Corrective Action Plans

Finding 42264 (2022-002)

Material Weakness 2022

PR

Student Financial Aid Eligibility Reporting

Management?s Response The UPR concurs with this finding. To address the situation and take corrective actions, a meeting was held at the Vice Presidency for Academic Affairs and Research on March 15, 2023 with registrars of the eleven (11) units of the UPR System. The following actions were...

Management?s Response The UPR concurs with this finding. To address the situation and take corrective actions, a meeting was held at the Vice Presidency for Academic Affairs and Research on March 15, 2023 with registrars of the eleven (11) units of the UPR System. The following actions were proposed as corrective actions: ? Registrars were instructed to attend a Federal Student Aid workshop on March 28, 2023, on Loan Servicing, Enrollment Reporting, and the National Student Loan System. ? Professors will be oriented on the importance of taking and reporting attendance timely. ? All campuses must use the NEXT System (student data platform developed internally) to report partial and total withdrawals, as well as the attendance report. (We noted that the units that are using NEXT System did not have findings). For the five students of RUM and RCM the UPR was unable to provide information from NSLDS; the search on the website displayed ?Search returned 0 students. No matching students records found?. On December 9, 2022 RUM contacted NSLDS Customer Service Center by e-mail. They later received an e-mail informing the case was closed without further explanations. Also, NSLDS issued electronic announcements confirming problems with the implementation of their new website. On the other hand, RUM was able to provide evidence to auditors that they reported the status change of all students to the Clearing House on time. Responsible Person or Office: Executive Vice President for Academic Affairs and Research. Timeline: June 2024

View Audit 41413

Finding 42263 (2022-003)

Significant Deficiency 2022

City of Burbank

CA

Questioned Costs Reporting Significant Deficiency

Views of responsible officials and planned corrective actions: We agree with the auditor?s findings and recognize that some customers did received funding beyond the June 15, 2021 deadline. BWP calculated the daily average arrears for each customer with 60 plus days arrears during the program pand...

Views of responsible officials and planned corrective actions: We agree with the auditor?s findings and recognize that some customers did received funding beyond the June 15, 2021 deadline. BWP calculated the daily average arrears for each customer with 60 plus days arrears during the program pandemic period and cross referenced it with the actual past due balances as of June 15, 2021 to ensure no arrears prior to March 4, 2020 were included. Prior to the pandemic, BWP did not have sufficient arrearage data to easily calculate the credits, hence BWP relied on a data search methodology that estimated qualified customer balances to apply funds. Since the pandemic, BWP has changed its reporting on customer arrearages. BWP will run a daily aging report that will be used to calculate customer arrearages incurred during a specific period. Before credits are authorized, BWP Customer Service will manually spot-check the data set to verify accuracy. With regards to review of Federal grants awarded, BWP holds a monthly meeting with key personnel and an outside grants administrator to get status updates of pursued and/or awarded grants, including any federally funded grants. The Financial Accounting Manager-BWP and Principal Utility Accounting Analyst now attend this meeting. The Principal Utility Accounting Analyst will be responsible for timely communication of all key Federal grants data to City Finance and will prepare an annual schedule for all grant funding received/spent through the general ledger. In addition, BWP?s Legislative Analyst and BWP Finance staff will cross check records to timely reconcile grant reporting/activity.

View Audit 48309 Questioned Costs: $1

Finding 42260 (2022-001)

Significant Deficiency 2022

Bon Secours Mercy Health

OH

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

Management recognizes that Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control ov...

Management recognizes that Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information, which includes the Calculation of Lost Revenues Attributable to Coronavirus. In all instances Bon Secours Mercy Health (BSMH) has adequate lost revenue to be eligible for PRF funding and has maintained a correct list of the assigned lost revenue amounts; the Cares Act portal was not updated correctly to incorporate certain lost revenue amounts. As recommended, Management will employ additional review steps to ensure that the portal tracking of lost revenues is properly stated going forward. The contact for this finding is Kim Ralston, VP, Reimbursement, KMRalston@mercy.com.

