as this software doesn’t provide that functionality. Implementation date: May 15, 2024 Responsible person: Brad Kaufman, Senior Director of IT Operations.

View Audit 296491

Finding 382913 (2023-009)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: The General Ledger Cost Allocation and Chartfield teams are currently fully staffed. An aggressive plan to complete FY 2023 reallocations and catch FY 2024 reallocations up to current (one federal quarter plus one month in arrears) is in place. Implementation date: August 31,...

Corrective action plan: The General Ledger Cost Allocation and Chartfield teams are currently fully staffed. An aggressive plan to complete FY 2023 reallocations and catch FY 2024 reallocations up to current (one federal quarter plus one month in arrears) is in place. Implementation date: August 31, 2024 Responsible person: Heather Nevill, Director, Fund Management

View Audit 296491 Questioned Costs: $1

Finding 382909 (2023-003)

Significant Deficiency 2023

Southern Oregon University

OR

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

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of Education when required....

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of Education when required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding. At the time of the audit, management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed in February 2024. Names of the contact persons responsible for corrective action: Agnes Maina Planned completion date for corrective action plan: Completed

View Audit 296487

Finding 382908 (2023-002)

Significant Deficiency 2023

Southern Oregon University

OR

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding as it was identified and rectified during an internal audit earlier this year. Effective Fall 2023 a new process is in place that incorporates all Title IV funding into the current stale-dated refund check process. The Bursar and the Student Financial aid office will closely monitor aging checks and reissue or return funds to the Department of Education. Names of the contact persons responsible for corrective action: Stephanie Hanigan and Karinda Decker Planned completion date for corrective action plan: Completed

View Audit 296487 Questioned Costs: $1

Finding 382907 (2023-001)

Significant Deficiency 2023

Southern Oregon University

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure ...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Action taken in response to finding: The Student Records Specialist will increase monitoring of Clearinghouse data. SOU will also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Issues that are identified will be communicated to the Director of Financial Aid and University Registrar for reconciliation. Name(s) of the contact person(s) responsible for corrective action: Karinda Decker and Matt Stillman Planned completion date for corrective action plan: Immediately

View Audit 296487

Finding 382903 (2023-001)

Material Weakness 2023

Plymouth-Shiloh Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Any contract/project that Plymouth-Shiloh Local School District receives or is awarded moving forward and it qualifies as needing to adhere to prevailing wage; Plymouth-Shiloh will contact our board attorney to create a contract that specifies compliance with the Davis-Beacon Act with the said contr...

Any contract/project that Plymouth-Shiloh Local School District receives or is awarded moving forward and it qualifies as needing to adhere to prevailing wage; Plymouth-Shiloh will contact our board attorney to create a contract that specifies compliance with the Davis-Beacon Act with the said contractor/company.

View Audit 296470

Finding 382888 (2023-002)

Material Weakness 2023

School Town of Speedway

IN

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

The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner....

The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner. Responsible party and timeline for completion: Superintendent and Director of Facilities; Information that was requested has been provided to the best of our ability. Future contracts will have required information provided during the project, and at the completion of the project.

View Audit 296461

Finding 382874 (2023-002)

Significant Deficiency 2023

Pennsylvania Institute of Technology and Subsidiaries

PA

Student Financial Aid Reporting Significant Deficiency

Finding 2023-002 – Enrollment Reporting – Significant Deficiency ALN Number: 84.063; 84.268 Federal Award Identification Number: P063P220616; P268K230616 Recommendation: It is recommended that the College have someone independent of the preparer review the NSLDS roster file to check the effective da...

Finding 2023-002 – Enrollment Reporting – Significant Deficiency ALN Number: 84.063; 84.268 Federal Award Identification Number: P063P220616; P268K230616 Recommendation: It is recommended that the College have someone independent of the preparer review the NSLDS roster file to check the effective date of change in status is in agreement with the College's records. Action Taken: Academic Records Office personnel were re-trained. Also, a report has been written to be run after the Student Status Confirmation Report (SSCR) procedure is run in the student financial aid system, that flags when a “Last Date of Attendance (LDA)” and NSLDS Withdrawal Date differ. Those cases can be troubleshooted and fixed, the SSCR rerun, and that updated file uploaded.

View Audit 296451

Finding 382873 (2023-001)

None 2023

Pennsylvania Institute of Technology and Subsidiaries

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2023-001 – Eligibility for Subsidized Direct Loans ALN Number: 84.268 Federal Award Identification Number: P268K230616 Recommendation: It is recommended that the College ensure that all EFC information from the ISIR is entered in to the student aid packaging system before the student aid awa...

