Corrective Action Plans

Finding 382414 (2023-036)

Significant Deficiency 2023

State of Nebraska

NE

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Eligibility Corrective Action Plan: The Agency is working on a new process to ensure that only eligible claims are charged to the Federal grant. Contact: Snita Soni, Will Varicak Anticipated Completion Date: ...

Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Eligibility Corrective Action Plan: The Agency is working on a new process to ensure that only eligible claims are charged to the Federal grant. Contact: Snita Soni, Will Varicak Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382405 (2023-034)

None 2023

State of Nebraska

NE

Questioned Costs Matching / Level of Effort / Earmarking Reporting

Program: AL 93.069 – Public Health Emergency Preparedness (PHEP); AL 93.889 – National Bioterrorism Hospital Preparedness Program (HPP) – Matching and Reporting Corrective Action Plan: The agency will ensure total reported match is substantiated by source documentation. In addition, DHHS will wor...

Program: AL 93.069 – Public Health Emergency Preparedness (PHEP); AL 93.889 – National Bioterrorism Hospital Preparedness Program (HPP) – Matching and Reporting Corrective Action Plan: The agency will ensure total reported match is substantiated by source documentation. In addition, DHHS will work with Federal Partners to make necessary reporting adjustments to the IDC rate used. Contact: Ryan Daly, Lisa Osborne, Ann Murphy Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382403 (2023-028)

Significant Deficiency 2023

State of Nebraska

NE

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: We are constantly reviewing policy and procedures to ensure internal controls are in compliance with federal r...

Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: We are constantly reviewing policy and procedures to ensure internal controls are in compliance with federal regulations. All contracts pass a legal and fiscal review prior to finalizing the agreement. If fiscal reviewer believes the nature of the agreement casts the entity as a subrecipient, then the fiscal reviewer will ask the agreement owner seeking review to further identify if the agreement is a contractor or subrecipient determination based on 2 CFR Chapter I, Chapter II, Part 200 et al. If determined a subrecipient agreement, then further information will be collected from the agreement owner to be incorporated into the agreement and made available for FFATA and fiscal monitoring purposes. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: 7/1/2024

View Audit 296116

Finding 382396 (2023-057)

Significant Deficiency 2023

State of Nebraska

NE

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.305 § 200.511

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency will increase continued trend analysis efforts and shift functional responsibilities back to the State Services Support Division for more detailed...

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency will increase continued trend analysis efforts and shift functional responsibilities back to the State Services Support Division for more detailed oversight moving forward now that vacancies have been filled. The Agency will explore the feasibility of increased frequency of funding requests to decrease the amount of time between the Federal draw and the disbursement of funds by the State. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

View Audit 296116

Finding 382389 (2023-032)

None 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403 § 200.405

Program: AL 93.658 – Foster Care Title IV-E; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.659 – Adoption Assistance – Allowable Costs/Cost Principles Corrective Action Plan: DHHS will assign RMTS Administrator rolls to Program staff to ...

Program: AL 93.658 – Foster Care Title IV-E; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.659 – Adoption Assistance – Allowable Costs/Cost Principles Corrective Action Plan: DHHS will assign RMTS Administrator rolls to Program staff to better monitor the RMTS process. Contact: Patrick Werner Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382387 (2023-001)

Significant Deficiency 2023

Dave Purchase Project

WA

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

In response to audit finding 2023-001, Dave Purchase Project will immediately implement the following corrective actions: • DPP will review all current employee files by 03.08.2023 to ensure that a background check has been completed and evidence of the check is present in each employee file; • All ...

In response to audit finding 2023-001, Dave Purchase Project will immediately implement the following corrective actions: • DPP will review all current employee files by 03.08.2023 to ensure that a background check has been completed and evidence of the check is present in each employee file; • All current staff will have a new background check run and placed in their file: • All new hires/volunteers/interns will have a background check conducted on their first day of employment/volunteering/internship, while they fill out their new hire/volunteer/internship paperwork;No new staff/volunteers/interns will be deployed to their work site until the check has been completed, and; • any background check findings are satisfactorily addressed; • their paperwork is appropriately filed; No new staff/volunteers/interns will be deployed if background check findings conflict with federal requirements regarding employment i.e ., OIG is required by law to exclude from participation in all Federal health care programs individuals and entities convicted of the following types of criminal offenses: Medicare or Medicaid fraud, as well as any other offenses related to the delivery of items or services under Medicare, Medicaid, SCHIP, or other State health care programs; patient abuse or neglect; felony convictions for other health care - related fraud, theft, or other financial misconduct; and felony convictions relating to unlawful manufacture, distribution, prescription , or dispensing of controlled substances; • Every January all current DPP staff will have an updated background check completed and evidence of such placed in their employee file

View Audit 296113

Finding 382380 (2023-001)

None 2023

Universidad Interamericana De Puerto Rico, Inc.