View Audit 47065

Finding 42258 (2022-003)

Significant Deficiency 2022

Bon Secours Mercy Health

OH

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

BSMH has implemented enhanced policy and procedures to assist with managing data and enrollment reporting. The procedures include an enhanced review by the Registrar of the student data reports prior to NSLDS submission to ensure no omissions. The contact for this finding is Mark McKellip, Regis...

BSMH has implemented enhanced policy and procedures to assist with managing data and enrollment reporting. The procedures include an enhanced review by the Registrar of the student data reports prior to NSLDS submission to ensure no omissions. The contact for this finding is Mark McKellip, Registrar, Mark.McKellip1@mercycollege.edu.

View Audit 47065

Finding 42257 (2022-002)

Significant Deficiency 2022

Bon Secours Mercy Health

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303 § 200.305

Management is implementing an enhanced, more detailed invoice review process where invoices will be reviewed irrespective of materiality by leadership on the RETAIN team. In addition, the invoice process will include periodic meetings to go through expenditures in detail prior to invoice submission...

Management is implementing an enhanced, more detailed invoice review process where invoices will be reviewed irrespective of materiality by leadership on the RETAIN team. In addition, the invoice process will include periodic meetings to go through expenditures in detail prior to invoice submission. The contacts for this finding are Kori Smith, RETAIN Program Manager, KASmith4@mercy.com and Alice Parisi, Foundation System Director, Alice_Parisi@mercy.com.

View Audit 47065 Questioned Costs: $1

Finding 42232 (2022-005)

Significant Deficiency 2022

Pillar College and Subsidiaries

NJ

Allowable Costs / Cost Principles Eligibility Significant Deficiency

Need Analysis Planned Corrective Action: The Pillar College financial aid office and third-party servicer utilizes the upgraded automated student information system to assess each student?s remaining need based on the Cost of Attendance Budget minus the total funding received from federal, state, a...

Need Analysis Planned Corrective Action: The Pillar College financial aid office and third-party servicer utilizes the upgraded automated student information system to assess each student?s remaining need based on the Cost of Attendance Budget minus the total funding received from federal, state, and institutional scholarships. Triggers within the system are generated to the financial aid department when a student?s financial eligibility for packaging changes. Changes occur when the student?s enrollment status is reassessed and modified, or when their credits have increased after transfer credits have been entered into the system. Periodic reports will be set up in the student information system to check for over or under awarding of need based federal aid. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current

View Audit 46355

Finding 42230 (2022-003)

Material Weakness 2022

Pillar College and Subsidiaries

NJ

Student Financial Aid Material Weakness Reporting

Inaccurate and Untimely Returns to Title IV Planned Corrective Action: Pillar College changed the R2T4 policy in the catalog and created an R2T4 form to monitor the process. Our operating system, Anthology, has been upgraded to include automatic triggers. The automated system alerts financial aid...

Inaccurate and Untimely Returns to Title IV Planned Corrective Action: Pillar College changed the R2T4 policy in the catalog and created an R2T4 form to monitor the process. Our operating system, Anthology, has been upgraded to include automatic triggers. The automated system alerts financial aid, the third-party servicer and the registrar to process and critique the effects of the student?s official and/or unofficial withdrawal. Three specific processes have been created and are combined under ?Withdrawal Process Flow Charts: Official, Unofficial and Non-Returning Student?. After analysis the financial aid office and third-party servicer determine the potentiality of funds to be returned to Title IV in a timely manner. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current

View Audit 46355

Finding 42229 (2022-002)

Material Weakness 2022

Pillar College and Subsidiaries

NJ

Reporting Student Financial Aid Eligibility

Enrollment Reporting to NSLDS Planned Corrective Action: The college will continue to process the semi-monthly NSLDS reporting through the SIS and undertake spot checking 10% of the reported students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Th...

