Corrective Action Plans

Finding 382735 (2023-001)

Significant Deficiency 2023

MA

Responsible Official Judith Bricklin, Chief Financial Officer Plan Detail JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting t...

Responsible Official Judith Bricklin, Chief Financial Officer Plan Detail JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting this Federal requirement. In addition, JTEC communicated the issue to MDCS. JTEC has established a separate youth and testing center, designed to cater to the specific needs and preferences of youth participants. In addition to keeping in regular contact with school guidance departments and student support staff, JTEC’s youth counselor continues to connect with juvenile court and probation officers, and works with the department of transitional assistance young parent program staff to encourage referrals to JTEC’s youth programs. JTEC is running an aggressive schedule of digital marketing campaigns that target youth in our service delivery area. JTEC has contracted with various vendors for content and distribution of these campaigns. JTEC has also increased its youth work experience wage, and is in the process of revising its support services and incentives policy to make incentives for youth participation more appealing. Increasing awareness of the out of school youth services available, ensuring that the youth program design and implementation match the needs of youth in our area, and maintaining strong relationships in our referral networks is JTEC’s strategy to increase out of school youth enrollments and youth work experience participation. Anticipated Completion Date June 30, 2024

View Audit 296326

Finding 382733 (2023-001)

Significant Deficiency 2023

Fisher College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan To ensure complete and comprehensive National Student Loan Data System (“NSLDS”) reporting compliance as outlined in 34 CFR 685.309(b)(2) and in 2 CFR Part 200, Appendix XI Compliance Supplement, the College undertook a review of its trainings and procedures. Within that revie...

Corrective Action Plan To ensure complete and comprehensive National Student Loan Data System (“NSLDS”) reporting compliance as outlined in 34 CFR 685.309(b)(2) and in 2 CFR Part 200, Appendix XI Compliance Supplement, the College undertook a review of its trainings and procedures. Within that review, areas of inconsistencies were identified relative to status changes and timely reporting. Acknowledging that the current procedures were not adequate, the College has implemented additional trainings and reconciliation procedures, as recommended. Revised trainings to the College employees responsible for processing information for the NSLDS will henceforth include, but not be limited to, an annual review of both the NSLDS Enrollment Reporting Guide and the National Student Clearinghouse Enrollment Overview. Such trainings will emphasize the importance of reporting accuracy and timeliness. The College has also updated reconciliation procedures for enrollment reporting and added the implementation of a secondary review of monthly enrollment submissions by the Director of Title IV Compliance. Timeline for Implementation of Corrective Action Plan Effective immediately. Contact Person Colleen Woods, Director of Title IV Compliance

View Audit 296325

Finding 382732 (2023-001)

Material Weakness 2023

Cardington-Lincoln Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Comply with Davis-Bacon Act for Federal Projects. The district will incorporate contract wording in all future contracts that enforce the Davis-Bacon act requirements. Final payments for projects requiring this documenation will not be made until all parts of the contract are fulfilled.

View Audit 296323

Finding 382722 (2023-002)

Material Weakness 2023

Benton Community School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

FINDING 2023-002 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...

FINDING 2023-002 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 $24,977, $1,171, $22,088, and $866, 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 Planned Corrective Actions: Management agrees with the finding. The Cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportional Share earmarking requirement and validate the earmarking requirement is 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. Tracy Albertson, Director of Finance and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

View Audit 296321

Finding 382710 (2023-001)

Material Weakness 2023

Weatherford Independent School District No. 26

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

A copy of the Davis-Bacon Act requirement has been placed in the office of the federal program director. The director will be responsible for filling out the appropriate paperwrok before approving any federal funds to be used on projects that are classified as construction. The requirements of the...

A copy of the Davis-Bacon Act requirement has been placed in the office of the federal program director. The director will be responsible for filling out the appropriate paperwrok before approving any federal funds to be used on projects that are classified as construction. The requirements of the Davis-Bacon Act have also been shared with the Encumbrance Clerk and Treasurer for the purpose of checks and balances.

View Audit 296312

Finding 382708 (2023-002)

Material Weakness 2023

Ou Medicine, Inc.

OK

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Period of Performance

Corrective Action Plan Finding 2023-002 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA); Assistance Listing No. 97.036, Disaster Grants – P...

