Corrective Action Plans

Finding 48084 (2022-001)

None 2022

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Identifying Number: 2022-001 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Borrower Data Transmission and Reconciliation Finding: The College was unable to produce the reconciliations for review. Name of Contact Person: Karen Overton, Director of Financial Aid Correcti...

Identifying Number: 2022-001 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Borrower Data Transmission and Reconciliation Finding: The College was unable to produce the reconciliations for review. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: Using the data files, provided by USDOE Common Origination and Disbursement (COD), the College will upload the files every month into CAMS to perform COD reconciliation monthly. A specific staff has been assigned to perform this task each month. Anticipated Completion Date: Monthly, beginning August 2022

View Audit 54135

Finding 48083 (2022-002)

None 2022

Coastal Area District Development Authority, Inc.

GA

Questioned Costs Reporting Matching / Level of Effort / Earmarking

Finding: 2022-02 Name of contact person: Terrence T. Louk, Chief Executive Officer Corrective Action: Management acknowledges the finding related to the reporting error on Form ED-209, RLF Financial Report for fiscal year 2021. Per a review with the Economic Development Administration (EDA), this er...

Finding: 2022-02 Name of contact person: Terrence T. Louk, Chief Executive Officer Corrective Action: Management acknowledges the finding related to the reporting error on Form ED-209, RLF Financial Report for fiscal year 2021. Per a review with the Economic Development Administration (EDA), this error is a result of the complexity of reporting a partial loan loss in the EDA?s Salesforce system. Management will work with the EDA to reconcile the report balances. Proposed Completion Date: September 30, 2023

View Audit 54072 Questioned Costs: $1

Finding 48082 (2022-001)

None 2022

Coastal Area District Development Authority, Inc.

GA

Matching / Level of Effort / Earmarking

Finding: 2022-01 Name of contact person: Terrence T. Louk, Chief Executive Officer Corrective Action: Management acknowledges that the agreement was not included in the loan documentation. Management is in the process of obtaining an executed agreement signed by the borrower. Management is also impl...

Finding: 2022-01 Name of contact person: Terrence T. Louk, Chief Executive Officer Corrective Action: Management acknowledges that the agreement was not included in the loan documentation. Management is in the process of obtaining an executed agreement signed by the borrower. Management is also implementing a closing checklist that includes all required documents that are to be included in each loan file. Proposed Completion Date: September 30, 2023

View Audit 54072

Finding 48081 (2022-001)

Significant Deficiency 2022

Jackson Hole Land Trust

WY

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2022-001 Contact person and responsible person: Derek Schaefer, Chief Financial Officer. Email address: derek@jhlandtrust.org Corrective Action Planned: As a result of the September 30, 2021 Schedule of Findings and Questioned Costs, subsequent to the month of May 2022, the Land Trust develo...

Finding 2022-001 Contact person and responsible person: Derek Schaefer, Chief Financial Officer. Email address: derek@jhlandtrust.org Corrective Action Planned: As a result of the September 30, 2021 Schedule of Findings and Questioned Costs, subsequent to the month of May 2022, the Land Trust developed a checklist of processes and procedures to guide the Land Trust through future conservation easement purchases made with federal funds. The Land Trust assigned an employee to review federal contracts and extract and summarize applicable compliance requirements. The Land Trust will continue to develop and hone these new procedures and tools. Anticipated Completion Date: Substantially completed at September 30, 2022 with ongoing adjustments.

View Audit 53099

Finding 48057 (2022-001)

Material Weakness 2022

Dayton Early College Academy

OH

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

OPEN FOR CLIENT.

View Audit 46047

Finding 48054 (2022-001)

Significant Deficiency 2022

Texas Guaranteed Student Loan Corporation

TX

Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan: FFEL variable interest rates must be updated annually in July. For example, a claim paid in December 2019 would need 0% interest rate updates on March 13, 2020, July 1, 2020, July 1, 2021, and annually thereafter until the present date. The original query was designed to s...