Enrollment Reporting to NSLDS Planned Corrective Action: The college will continue to process the semi-monthly NSLDS reporting through the SIS and undertake spot checking 10% of the reported students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. The errors will be fixed, and the type of errors will be tracked to modify the SIS as needed. Person Responsible for Corrective Action Plan: Brian Schroeder, Registrar Anticipated Date of Completion: current

View Audit 46355

Finding 42215 (2022-001)

Significant Deficiency 2022

National Urban League, Inc.

NY

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting

Audit Finding Reference: 2022-001 Planned Corrective Action: This is a repeat finding from 2021 audit which was properly addressed and fully resolved by March 2023. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and...

Audit Finding Reference: 2022-001 Planned Corrective Action: This is a repeat finding from 2021 audit which was properly addressed and fully resolved by March 2023. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. NUL Legal Department used to be responsible for generating FFATA reports, as they are authorized with review of new grant agreements as well as related contracts/subrecipients agreements submitted for approval. Some reports were not submitted in time because of continuous turnover in the department in 2021-22. The regular workflow was sometimes interrupted, and new appointees had to catch up following their priority lists. Eventually, at the end of February 2023, the function was moved to the Finance department and a specific position designated for completing FFATA reports under supervision of VP, B&G/Director, B&G. All pending FFATA reports have been completed immediately after that. We keep submitting FFATA reports for new grants as soon as subaward amounts are finalized. Name and Title of Contact Persons: Paul Wycisk, Interim Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants

View Audit 44515

Finding 42214 (2022-001)

Significant Deficiency 2022

City of San Diego

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

Reference Number: 2022-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. Al...

Reference Number: 2022-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All notification receipts and various forms of verification will be saved in house, on the City of San Diego?s network. As of today, March 28, 2023, once email notifications are sent to customers using an external service provider, the notification confirmations will be immediately archived at the City of San Diego. This affords the City full control and oversight of the verification process for all future noticing. As of today, all available notification verifications from the third-party vendor have been downloaded and saved to the City network for future inquiries. Furthermore, internal controls will be enhanced to ensure notification verification compliance. Upon notification to customers, the Data and Analytics Program Coordinator will oversee the immediate archiving of all confirmations of emails sent to customers using an external service provider. Once complete, the Data and Analytics Program Coordinator will notify the Program Manager, who will in turn, perform a secondary review of all notifications against the verification documentation to ensure accuracy. At this point, a third level of approval will be added, as the Public Utilities Customer Support Deputy Director will provide a final level review. Once complete, these documents will be saved for a minimum of five years, per the City of San Diego?s retention policy. Anticipated Implementation Date: 3/28/23 Contact: Katie Keach, Deputy Director, Public Utilities Department

View Audit 40444

Finding 42197 (2022-001)

Significant Deficiency 2022

Preferred Family Healthcare, Inc.

MO

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions ? PFH Management has reviewed the procedures surrounding funding match and made the necessary changes to ensure compliance. Additional training has also occurred and is ongoing with accounting as well as program staff and new monitoring ...

Views of Responsible Officials and Planned Corrective Actions ? PFH Management has reviewed the procedures surrounding funding match and made the necessary changes to ensure compliance. Additional training has also occurred and is ongoing with accounting as well as program staff and new monitoring steps designed and implemented.

View Audit 38591 Questioned Costs: $1

Finding 42193 (2022-004)

Material Weakness 2022

Naco Elementary School District No.23

AZ

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

FINDING 2022-004 Schedule of Federal Expenditures We have prepared the accompanying corrective action plan as required by the standards applicable to financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Unifo...