Corrective Action Plan Finding 2023-002 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA); Assistance Listing No. 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Condition: Per discussion with management, OU Medicine, Inc. has processes and internal controls in place to ensure personnel expenses submitted to the FEMA program were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the expenses to ensure the expenses comply with the terms and conditions of the award. However, management did not consistently retain documentation evidencing the performance of these controls. Corrective Action: As part of the Uniform Guidance audit, OU Health provides documentation to explain how eligible costs are/will be identified and submitted. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will develop a checklist to document the review and approval of supporting documentation of costs as reported as federal expenditures. The supporting documentation will be reviewed by management to ensure expenses charged to the federal program are allowable and have not been reimbursed under another federal program. The checklist and all correspondence will be retained with the report and within the Audit Folder. Responsible Official: Bernard Githinji, AVP – Corporate Controller Anticipated Completion Date: April 30, 2024

View Audit 296298

Finding 382707 (2023-003)

Material Weakness 2023

Ou Medicine, Inc.

OK

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Period of Performance

Corrective Action Plan Finding 2023-003 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA); Assistance Listing ...

Corrective Action Plan Finding 2023-003 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA); Assistance Listing No. 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions Condition: Per discussion with management, OU Medicine, Inc. has processes and internal controls in place to comply with the terms and conditions of the award and the reporting requirements. However, management did not retain documentation evidencing the performance of these controls. Corrective Action: At the beginning of the pandemic, OU Health created working groups to evaluate the requirements for COVID-19 funding received and ensure the funds were only used for allowable purposes. The working groups were assisted by outside consultants to stay updated on the reporting requirements as the continued to evolve. As part of the Uniform Guidance audit, OU Health provided documentation of the Provider Relief Fund review process that explained how eligible costs were identified and submitted. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will develop a checklist to document the review and approval of supporting documentation of contract labor costs as reported federal expenditures. The supporting documentation will be reviewed by management to ensure expenses charged to the federal program are allowable and have not been reimbursed under another federal program. The checklist will be retained with the existing report. Responsible Official: Bernard Githinji, AVP Corporate Controller Anticipated Completion Date: April 30, 2024

View Audit 296298

Finding 382706 (2023-001)

Material Weakness 2023

Ou Medicine, Inc.

OK

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Period of Performance

Corrective Action Plan Finding 2023-001 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: Department of the Treasury; Assistance Listing No. 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLRF) C...

Corrective Action Plan Finding 2023-001 Internal Control Deficiency Activities Allowed or Unallowed/Allowable Costs Identification of the federal program: Federal Grantor: Department of the Treasury; Assistance Listing No. 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLRF) Condition: Per discussion with management, OU Medicine, Inc. has processes and internal controls in place to ensure expenses submitted to the CSLFRF program were allowable expenses per the grant agreement These internal controls include ensuring completeness and accuracy of the expenses to ensure the expenses comply with the terms and conditions of the award. However, management did not consistently retain documentation evidencing the performance of these controls. Corrective Action: As part of the Uniform Guidance audit, OU Health provides documentation to explain how eligible costs are/will be identified and submitted. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will develop a checklist to document the review and approval of supporting documentation of costs as reported as federal expenditures. The supporting documentation will be reviewed by management to ensure expenses charged to the federal program are allowable and have not been reimbursed under another federal program. The checklist and all correspondence will be retained with the report and within the Audit Folder. Responsible Official: Bernard Githinji, AVP – Corporate Controller Anticipated Completion Date: April 30, 2024

View Audit 296298

Finding 382694 (2023-007)

Material Weakness 2023

Muncie Community Schools

IN

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-007 – Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirement Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We wil...

Finding 2023-007 – Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirement Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all construction projects using federal funding will meet the wage rate requirements. Anticipated Completion Date: March 2024

View Audit 296252

Finding 382689 (2023-006)

Material Weakness 2023

Muncie Community Schools

IN

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

Finding 2023-006 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate...

Finding 2023-006 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next ESSER reports due in FY24

View Audit 296252

Finding 382684 (2023-005)

Significant Deficiency 2023

Muncie Community Schools

IN

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

Finding 2023-005 – Title I Grants to Local Educational Agencies - Maintenance of Effort Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ex...