Corrective Action Plan: FFEL variable interest rates must be updated annually in July. For example, a claim paid in December 2019 would need 0% interest rate updates on March 13, 2020, July 1, 2020, July 1, 2021, and annually thereafter until the present date. The original query was designed to search only for updates made to the most recent annual interest rate anniversary. The query has been modified to look at each annual variable rate anniversary to ensure that all updates, including March 13, 2020 were completed. All loans identified were updated with the correct interest rates as of September 15, 2022. The reports mentioned in the recommendation will be reviewed weekly. Accounts identified in the reports will be updated timely. Responsible Person: Susan High, VP of Operations Anticipated Completion Date: Ongoing until notified by USDE of the required end date.

View Audit 46041

Finding 47969 (2022-011)

Significant Deficiency 2022

Ucan

IL

Questioned Costs Matching / Level of Effort / Earmarking

Identifying Number: 2022-011 Finding: Matching, Level of Effort, Earmarking Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to training staff and documenting processes. Every member of the finance team will undergo extensive training in grant vouchering and matc...

Identifying Number: 2022-011 Finding: Matching, Level of Effort, Earmarking Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to training staff and documenting processes. Every member of the finance team will undergo extensive training in grant vouchering and match reporting. Staff turnover in the finance department caused the incorrect reporting of the match dollars, and the lack of sufficient review. Implementation will be planned for completion before June 30, 2024. Contact person is Kimberly Parish, Chief Financial Officer.

View Audit 53429 Questioned Costs: $1

Finding 47958 (2022-002)

Significant Deficiency 2022

Adams Central Community Schools

IN

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

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana ...

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. 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. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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 Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001- PN01 grant application was $5,368. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corrective action plan is following the AWSSC plan of: Co-ops cannot combine proportionate share funds. Funds must be spent within each LEA?s geographic boundary. We will not receive a repeat finding for FY21. We will correct for FY22 and forward. Time & Effort Logs are being completed to show how many hours personnel are servicing Non-Pub school students with a service plan. If Materials and Equipment are purchased for a specific student?s need, per the service plan, then those expenditures are 100% school specific. Per the DOE, Materials used by our Speech Language Pathologist for Speech Therapy for all six school corporations, those expenditures are split evenly across all school corporations with a non-pub proportionate share allocation. Responsible Party and Timeline for Completion: The Superintendent and Corporation Treasurer will work with the Adams Wells Special Services Cooperative to monitor and verify those expenditures are allocated appropriately across all school corporations with a non-pub proportionate share allocation.

View Audit 52770

Finding 47955 (2022-001)

Material Weakness 2022

Adams Central Community Schools

IN

Questioned Costs School Nutrition Programs Cash Management § 200.303

FINDING 2022-001 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Departm...

FINDING 2022-001 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: We noted that for one claim in a sample of four, the school lunch meal count was overclaimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 173 meals. We noted that the sponsor claim reimbursement form had been reviewed, however, the lack of an effective review allowed the error to go unnoticed. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Going forward, we will have multiple people verifying the data before submission to reimbursement for claims to make sure all meals submitted meet the criteria and eligibility of the Child Nutrition Cluster. Responsible Party and Timeline for Completion: The Food Service Director and the Corporation Treasurer are the responsible parties for this corrective action. This has already been implemented.

View Audit 52770 Questioned Costs: $1

Finding 47913 (2022-002)

Significant Deficiency 2022

Enterprise State Community College

AL

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

Item 2022-002 ? Eligibility Contact person: Chellye Stump, Dean of Administrative Services Finding ? During a dual purpose tests of controls and compliance there were 3 participants who were identified that did not certify to the fact that they were a citizen, national, or permanent resident of the ...

Item 2022-002 ? Eligibility Contact person: Chellye Stump, Dean of Administrative Services Finding ? During a dual purpose tests of controls and compliance there were 3 participants who were identified that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Management Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before 9/30/23. Effective date of completion: within the fiscal ending September 30, 2023

View Audit 46519

Finding 47883 (2022-002)

Material Weakness 2022

Central Michigan University

MI

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

Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed...

Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $5,990 in questioned costs. 2.Of the 60 students tested there were 18 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended). 3.Of the 60 students tested, there were 4 identified where no return to Title IV calculation was performed and therefore no return of funds until students were selected for testing for the audit resulting in $1,715 in questioned costs. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked as appropriate. This will clarify the procedures being used for the return to Title IV process. ?Procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?Methodology for dates being used for end of semester and date of determination will be clearly documented for each semester along with the actual dates used. For non- modular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the ask regs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to reconcile all required returns for a given semester have occurred. This will address students who were also missed in the prior year process. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2022

View Audit 53360 Questioned Costs: $1

Finding 47882 (2022-001)

Material Weakness 2022

Central Michigan University

MI

Student Financial Aid Material Weakness Reporting

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attribut...

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding. 1. Of the 40 students tested, there was 15 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew/graduated whose status change were not reported to the NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: Following guidance provided via Plante Moran and the Dept, of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective Fall 2022 to address correct enrollment status change reporting by: ? Adopt the use of the published academic semester end date for enrollment reporting vs using the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that published end of an academic semester, per the Academic Calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ? Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date at which Registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated, due to having attended at least 60% of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting as last date of attendances are supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure accuracy of identifying students who are unofficial withdrawals at the end of an academic semester and adjust staffing resources as necessary to account for critical time periods such as the period between CMU?s Fall and Spring semesters when the university is closed. This will be necessary due to using the published last date of the semester instead of the end of the payment period date that was used in prior years. ?Planned timeline to complete corrective actions is February 2023 to account for end of Fall 2022 grading processes and manual updating of NSLDS as necessary for identified unofficial withdrawals. ?Contact person responsible for corrective action: Keith Malkowski, Registrar ?Anticipated Completion Date: February 2023 following end of semester grading and subsequent student record updating per our Date of Determination process.

View Audit 53360

Finding 47877 (2022-001)

Significant Deficiency 2022

Philadelphia Industrial Development Corporation

PA

Questioned Costs Allowable Costs / Cost Principles Cash Management

Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Manage...

Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Management will continue to rely on its existing controls in place; however, noting that Management will closely monitor loans and loan disbursements where the funding source has changed closely to ensure that disbursements are in accordance with funding terms and approval limits. Management will continue to rely on its existing controls that are in place, including the ongoing communication with the City for any changes in transactions that require their approval. In the circumstances where management is pending a contract amendment from the City for loans requiring additional funding, management will determine if there are unrestricted funding sources to support the change in the approved amount of the loan until the amended contract is finalized. Questioned Program: CFDA #14.218 Community Development Block Grants (CDBG)

View Audit 52296 Questioned Costs: $1

Finding 47865 (2022-001)

Significant Deficiency 2022

Mission Consolidated Independent School District

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring HUD Housing Programs § 200.303

The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential av...

The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential avenues of relief: 1. 5-year flexibility: If a District is non-compliant with FY 2022 ESSA LEA MOE (determinations that FFCR will issue in Spring 2023) but was compliant in FYs 2017, 2018, 2019, 2020, and 2021 then the District would not have its FY 2024 (the school year 2023?2024) ESSA allocations reduced. However, the District would still be considered non-compliant, and FY 2023 expenditures would be compared to FY 2021. 2. USDE waiver: A non-compliant District can submit a waiver request to the U.S. Department of Education (USDE), as TEA does not have the authority to waive ESSA LEA MOE. USDE considers each request on a case-by-case basis and has not shared the criteria they use to evaluate requests. If a District is non-compliant, even if they are eligible for the 5-year flexibility, FFCR staff contact the impacted Districts to advise them on the steps to submit a waiver request to USDE. The District met ESSA LEA MOE in fiscal years 2017, 2018, 2019, 2020, and 2021. Therefore, the District will utilize the allowable 5-year flexibility and submit the USDE waiver. The District will continue to run the state aid template every six weeks to monitor student enrollment and attendance to project revenue. The District will facilitate meetings with the program directors, Human Resources, and Payroll department. In addition, the District will monitor actual expenditures compared to the budget every six weeks to ensure that MOE tests are met by year-end. Contact person: Joel Garcia, Assistant Superintendent for Finance Proposed Completion Date: November 15. 2022 "See full CAP in report"

View Audit 51195

Finding 47834 (2022-002)

Significant Deficiency 2022

Morrow County

OH

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.208 § 200.305

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We ...