FINDING 2022-004 Schedule of Federal Expenditures We have prepared the accompanying corrective action plan as required by the standards applicable to financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Federal Assistance Number 84.425 Program Title Covid-19 Education Stabilization Fund Federal Agency U.S. Department of Education Compliance Requirements A. Activities Allowed or Unallowed B. Allowable Costs/Cost Principles Finding Type Noncompliance, Material Weakness CONDITION The District recorded $67,632 in employee health insurance expenditures to the federal program Covid-19 Education Stabilization Fund. Due to errors in the posting of health insurance expenditures the amount of health insurance applied could not be relied on. It could not be determined if the health insurance expenditures reported were questioned costs. CORRECTIVE ACTION PLAN Management is in the process of hiring additional personnel to alleviate the workload of the Business Manager and will evaluate the need for the consultant when that process is complete. DISTRICT CONTACT Timothy Mayclin, Superintendent Completion Date June 30, 2023

View Audit 40032

Finding 42192 (2022-004)

Material Weakness 2022

Van Buren County Hospital

IA

Reporting Material Weakness Matching / Level of Effort / Earmarking

Based on the size of the hospital and expenses, it is not cost effective to have an internal control system designed to provide for the preparation of this schedule. We requested that our auditors, Eide Bailly LLP, prepared this schedule as part of their single audit. We will designate someone to re...

Based on the size of the hospital and expenses, it is not cost effective to have an internal control system designed to provide for the preparation of this schedule. We requested that our auditors, Eide Bailly LLP, prepared this schedule as part of their single audit. We will designate someone to review this schedule and approve moving forward.

View Audit 39690

Finding 42161 (2022-001)

Significant Deficiency 2022

Southern California Institute of Architecture

CA

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

Management?s Corrective Action Plan - For the Year Ended August 31, 2022 - Finding number 2022-001 - Reporting: Significant Deficiency Over Internal Controls Over Compliance - Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corr...

Management?s Corrective Action Plan - For the Year Ended August 31, 2022 - Finding number 2022-001 - Reporting: Significant Deficiency Over Internal Controls Over Compliance - Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action was implemented in October 2022. The school's management agrees with the finding and has implemented procedure whereby the CFO will send calendar reminders to the Financial Aid Manager and other parties involved to set a reminder of submission deadlines for each quarterly report and set an internal deadline prior to such due date. Due dates are specified by OMB Control Number 1840-0849; the reporting deadline for quarterly reports is 10 days after each reporting period. In addition to the calendar invitation above, once the report is uploaded, the uploader will send a follow up email to all parties involved to confirm that the upload to the website has occurred. If the uploader has not posted the report to the website within two business days of receipt, the Financial Aid Manager will follow-up with the uploader to ensure the posting happens before the reporting deadline.

View Audit 50238

Finding 42160 (2022-008)

Significant Deficiency 2022

Leflore County Hospital Authority Dba Eomc

OK

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

USDA Annual Reporting Finding: 2022-008 Federal Agency Name: U.S. Department of Agriculture Program Name Community Facilities Loans and Grants Federal Financial Assistance Listing Number 10.766 Finding Summary: The Authority did not file the annual financial audit within 150 days after the end of...

USDA Annual Reporting Finding: 2022-008 Federal Agency Name: U.S. Department of Agriculture Program Name Community Facilities Loans and Grants Federal Financial Assistance Listing Number 10.766 Finding Summary: The Authority did not file the annual financial audit within 150 days after the end of the fiscal year and did not file the operating budget with the proposed rate schedule 30 days prior to the beginning of the new fiscal year. Responsible Individual: Priacilla Leatherman Interim Chief Financial Officer Corrective Action Plan: The Authority is in the process of developing processes and controls to ensure the reporting requirements are being met. Anticipated completion date: Ongoing

View Audit 50082

Finding 42159 (2022-007)

Material Weakness 2022

Leflore County Hospital Authority Dba Eomc

OK

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

Maintenance of Debt Service Reserve Account Finding: 2022-007 Federal Agency Name: U.S. Department of Agriculture Program Name Community Facilities Loans and Grants Federal Financial Assistance Listing Number 10.766 Finding Summary: The Authority did not deposit the required funds into the debt s...