Finding 2023-005 – Title I Grants to Local Educational Agencies - Maintenance of Effort Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all expenses are recorded correctly and any capital items over the threshold are properly recorded to capital object codes. Anticipated Completion Date: March 2024

View Audit 296252

Finding 382651 (2023-001)

Significant Deficiency 2023

River Forest Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The Scho...

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The School Corporation did not have a proper system of oversight or review to ensure that all students on the direct certification match report were entered accurately into the point-of-sale system. We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the Eligibility compliance requirement Contact Person Responsible for Corrective Action: Nick Alessandri Contact Phone Number and Email Address: 219-962-7551 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: River Forest Community School Corporation is now part of the Community Eligibility Provision (CEP) and therefore the direct certification process will no longer take place. In the event that we are no longer CEP and begin the direct certification process, we will implement a process of internal controls that ensure proper oversight and review to ensure all students are entered accurately into our point-of-sale system. Anticipated Completion Date: July 1, 2023

View Audit 296243

Finding 382645 (2023-002)

Significant Deficiency 2023

San Joaquin Delta Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The Admissions & Records Department discovered that there was an error in our reporting. The issue is that the wrong field was being picked up by NSLDS because our report was not pulling the correct data field. This has been corrected by the District IT department. We also discovered that although w...

The Admissions & Records Department discovered that there was an error in our reporting. The issue is that the wrong field was being picked up by NSLDS because our report was not pulling the correct data field. This has been corrected by the District IT department. We also discovered that although we reported the correct data to the National Clearinghouse, it never transferred over to NSLDS. We will reach out to the Clearinghouse to ensure that this will not occur again. We also discovered that with one student enrollment issue, the college did not follow the correct process so that the report did not pick up the student enrollment. This has been resolved by providing staff with appropriate training. The director has and will continue to provide ongoing training.

View Audit 296241

Finding 382635 (2023-003)

Material Weakness 2023

West River Area Health Education Center

SD

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding No. 2023-003: Compliance Controls Responsible Individuals: Stephanie Mayfield, Executive Director Corrective Action Plan: The Organization is continuing to evaluate its internal control systems to ensure proper segregation of duties surrounding various compliance with grant programs. After t...

Finding No. 2023-003: Compliance Controls Responsible Individuals: Stephanie Mayfield, Executive Director Corrective Action Plan: The Organization is continuing to evaluate its internal control systems to ensure proper segregation of duties surrounding various compliance with grant programs. After the Department of Labor review in fiscal year 2024, the Organization implemented new processes and internal controls to improve segregation of duties and address eligibility documentation issues. Anticipated Completion Date: Ongoing

View Audit 296216

Finding 382630 (2023-002)

Significant Deficiency 2023

Olivet Nazarene University

IL

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

The University understands the importance of returning Title IV funds within the established federal timeframe guidelines. This incident occurred as a result of the student stopping attendance without going through the proper channels to notify the university of their intention to withdraw. The staf...

The University understands the importance of returning Title IV funds within the established federal timeframe guidelines. This incident occurred as a result of the student stopping attendance without going through the proper channels to notify the university of their intention to withdraw. The staff attempted to contact the student to clarify the reason for their absence but was not able to do so until after the holiday break. The staff have been instructed to make as many attempts as it takes to resolve the question of a student’s unofficial withdrawal within the required timeframes. Trisha O’Brien will ensure the process of communicating with the student is followed. This should reduce the chance of the finding in the future.

View Audit 296208

Finding 382629 (2023-001)

Significant Deficiency 2023

Olivet Nazarene University

IL

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

The University understands the importance of timely exit counseling. The reporting structure for the January, 2023 determination of students not returning from the holidays did not work properly, and the university has corrected the process. Those reports will be activated weekly and immediately aft...

The University understands the importance of timely exit counseling. The reporting structure for the January, 2023 determination of students not returning from the holidays did not work properly, and the university has corrected the process. Those reports will be activated weekly and immediately after returning from any campus closure. Tiffany McCann, the Executive Director of Student Financial Services, will verify the Veera reporting structure is in compliance, which should eliminate the chance of a recurring finding.

View Audit 296208

Finding 382628 (2023-001)

Material Weakness 2023

Tipton Independent School District #8

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The Tipton School District will immediately implement the following controls to assure that the district has adequate internal controls in place should any future expenditures of federal funds for Capital Projects be made. The district will review the Federal Procurement and contractor requirements...