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We will implement procedures to ensure all quarterly reports are submitted timely under this grant. December 31, 2023 Director of Morrow County Job and Family Services and Morrow County Area Transit

View Audit 46816

Finding 47832 (2022-001)

Significant Deficiency 2022

Collaborative for Children

TX

Equipment & Real Property Management Matching / Level of Effort / Earmarking Special Tests & Provisions

Finding #2022-001 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Passed through Houston-Galveston Area Council Child Care and Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care and Developme...

Finding #2022-001 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Passed through Houston-Galveston Area Council Child Care and Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing #: 93.575/93.596 Contract Numbers: 301-22, 301-23 Contract Years: 10/01/21 ? 09/30/22, 10/01/22 ? 12/31/22 Recommendation: Re-emphasize CFC?s policies and procedures related to equipment and real property purchased under the contracts. Planned corrective action: During staff training, we have clearly stated the requirement for a physical inventory to be performed annually. To ensure that a physical inventory is performed in accordance with written policies and procedures, we have taken the following measures: ? Designated a responsible person to oversee the physical inventory process. ? Created a checklist of steps to be followed during the physical inventory process. ? Trained staff on how to perform the physical inventory process. Responsible officer: Chief Financial Officer, Alisa Ealy Estimated completion date: September 30, 2023

View Audit 45789

Finding 47825 (2022-001)

Material Weakness 2022

Lancaster City School District

OH

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

CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with fed...

CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with federal ESSER funds. School Districts are usually not required to pay prevailing wages (state/local funds). The District had not used federal funds for construction in the past and was unaware of the requirement. Due to using an architect firm for the HVAC and window projects that were familiar with the requirements, the District had paid prevailing wage and had the required Davis-Bacon documentation for two of the three projects spent out of ESSER funds. The remaining project was in the amount of $46,870 for Locker Room Floor Renovations at the High School. The District was not aware of the Davis-Bacon requirements when the Business Manager originally contacted Kiefer in 2020 about the rubber flooring (no guidance was available). Due to COVID and delays in materials, the project was pushed back and this requirement was not reconsidered. District Administration has been made aware of the requirements using Federal ESSER funds going forward. In addition, the District policy (DJF) regarding purchasing procedures, that did not specifically include Davis-Bacon language, was updated to include Davis-Bacon requirements (Board approved 9/27/22). Further, the District intends to closely follow internal controls pertaining to federal grant management in order to prevent future issues as described in Finding 2022-001. Anticipated Completion Date: 09/27/22 Responsible Contact Person: Julie Taylor, Treasurer

View Audit 41547

Finding 47811 (2022-044)

Material Weakness 2022

State of Oregon

OR

Matching / Level of Effort / Earmarking § 200.303

2022-044 Oregon Health Authority Implement a consistent methodology for calculation of maintenance of effort Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for ...