Maintenance of Debt Service Reserve Account Finding: 2022-007 Federal Agency Name: U.S. Department of Agriculture Program Name Community Facilities Loans and Grants Federal Financial Assistance Listing Number 10.766 Finding Summary: The Authority did not deposit the required funds into the debt service fund until October 2021 and the Authority?s June 2022 deposit was not received by the bank until July 11, 2022. Responsible Individual: Priacilla Leatherman Interim Chief Financial Officer Corrective Action Plan: The Authority is in the process of revising controls to ensure deposits are made timely and they are establishing controls to aid with the monitoring the debt service requirements are being met. Anticipated completion date: Ongoing

View Audit 50082

Finding 42116 (2022-002)

None 2022

Notre Dame De Namur University

CA

Student Financial Aid Matching / Level of Effort / Earmarking

2022-002 Federal Direct Loan Reconciliations Assistance Listing Number: 84.268 Criteria According to 34 CFR 685.300(b)(5), the school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and acc...

2022-002 Federal Direct Loan Reconciliations Assistance Listing Number: 84.268 Criteria According to 34 CFR 685.300(b)(5), the school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; Condition The University did not perform the monthly reconciliations over direct loans. Context We requested a selection of reconciliations out of the 12 required and were informed that only a year-end reconciliation was performed. Cause The reconciliations were not performed due to the University being short-staffed. Effect Direct loan discrepancies may not have been identified and resolved in a timely manner due to the lack of monthly reconciliations. Questioned Cost There were no questioned costs related to this finding. Recommendation We recommend that the University perform direct loan reconciliations monthly to ensure that discrepancies are properly addressed in a timely manner. Planned Corrective Action Existing fiscal staff will now have more bandwidth to help with monthly analysis and accounting close protocols with student services staff. Implementation Date Effective date: 7/1/23 for fiscal year 2024. Responsible Personnel Arlene Cash Interim Vice President for Enrollment Management awcash@ndnu.edu

View Audit 39518

Finding 42114 (2022-001)

Significant Deficiency 2022

Jewish Federation of Metropolitan Chicago

IL

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430

FY 2022 Corrective Action Plan Audit Firm: RSM US LLP 30 South Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 07/01/2021 ? 06/30/2022 Contract Number: FCSAK05984 Award Year: 2021 ? 2022 Comments on Findings and Recommendations: Finding 2022-001?Budget Based Salary Allocation...

FY 2022 Corrective Action Plan Audit Firm: RSM US LLP 30 South Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 07/01/2021 ? 06/30/2022 Contract Number: FCSAK05984 Award Year: 2021 ? 2022 Comments on Findings and Recommendations: Finding 2022-001?Budget Based Salary Allocation (Compliance and Control Finding)? The Jewish Federation of Metropolitan Chicago (the Federation) allocated staff salaries to the federal program based on budget estimates, which alone does not qualify as support for charges to federal awards. The Federation allocated one employees? salary to the program based on a budgeted rate. All other employees have 100% of their salaries allocated to the program. 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that the non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Action Taken?As the Federation does not have processes and controls in place for federal program time tracking, the Federation will only allocate staff to the program that spend 100% of their time on the program starting July 1, 2022. The required corrective action for Finding 2022-001 for the period 07/01/2021 ? 06/30/2022 was completed on July 1, 2022. The person responsible for completion of the corrective action plan was James Pinkston, Vice President, Accounting. James Pinkston Date Vice President, Accounting Jewish Federation of Metropolitan Chicago 30 South Wells Street, Chicago, IL 60606 Email: jamespinkston@juf.org

View Audit 39575 Questioned Costs: $1

Finding 42111 (2022-002)

None 2022

Lessie Bates Davis Neighborhood House Inc.

IL

Matching / Level of Effort / Earmarking

Management Response: The Neighborhood House, like many organizations, was impacted by the effects of COVID. The effects in the current year resulted in an inability to obtain in-kind contributions to the level necessary to meet AmeriCorps criteria. The Neighborhood House is investigating alternate s...