PR

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Corrective Action Plan The Inter American University of Puerto Rico (IAUPR) will implement the following actions to strengthen compliance with the 30-day reglementary period for the R2T4 determination: 1. IAUPR will also prepare compulsory online or face-to-face training sessions which all full an...

Corrective Action Plan The Inter American University of Puerto Rico (IAUPR) will implement the following actions to strengthen compliance with the 30-day reglementary period for the R2T4 determination: 1. IAUPR will also prepare compulsory online or face-to-face training sessions which all full and part-time faculty will be required to take in August and January of each year. The training sessions will review grading policies and any other procedures required for compliance with Federal Regulations. The primary executives of each academic unit, through the Deans of Academic Affairs, will be responsible for ensuring and certifying to the Vice President of Academic and Student Affairs that all faculty participated in the training. 2. The Deans of Academic Affairs or their designees at each academic unit will monitor the entry of final grades in the Banner System and report any suspicious grades and suspected cases of noncompliance with Federal Regulations to the chairs of the academic departments for immediate follow-up and correction. 3. IAUPR will develop a course of action whereby a department chair or dean of academic affairs may correct or update a grade in the Banner System, based on the academic information available, when a faculty member is unable to do so because of a force majeure. 4. In recurrent cases of noncompliance, the primary executives of each academic unit will send a written communication to faculty that do not comply with established procedures and include a copy of the communication in the professors' academic/administrative files.

View Audit 296084

Finding 382362 (2023-001)

None 2023

Seton Hill University

PA

Student Financial Aid Eligibility Material Weakness § 200.516

Finding 2023-001: Student Financial Assistance Cluster, Department of Education Programs Program Name: Federal Direct Student Loans CFDA Numbers: 84.268 Corrective Action Plan: The University will update written procedures to clearly identify a step to manually do enrollment testing following all c...

Finding 2023-001: Student Financial Assistance Cluster, Department of Education Programs Program Name: Federal Direct Student Loans CFDA Numbers: 84.268 Corrective Action Plan: The University will update written procedures to clearly identify a step to manually do enrollment testing following all conferral of degrees. For those regularly scheduled graduation periods and following the submission of both the degree and last of term enrollment files, we will randomly sample 10% of graduated students and manually verify their statuses. For degrees conferred outside of the regularly scheduled graduation periods, each record will be manually verified. This will ensure recorded graduation records will be verified within the National Student Clearinghouse to ensure alignment between degree history and enrollment history. The error was found to be a bug in the reporting software that happened in the current fiscal year. The University’s processes in previous years were correct as this error was not present. Completion Date: Estimated March 2024

View Audit 296043

Finding 382357 (2023-008)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal A...

FINDING 2023-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. Context: The School Corporation had not designed, nor implemented a system of internal control to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling $4,000,000 was paid from the Education Stabilization Fund grant funds during the audit period. The single contract was tested and it did not contain the required prevailing wage rate clause. Additionally, certified payrolls were not obtained until after the School Corporation was issued an ESSER Construction Monitoring Report in late 2023. The School Corporation only obtained "sample" of certified payrolls and did not obtain all of the certified payrolls for the work performed within the grant period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Officer and Grant Director will ensure that all future construction contracts contain the prevailing wage rate clause required by the program. Additionally, the Chief Financial Officer will review and approve all certified payrolls and compliance statements submitted by contractors and subcontractors in order to ensure compliance with the program. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382353 (2023-006)

Material Weakness 2023

Lake Ridge Schools

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.303

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Numbe...

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Bajmakovich, Principal Calumet HS Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cbajmakovich@lakeridgeschools.net Condition: 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 Annual Report Card, High School Graduation compliance requirement. Context: One individual was involved in collecting the High School student documentation for withdrawal, reviewing the documentation, and removing the student from the cohort. Other review of knowledgeable individual was not documented to ensure all students that were removed from the graduation cohort, had the appropriate documentation to do so. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The high school principal shall review and approve withdrawal documentation collected by the registrar prior to the removal of the student from the graduation cohort. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382351 (2023-005)

Material Weakness 2023

Lake Ridge Schools

IN

Internal Control / Segregation of Duties Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numb...