2022-044 Oregon Health Authority Implement a consistent methodology for calculation of maintenance of effort Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Matching, Level of Effort, Earmarking Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 42 USC 300x-2(a)(1)(C); 42 USC 300x-4(b)(1); 42 USC 300x-9(c)(1); 42 USC 300x-22(b)(1)(C); 42 USC 300x-30(a); 2 CFR 200.303 The Mental Health Block Grant and Substance Abuse Block Grant are subject to various Maintenance of Effort and Earmarking requirements. These requirements ensure the department meets minimum expenditure thresholds. Federal regulations require recipients of federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Based on auditor recalculations, we determined the department was in compliance with the applicable Maintenance of Effort and Earmarking requirements during state fiscal year 2022. However, we noted the following control weaknesses in the department?s calculations and demonstration of their compliance with the requirements: The department is required to expend 10% of the federal award for early serious mental illness and a first episode psychosis treatment services under the Mental Health Block Grant. The 10% set aside is calculated and budgeted when federal awards are granted. However, tracking of expenditures is not performed to ensure compliance is achieved. The department is required to maintain state expenditures for community mental health services and authorized substance abuse activities at a level not less than the average expenditures of the prior two state fiscal years. The department is also required to ensure expenditures for systems of integrated services for children with serious emotional disturbance and substance abuse treatment for pregnant women and women with dependent children is not less than the amount expended for these services in fiscal year 1994. The applicable expenditures were not consistently or accurately calculated by the department in each of the state fiscal years included in the Maintenance of Effort determinations. Additionally, no written procedures exist for the calculations. The department is at risk of noncompliance without controls in place to help ensure expenditures are tracked and calculations are consistently applied across fiscal years. We recommend department management implement controls to ensure applicable expenditures are adequately tracked and calculations applicable to the maintenance of effort requirements are consistently performed across fiscal years. We further recommend department management work with the federal awarding agency to submit corrected maintenance of effort totals to ensure appropriateness of future maintenance of effort determinations. MANAGEMENT RESPONSE: We agree with this recommendation. There were inconsistencies in how Maintenance of Effort (MOE) has been calculated. The applicable expenditures were not consistently or accurately calculated in each state fiscal year. The use of Marijuana paid expenses were not consistently used for both Mental Health and Substance Abuse Block Grant. We have met with SAMHSA MHBG State Project Office (SPO) for clarification on how Marijuana funds can be utilized in the calculation for the MOE. We have received guidance and clarification. We have recalculated MOE for the Block grants for SFY2022, SFY2021, and SFY2020 and are still doing data checks on these recalculations. With any changes to be made to previous years? MOE calculations, we must resubmit the request and reasons behind the changes to the SAMHSA project officers. HSD Budget is working on a written desk procedures to ensure applicable expenditures are adequately tracked and calculated to the maintenance of effort requirements and are consistently performed. Anticipated Completion Date: February 28, 2024 Contact: Annabelle Atalig, Budget and Fiscal Manager

View Audit 45093

Finding 47799 (2022-032)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.332

2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Fami...

2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6 , 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.332(a) ? (h) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward to determine the extent and scope of subrecipient monitoring activities. Monitoring activities should be based on the results of a given subrecipient?s determined risk. Pass-through entities must also communicate certain award information to subrecipients as the time of the subaward. The department, as the pass-through entity, has long-established subrecipient monitoring procedures broken into two categories: program and fiscal monitoring. Program monitoring is performed by program-specific staff and focuses on requirements related to certain aspects of Activities Allowed and Client Eligibility. During FY2022, the department performed program monitoring activities as planned. Fiscal monitoring reviews compliance requirements related to Allowable Costs, Activities Allowed, and Earmarking. However, fiscal monitoring activities were limited due to staff turnover. As a result, limited fiscal monitoring procedures were performed for 5 of 17 subrecipients, and fiscal monitoring risk assessments were not performed for any of the 17 subrecipients. Without the performance of subrecipient risk assessments and adequate fiscal monitoring, the department risks distributing program funds to subrecipients out of compliance with federal program requirements. Additionally, we reviewed 5 randomly selected subrecipients to determine whether all required grant award information was communicated at the time of the subaward. For all of the 5 subrecipients reviewed, only some of the required information was communicated at the time of the award. The required information missing in the original grant agreements was communicated via agreement amendments several months later. Without timely communication of required grant information, subrecipients may not have all the information they need for the subaward they received. We recommend department management ensure subrecipient risk assessments are performed for all subrecipients and ensure required fiscal monitoring activities are performed based on the results of the risk assessments. We also recommend department management ensure all required award information is communicated to subrecipients at the time of the subawards. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS lost critical fiscal monitoring staff and was unable to complete all risk assessments and fiscal monitoring due to this. OHCS is on track to complete fiscal monitoring and risk assessments for all subrecipients of LIHEAP in FY23. Additionally, OHCS has established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller or Michelle Cole, Assistant Director of Energy Services

View Audit 45093

Finding 47756 (2022-003)

Material Weakness 2022

Union Township School Corporation

IN

School Nutrition Programs Cash Management Material Weakness § 200.303

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed ...

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed off on between the submitter and the Food Service Consultant or Kitchen Manager(s) in order to ensure accuracy. Anticipated Completion Date: January 23, 2023.