Management Response: The Neighborhood House, like many organizations, was impacted by the effects of COVID. The effects in the current year resulted in an inability to obtain in-kind contributions to the level necessary to meet AmeriCorps criteria. The Neighborhood House is investigating alternate sources of contributions and will monitor the requirement annually.

View Audit 39402

Finding 42096 (2022-002)

Significant Deficiency 2022

Indianapolis Aids Housing Corporation, Inc.

IN

Questioned Costs Matching / Level of Effort / Earmarking

Statement of condition #2022-002: During the year ended December 31, 2022, the Community paid for payroll expenditures on behalf of another community managed by the Agent totaling $13,772. Recommendation: The other community managed by the Agent should reimburse the Community in the amount of $13,7...

Statement of condition #2022-002: During the year ended December 31, 2022, the Community paid for payroll expenditures on behalf of another community managed by the Agent totaling $13,772. Recommendation: The other community managed by the Agent should reimburse the Community in the amount of $13,772. Action(s) Taken or Planned on the Finding: Agree. The other community managed by the Agent will reimburse the Community $13,772.

View Audit 38773 Questioned Costs: $1

Finding 42091 (2022-003)

Material Weakness 2022

Greenville Public School District

MS

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

2022-003 a. Name of Contact Person Responsible for Corrective Action: Waukesah Townsend ? Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability to ensure compliance with ...

2022-003 a. Name of Contact Person Responsible for Corrective Action: Waukesah Townsend ? Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability to ensure compliance with all state and federal purchasing requirements. c. Anticipated Completion Date: Immediately.

View Audit 38595 Questioned Costs: $1

Finding 42086 (2022-003)

None 2022

Chesterfield Marlboro Economic Opportunity Council INC

SC

Matching / Level of Effort / Earmarking Special Tests & Provisions

2022-003 ? Maintenance of Reserve Account Condition: In 2016 the Agency closed on a U.S. Department of Agriculture Rural Development (?USDA-RD?) loan. This loan requires that the Agency establish and maintain a Reserve Account, contributing to it until the account balance equals one annual payment ...

2022-003 ? Maintenance of Reserve Account Condition: In 2016 the Agency closed on a U.S. Department of Agriculture Rural Development (?USDA-RD?) loan. This loan requires that the Agency establish and maintain a Reserve Account, contributing to it until the account balance equals one annual payment amount. The balance as of December 31, 2022, should be $3,271.44. The Agency has not yet established such a Reserve Account. As a result of this condition, the Agency did not have the Reserve Account required by the terms of its USDA-RD loan. Corrective Action Planned: The Agency will establish a Reserve Account, contribute an amount so as to meet the required balance at that date and continue monthly contributions until the maximum required balance is met. Name of Contact Person Responsible for Corrective Action: Deborah E. Clyburn, Deputy/Fiscal Director Anticipated Completion Date: October 31, 2023

View Audit 45583

Finding 42084 (2022-001)

Material Weakness 2022

Chesterfield Marlboro Economic Opportunity Council INC

SC

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Finding 2022-001 ? Accounting for Notes Payable Condition: In 2016 the Agency closed on a U.S. Department of Agriculture Rural Development (?USDA-RD?) loan. In 2018 and 2019 the Agency borrowed a total of $143,098 under this loan. The liability associated with this note payable was not recorded in ...