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numbers: S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Regin Johnson, Title I Director Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net Condition: This finding addresses two issues. First, an effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Second, The School Corporation has established a process of receiving and reviewing the listing of students from the Private Schools in order to be entered into the Title I application. However, the internal controls were determined not effective since the School Corporation only requested to receive eligible students listing and not enrolled students. Context: The School Corporation has not established a process of review of the Eligibility Summary in the Title I application for the student enrollment and poverty. Real time report October 1 count is used for the eligibility summary in the Title I application. Additionally, the examiner could not determine if the enrolled private school number was correct because the School Corporation did not request the information. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will review and sign off on the Real Time October 1 report to ensure that the student enrollment and poverty numbers reconcile with what is submitted in the Eligibility Summary. Additionally, the Title I Director will solicit both eligible and total enrollment figures from private schools that wish to participate in Title I. Anticipated Completion Date: The Corrective Action will be implemented immediately and completed upon the filing of the next Real Time report and Eligibility Summary.

View Audit 296034

Finding 382343 (2023-004)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistanc...

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Chris Akers, Treasurer Contact Phone Number and Email Address: (219) 838-1819 cakers@lakeridgeschools.net Condition: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the monthly sponsor claim for reimbursement. Context: School Food Authority’s (SFA) and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. The Food Service Management Company employed Food Service Director prepared the monthly claim for reimbursement on the Indiana Department of Education Child Nutrition Program website based on meal count reports from the point-of-sale system. The School Corporation did not implement a system of internal control to ensure what was claimed for reimbursement agreed to the point-of-sale system meal count reports. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Before the monthly claim for reimbursement is submitted by the FSMC, the Treasurer will reconcile the claim with the meal count report generated by the point-of-sale system. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382322 (2023-004)

Material Weakness 2023

Board of Education Baltimore County

MD

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – ...

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24) 211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22) 221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22) Compliance Requirement: Special Test Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation to support student withdrawals and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BCPS conducts regular training with the school-based staff that maintain this related student documentation. The training will include updates on collecting and maintaining written documentation to meet the requirements for removing a student form the cohort. Name(s) of the contact person(s) responsible for corrective action: Dr. Kim Ferguson, Executive Director of Student Support Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382316 (2023-003)

Significant Deficiency 2023

Board of Education Baltimore County

MD

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

Finding Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – ...

Finding Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24) 211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22) 221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22) Compliance Requirement: Special Test Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board revises the Student Participation process to include a step that includes matching the student grade level to the corresponding school type and a step to include a second review of the Title I School eligibility address and school type by a second staff member. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BCPS revised their procedures on Title I Equitable Services: Student Participation in early Fall 2023. Revisions outlined below will lessen the risk of potential audit findings in the future: - Revise the Student Participation process to include a step that includes matching the student grade level to the corresponding public school type. - Revise the Student Participation Process to include a second review of the Title I School eligibility address and school type by a second staff member. Name(s) of the contact person(s) responsible for corrective action: Michele Stansbury, Director of Title I Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382283 (2023-004)

Material Weakness 2023

Ascension Health Alliance D/b/a Ascension

MO

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

Finding 2023-004 – Reporting Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services A...

Finding 2023-004 – Reporting Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA000420 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, Ascension will reinforce the importance to management of oversight and accountability of oversight and accountability to submit required reports. Responsible Official: July Turley, Director of Accounting and Reporting; Rob Madsen, Director of Accounting and Reporting Anticipated completion date: May 31, 2024

View Audit 295994

Finding 382282 (2023-002)

Material Weakness 2023

Ascension Health Alliance D/b/a Ascension

MO

Allowable Costs / Cost Principles Cash Management Period of Performance

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

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

View Audit 295994

Finding 382277 (2023-002)

Significant Deficiency 2023

Bowling Green Independent School District

KY

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

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

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

View Audit 295993

Finding 382274 (2023-002)

None 2023

Landmark College, INC

VT

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

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

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

View Audit 295992

Finding 382273 (2023-004)

Material Weakness 2023

Rensselaer Central School Corporation

IN

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

Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entit...

Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the corrective action plan which will be implemented by June 30, 2024.

View Audit 295986

Finding 382265 (2023-003)

Material Weakness 2023

Rensselaer Central School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

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

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

View Audit 295986

Finding 382253 (2023-004)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

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

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

View Audit 295985

Finding 382246 (2023-003)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

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

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

View Audit 295985

Finding 382243 (2023-005)

Material Weakness 2023

The University of Chicago

IL

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

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

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

View Audit 295975

Finding 382241 (2023-003)

Material Weakness 2023

The University of Chicago

IL

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

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

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

View Audit 295975

Finding 382240 (2023-004)

Material Weakness 2023

The University of Chicago

IL

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

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

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

View Audit 295975

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