Finding 2023-001 – Eligibility for Subsidized Direct Loans ALN Number: 84.268 Federal Award Identification Number: P268K230616 Recommendation: It is recommended that the College ensure that all EFC information from the ISIR is entered in to the student aid packaging system before the student aid award is calculated. Action Taken: In review of the student records, the student aid packaging system at the time of aid determination indicated an EFC of $0 and months and weeks in academic year being zero. However, the FASFA was completed and the ISIR EFC amount was known at the time of the packaging and loan issued due to the cost of attendance not calculating correctly at time of packaging. The student aid packaging system parameters ensure that if need amount is $0 the system will stop a subsidized direct loan from being awarded. The weeks and months in academic year information was corrected in their next term and a subsidized loan was not awarded. Error appears related to only their first loan issued. The allowance of subsidized loans was due to user error because the months and weeks enrolled in academic year were showing as zero. The College has re-trained its staff on the sequence of processing and ensure that inputs for months and weeks in academic year are correct. The College also worked with their student information system to ensure the set up for academic year definitions for cost of attendance calculations are set to be automatic for proper calculations. The College made an internal report in order to review all student financial need for the 2022-2023 academic year in February 2024 and determined there were no additional students awarded need based aid in excess of their financial need. The College will continue to use this report every term to review need. For the 2 students that received subsidized loans in error, their loans were refunded in March 2024.

View Audit 296451 Questioned Costs: $1

Finding 382872 (2023-003)

Material Weakness 2023

Northeast School Corporation

IN

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

Finding 2023-003 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...

Finding 2023-003 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: 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 obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $540,000 during the audit period on a construction project for the North Central High School Kitchen/Cafeteria remodel, which was charged to the ESSER III grant award (84.425U). The construction contract did 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 ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing ($254,377), we noted that labor costs totaled $55,299. The School Corporation did not receive the weekly payroll reports as required to ensure that pay rates complied with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. Treasurer will track future projects' labor cost. 1 - The Northeast School Corporation will ensure Davis Bacon rules are included in any RFP using federal funds. The treasurer will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

View Audit 296449

Finding 382869 (2023-004)

Material Weakness 2023

Northeast School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.328

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II),...

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II), and Elementary and Secondary School Emergency Relief (ESSER III) Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Number: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have a review control in place to ensure the annual data report was reviewed by someone other than the preparer and that the report was submitted timely. Context: The Annual Data Report for the period of July 1, 2021 to June 30, 2022 was due to the Indiana Department of Education (IDOE) by April 7, 2023. The School Corporation did not submit the report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will submit future reports in a timely manner. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer Effective for the 2023-2024 school year

View Audit 296449

Finding 382868 (2023-008)

Significant Deficiency 2023

Northeast School Corporation

IN

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

FINDING 2023-008 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: 22611-022-PN01 Pass-Through Entity: Indian...

FINDING 2023-008 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: 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 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 22611-022-PN01 grant award 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 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 22611-022-PN01 grant award. The minimum earmarking requirement for the 22611-022-PN01 grant award was $1,620. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Northeast 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: Mark A Baker, Superintendent Effective April 2024

View Audit 296449

Finding 382857 (2023-007)

Material Weakness 2023

Northeast 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 2023-007 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 Fe...

FINDING 2023-007 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: 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: Mark A Baker, Superintendent Effective April 2024

View Audit 296449

Finding 382835 (2023-005)

Material Weakness 2023

Northeast School Corporation

IN

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

FINDING 2023-005 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 Pre...

FINDING 2023-005 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: The Superintendent and Treasurer of Northeast School Corporation will review the documentation for the Cooperative at least semi-annually. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

View Audit 296449

Finding 382828 (2023-004)

Material Weakness 2023

North White 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: 84.425D, 84.425U Federal A...

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: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 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 $2,354,885 during the audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building which included labor installation costs subject to federal Davis Bacon wage rate requirements. Each project had a separate vendor for a total of two vendor contracts during the audit period subject to testing for Davis Bacon wage rate requirements. The vendor contracts did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. 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 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. For the period July 1, 2021 through June 30, 2023, $925,844 was disbursed related to these building projects and charged to the ESSER II grant award (84.425D). For the period July 1, 2021 through June 30, 2023, $1,429,041 was disbursed related to these building projects and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 80.1% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Corporation will make sure all contracts using federal dollars will have the Davis-Bacon clause written in the contract. The project manager will request weekly time sheets for all labor installation and verify the work has been completed. Responsible Party and Timeline for Completion: The Superintendent, Nicholas Eccles, will oversee the corrective action plan regarding the Davis-Bacon clause in future contracts which will be implemented by June 30, 2024. The Building/Maintenance Director, Dean Cook, will oversee the corrective action plan regarding the verification of time sheets for labor installation which will be implemented by June 30, 2024.

View Audit 296431

Finding 382799 (2023-003)

Material Weakness 2023

Nettle Creek School Corporation

IN

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

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement an...

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for ESSER II, Year 1, annual report tested the School Corporation could provide supporting documentation that did not agree with the ESSER II, Year 1, annual report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated from ESSER 1I, Year 1 report. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will prepare annual reports for grants and the Director of Learning and/or Superintendent will review and sign-off reports before submission. Anticipated Completion Date: June 30, 2024

View Audit 296407

Corrective Action Plans

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