Finding 2022-001 ? Accounting for Notes Payable Condition: In 2016 the Agency closed on a U.S. Department of Agriculture Rural Development (?USDA-RD?) loan. In 2018 and 2019 the Agency borrowed a total of $143,098 under this loan. The liability associated with this note payable was not recorded in the Agency?s financial records. Internal controls over financial reporting should be in place to provide reasonable assurance that notes payable are recorded in the Agency?s financial books and records at inception and are reported in accordance with accounting principles generally accepted in the United States. As a result of this condition, the Agency?s financial records did not include the liability associated with this loan. It was necessary for the external auditors to make adjustments to the Agency?s accounting records so that the financial statements would be presented in accordance with generally accepted accounting standards. Corrective Action Planned: The Agency will establish procedures to ensure that there is strong communication between administrative and financial management so as to identify any borrowing transactions requiring recording in the financial books and records. Name of Contact Person Responsible for Corrective Action: Deborah E. Clyburn, Deputy/Fiscal Director Anticipated Completion Date: August 1, 2023

View Audit 45583

Finding 42044 (2022-001)

Material Weakness 2022

Flower Hill Institute

NM

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.405

The Organization billed the federal government for amounts of costs that had not yet been incurred and is at-risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements. Statement of Concurrence or Nonconcurrence: Flower Hill has been billing the U...

The Organization billed the federal government for amounts of costs that had not yet been incurred and is at-risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements. Statement of Concurrence or Nonconcurrence: Flower Hill has been billing the US Department of Agriculture 100% of its annual expenses in equal monthly amounts whether the total amount billed was expensed or not. According to audit, this is not allowable under a cost reimbursable contract. The organization agrees with, understands this finding and has already implemented corrective action to this finding. Questioned Costs $186,089 Corrective Action: Corrective action has been taken. FHI has discussed this finding with grantor (USDA Department of Agriculture) as has Auditor. To date, there has been no action taken by the USDA. As of July 2023, FHI has been billing only reimbursable amounts for direct costs incurred and for the approved 10% indirect rate. Name of Contact Person: Person responsible for completing the corrective action plan is Nicole Mast, Director of Operations, nmast@flowerhill.institute. Projected Completion Date: July 2023 Oversight: Billings will be monitored on a monthly basis to ensure full implementation through the end of the current contract (currently March 2026).

View Audit 43032 Questioned Costs: $1

Finding 42043 (2022-003)

Material Weakness 2022

Jacksonville College

TX

Matching / Level of Effort / Earmarking Cash Management Material Weakness § 200.303

Finding 2022-003: Information on the Federal Program: 84.42SF - Higher Education Emergency Relief Fund - institutional Portion, 84.42SE- Higher Education Emergency Relief Fund - Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 2...

Finding 2022-003: Information on the Federal Program: 84.42SF - Higher Education Emergency Relief Fund - institutional Portion, 84.42SE- Higher Education Emergency Relief Fund - Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from GS and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from GS and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. The Supplemental Agreement published by the U.S. Depaitment of Education pe1tammg to Supplemental Grant Funds identifies that funds not disbursed within 3 days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution's auditors, and/or the Department's Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition: During testing of cash management compliance requirements, it was noted that Jacksonville College had drawn down the entirety of the HEERF awards in 2021 and recorded $1,302,078. In 2022, the College had expended the majority of the funds but continues to report a deferred liability of $42,887 related to prematurely drawn-down HEERF funds. Context: Jacksonville College did not review compliance requirements related to drawing down of grant funds and over-drew funds related to the HEERF grant. Questioned Costs: $42,887 remaining in Deferred Income. Cause: A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. Effect or Potential Effect: The College was not in compliance with Federal requirements of the COVID-l 9 Education Stabilization Fund. 44 Repeat Finding: Not a repeat finding. Recommendation: We recommend that the College put into place controls that require review of grant requirements prior to drawing down funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College regrets that this was the process that was used. The failure to review the requirements for the draw-down of HEERF funds was managed by a previous administration. When it was discovered that the proper process was not used by the previous administration, immediate controls and policy reviews were put into place to avoid any further issues of non-compliance. Specifically, Cabinet held weekly meetings where the Executive Vice President was responsible to update Executive Administration with the current status on the utilization of funds. Since that time, a new president has been put into place by the Board of Trustees. The president is committed to following whatever requirements are mandated for all federal programs. In collaboration with all Cabinet members, relevant departments on campus, and a financial consultant, the College will avoid any further issues of non-compliance.

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