The Tipton School District will immediately implement the following controls to assure that the district has adequate internal controls in place should any future expenditures of federal funds for Capital Projects be made. The district will review the Federal Procurement and contractor requirements prior to submitting documents to use Federal Funds for Capital Projects. The district will provide training to staff to ensure compliance with all Federal Program Procurement including compliance with the Davis-Bacon Act (prevailing wage rate) requirements, and reviewing weekly certified payroll reports from the contractor or subcontractor. The district will ensure that all items are posted at the work site to confirm compliance. This corrective action plan will go into effect by March 11, 2024.

View Audit 296205

Finding 382621 (2023-002)

Significant Deficiency 2023

Flagler College, Inc.

FL

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

Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks....

Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College’s Information Technology department will amend the written program and policy to include all necessary aspects of GLBA compliance and IT management and cybersecurity risk. Names of the contact person responsible for corrective action: Gwen Pechan Planned completion date for corrective action plan: March 31, 2024

View Audit 296201

Finding 382620 (2023-001)

Significant Deficiency 2023

Flagler College, Inc.

FL

Student Financial Aid Subrecipient Monitoring Reporting

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is complet...

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Registrar’s Office will collaborate with our Information Technology Department to identify and correct all students with erroneous program start dates. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions in collaboration with the Information Technology Department and Advising Office to ensure that the program-level enrollment effective dates are accurately reflected when a student submits a change of major. Names of the contact persons responsible for corrective action: Sheia Pleasant-Doine and Adam Doine Planned completion date for corrective action plan: May 3, 2024

View Audit 296201

Finding 382600 (2023-002)

None 2023

East-West University

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2023-002 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2023 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect ...

2023-002 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2023 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need the students were over awarded $4,500 in Subsidized Loans and under awarded $4,500 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan and Direct Unsubsidized Loan to reflect the correct amount foer the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan February 15, 2024

View Audit 296164

Finding 382592 (2023-005)

Material Weakness 2023

Portage Township Schools

IN

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

Finding 2023-005 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Linda Williams Contact Phone Number: 219-764-6209 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The PTS Office of Grants and Assessmen...

Finding 2023-005 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Linda Williams Contact Phone Number: 219-764-6209 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The PTS Office of Grants and Assessments will collaborate with the PTS Finance Office to establish a system of internal controls and separation of duties to ensure a thorough review prior to the submission of the Annual ESSER Data Report. Anticipated Completion Date: April 2024

View Audit 296149

Finding 382586 (2023-003)

Significant Deficiency 2023

Portage Township Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

Finding 2023-003 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number: 219-850-1914 - qvanrypces.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Provider/Emp...

Finding 2023-003 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number: 219-850-1914 - qvanrypces.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records by student services monthly/bi-monthly to the bookkeeper. Once payroll records are received, the CFO will prepare a spreadsheet that calculates the time serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. This documentation will be reviewed and signed off by the Director of Special Education of Portage Township Schools. Anticipated Completion Date: March 2024

View Audit 296149

Finding 382584 (2023-007)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Beginning January 31, 2024, DDAP started having internal discussions to determine the most effective and efficient methodology to evaluate the internal controls of the SCAs' data being reported to DDAP during the federal grant period and in the PPRs. Steps currently being taken by DDAP include updat...