View Audit 41100

Finding 47749 (2022-004)

Material Weakness 2022

Liberty-Perry Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring Cash Management § 200.303

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will...

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023

View Audit 54302

Finding 47742 (2022-003)

Material Weakness 2022

Three Rivers Community Schools

MI

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

Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budge...

Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Ultimately a reconciliation was performed and approximately $ 99,000 was overcharged to Title I and subsequently reclassified as a non- grant expenditure. However, the School District requested and received reimbursement for this amount during the year- end June 30,2022. Planned Corrective Action: The School District will implement procedures to complete a review and reconciliation process to support the amount charged to Title I based on budget estimates is reasonable when compared to actual time expended on federal and state grants, specifically Title I Reconciliation will occur more than once a year to be able to align grant budgets, as needed. Contact person responsible for corrective action: Jennifer Graber, Director of Curriculum and Instruction and Blair Brindley, Director of Business Operations Anticipated Completion Date: 6/30/2023

View Audit 53995

Finding 47733 (2022-003)

Material Weakness 2022

Dugger Union Community Schools CORP

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.327

Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Ba...

Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction) (2CFR section 200.327; Appendix II D to 2 CFR Part 200). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payroll) (29 CFR section 5.5 and 5.6; the A-102 Common Rule(section 36(i)(S)): 0MB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.327). Condition: A LEA must use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics that must meet Davis-Bacon prevailing wage requirements. Cause: The School failed to timely notify a certain contractor about the Davis-Bacon Act contract clause requirements related to the prevailing wage rate for contractors and subcontractors. As a result, the contractor did not provide the certified payrolls or statement of compliance. Potential Effect: The contractor may not have complied with the wage requirements. Questioned costs: $214,716.62. Context: A total sample of one (1) item related to a certain contractors HVAC project was selected as part of allowable cost testing for the Education Stabilization Fund. Recommendation: We recommend that the School provide timely communication related to the prevailing wage rate requirements for contracts with future contractors and subcontractors. The School should also ensure that the proper prevailing wage rate clauses are included in future contracts. We further recommend that the School ensure the contractors and subcontractors compliance with the required federal compliance requirements. Action: We concur with the recommendation and will implement the appropriate language identifying the prevailing wage rate requirements in future contracts with both contractors and subcontractors. Furthermore, certified payrolls and statements of compliance with be required and tracked for each project.

View Audit 53695 Questioned Costs: $1

Finding 47720 (2022-001)

None 2022

City of Gloucester, Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.302

Condition: The subsidiary ledger for community development rehabilitation loans maintained by the Department did not agree to the City?s general ledger. Corrective Action Planned: A thorough review of the Grants Division?s loan files was conducted by the City?s Fiscal Analyst in 2018/2019. Correctio...

Condition: The subsidiary ledger for community development rehabilitation loans maintained by the Department did not agree to the City?s general ledger. Corrective Action Planned: A thorough review of the Grants Division?s loan files was conducted by the City?s Fiscal Analyst in 2018/2019. Corrections and notations from that analysis will be included when the loan data is imported into the current grant management software. Once the import has been completed, the Grants Division will provide the relevant City Offices with the most current loan data. Ideally, loan balances will also be managed using the accounts receivable module in MUNIS. Anticipated Completion Date: June 2023 Contact: Jaimie Corliss, Grants Administrator

View Audit 52709

Finding 47715 (2022-001)

Material Weakness 2022

Morgan County

IN

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

FINDING 2022-001 Contact Person Responsible for Corrective Action: Linda Pruitt Contact Phone number: 765-342-1001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Morgan County Commissioners adopted Ordinance No. 2023-10 which establishes interna...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Linda Pruitt Contact Phone number: 765-342-1001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Morgan County Commissioners adopted Ordinance No. 2023-10 which establishes internal control procedures related to the expenditure of ARPA funds. This ordinance also requires reports to be reviewed by the Auditor?s office prior to submission and a printed copy with the County Administrator?s signature and the County Auditor or Deputy Auditor?s signature shall be retained. This ordinance took effect upon passage on April 17, 2023. Anticipated Completion Date: Has already been corrected.

View Audit 51137

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