Beginning January 31, 2024, DDAP started having internal discussions to determine the most effective and efficient methodology to evaluate the internal controls of the SCAs' data being reported to DDAP during the federal grant period and in the PPRs. Steps currently being taken by DDAP include updating the SCAs' monitoring process for the next annual monitoring cycle for FY 2023-24. The goal is to have a sound methodology with formalized policies and procedures in place by April 2024 to ensure the data collected is sampled for accuracy going forward. To ensure accuracy of the information reported by the SCAs, which is included on the PPRs, DDAP will add verification of this data to the current SCA monitoring process. Specifically, the Project Officers who conduct SCA monitoring will: - Add a question to the SCA Pre-Submission packet: ‘How does your SCA track SOR-funded clients in order to accurately report them on the SOR Report?’ The SCA must specifically state how they are accounting for these clients and how they arrive at the data reported to DDAP. If DDAP determines the process is not acceptable, the SCA will be required to revise and resubmit. - During the virtual monitoring call, Project Officers will review the SCA’s written answer to the question, and ensure they have a full understanding of where the SCA keeps data on SOR-funded clients, and how they access this data to complete the SOR reports. - During the onsite monitoring visit, the Project Officers will take the most recently submitted SOR report and ask the SCA staff to duplicate the steps they used to arrive at the reported numbers. * If the SCA is able to demonstrate how clients are tracked and the steps used to determine the reported numbers produce results consistent with what was submitted in the report, the SCA’s submitted data will be considered verified. * If the SCA is unable to demonstrate how clients are tracked, and the steps used to determine the reported numbers do not produce results consistent with what was submitted in the report, the SCA will be required to implement a process by which they can accurately track this data and report client numbers. Any SCA required to implement a new client-tracking system will be required to submit backup documentation with their SOR reports, until such time as they are able to demonstrate to DDAP that they are accurately tracking clients and can demonstrate the steps used to determine their reported numbers. - This review process and results will be added to the Monitoring Report sent to the SCA at the end of the monitoring cycle, to reflect the SCA’s compliance status. Anticipated Completion Date: 09/30/2024 Contact Names: Susan Duff, Chief, Program Monitoring Division; Autumn Croasmun, Project Director for State Opioid Response III Grant; Tia Roebuck, Director, Division of Budget and Procurement

View Audit 296143 Questioned Costs: $1

Finding 382583 (2023-006)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.404

DOC will institute internal controls to review and monitor, on a quarterly basis, medical costs billed from the pharmaceutical vendor to ensure the billing is consistent with contract language. The review will be done by a Fiscal Management Specialist (FMS). The internal control will consist of the...

DOC will institute internal controls to review and monitor, on a quarterly basis, medical costs billed from the pharmaceutical vendor to ensure the billing is consistent with contract language. The review will be done by a Fiscal Management Specialist (FMS). The internal control will consist of the following: - Beginning with the December 2023 invoice, DOC will request fully executed procurement documents from the pharmaceutical contractor to verify acquisition costs. - The current contract language states that pharmaceuticals are billed at actual acquisition costs plus a dispensing fee. Therefore, the FMS will match the acquisition cost for the vendor for a sample of transactions to the invoices received from the vendor. - DOC will conduct this review on the pharmaceutical invoices for March, June, September, and December in each year continually. - DOC will document the review using an excel spreadsheet that has the universe of pharmacy orders by patient – matching the records and recording the date the review was done. All documents will be saved in an internal medical invoice folder. - Reviews will be completed by the last day of the month after the invoice is submitted. - Training on the new process will be done by March 31, 2024. Findings (or lack thereof) will be reported to DDAP by April 30th, July 31st, October 31st, and January 31st of each year via email. - If there are discrepancies, the vendor will be contacted immediately and a true-up will be requested in the next month’s invoices (either a credit or a debit depending on the discrepancy). DOC will continue to utilize PACE to complete full audits on reasonability of drug prices. DOC acknowledges, due to purchasing and distribution practices for the pharmaceutical vendor, Sublocade was not on prior reports. However, in the third and fourth quarter of 2023, Sublocade was added to the quarterly PACE audits for reasonability of drug prices. DOC has spoken with PACE and will now receive all quarterly audits and will be invited to all meetings between PACE and the contracted pharmaceutical vendor to discuss any findings. Anticipated Completion Date: 03/31/2024 Contact Names: Erica Benning, Director, Healthcare Services; Jodilynn Jacob-Byrd, Fiscal Management Specialist

View Audit 296143 Questioned Costs: $1

Finding 382570 (2023-022)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

The following steps were taken to address this material weakness: - Finalize FFATA procedures to ensure a consistent FFATA review is being conducted in General Accounting. - Mangers will review FFATA preparer’s reports for completeness. - Review fiscal year end FFATA errors and make corrections need...

The following steps were taken to address this material weakness: - Finalize FFATA procedures to ensure a consistent FFATA review is being conducted in General Accounting. - Mangers will review FFATA preparer’s reports for completeness. - Review fiscal year end FFATA errors and make corrections needed so the FFATA reports are in FSRS and USAspending.gov. Anticipated Completion Date: 11/01/2024 Contact Names: Sandra Bruno, Integrated Financial Service Manager; Jamie Jerosky, Assistant Director

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Corrective Action Plans

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