Corrective Action Plans

Finding 35202 (2022-002)

Significant Deficiency 2022

IL

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

Finding No. 2022-002 ? Salaries and Benefits Not Supported by Proper Time and Effort Documentation Federal Program: Crime Victim Assistance Project No: 219001 and 216001 CFDA No: 16.575 Passed Through: Illinois Coalition Against Domestic Violence and Illinois Coalition Against Sexual Assault Federa...

Finding No. 2022-002 ? Salaries and Benefits Not Supported by Proper Time and Effort Documentation Federal Program: Crime Victim Assistance Project No: 219001 and 216001 CFDA No: 16.575 Passed Through: Illinois Coalition Against Domestic Violence and Illinois Coalition Against Sexual Assault Federal Agency: U.S. Department of Justice Condition: During our testwork, we noted the following: ? Two employee?s timesheets did not reflect the correct allocation percentages determined by the Organization, and ? One employee did not have a time and effort certification submitted during the 4th quarter of 2022. Plan: The Survivor Empowerment Center, Inc. is currently in the process of training a new HR Specialist and putting together a step-by-step checklist for completing payroll to ensure all steps are taken. This checklist includes a review of payroll by the Assistant Director. Anticipated Date of Completion: By February 10, 2023 ? the next payroll. Name of Contact Person: Susan Hicks, Assistant Director

View Audit 24593

Finding 35174 (2022-008)

Significant Deficiency 2022

City of Woonsocket

RI

HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

Name of Contact Person: Veronicka Vega Corrective Action Plan: The division of housing and community development is now fully staffed, which will ensure that proper monitoring is completed annually. Current staff has completed HUD training modules on monitoring to ensure that monitoring that takes...

Name of Contact Person: Veronicka Vega Corrective Action Plan: The division of housing and community development is now fully staffed, which will ensure that proper monitoring is completed annually. Current staff has completed HUD training modules on monitoring to ensure that monitoring that takes place will follow all guidelines. With the updated catalogue of all HOME loans, the division of housing and community development can have an accurate list of properties that are in the period of affordability and subject to monitoring. Staff will refer to monitoring files from previous years to create documents and letters to be sent to homeowners. Proposed Completion Date: 06/30/2023

View Audit 29946

Finding 35173 (2022-007)

Material Weakness 2022

City of Woonsocket

RI

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

Name of Contact Person: Veronicka Vega Corrective Action Plan: The City of Woonsocket has developed policies and procedures in order to facilitate the proper standards for documentation of income eligibility. The department will ensure that proper approvals will be solicited from the HOME Program ...

Name of Contact Person: Veronicka Vega Corrective Action Plan: The City of Woonsocket has developed policies and procedures in order to facilitate the proper standards for documentation of income eligibility. The department will ensure that proper approvals will be solicited from the HOME Program Compliance Officer after thorough review. Written agreement documentation will be revised to include the requirements from the new compliance manual. The City of Woonsocket plans to procure grant management software which will streamline the application process and allow for improved recordkeeping to ensure compliance with all policies and procedures. Proposed Completion Date: 06/30/2023

View Audit 29946

Finding 35172 (2022-002)

Material Weakness 2022

City of Woonsocket

RI

Reporting Subrecipient Monitoring Eligibility

Name of Contact Person: Veronicka Vega Corrective Active Plan: In the past year, the City has worked to develop an updated record of all HOME assisted projects. Staff thoroughly catalogued all program files creating separate documents for files that are discharged or still active. The documents ca...

Name of Contact Person: Veronicka Vega Corrective Active Plan: In the past year, the City has worked to develop an updated record of all HOME assisted projects. Staff thoroughly catalogued all program files creating separate documents for files that are discharged or still active. The documents can be reviewed to add monitoring information. The document contains the period of affordability and the amount due at payoff. Proposed Completion Date: 6/30/23

View Audit 29946

Finding 35167 (2022-006)

Significant Deficiency 2022

City of Woonsocket

RI

Equipment & Real Property Management Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Name of Contact Person: Alyssa McDermott Corrective Action Plan: The City of Woonsocket has experienced significant turnover over the past years. With the division of housing and community development fully staffed, a thorough review of project files has occurred. Properties that were funded throu...

Name of Contact Person: Alyssa McDermott Corrective Action Plan: The City of Woonsocket has experienced significant turnover over the past years. With the division of housing and community development fully staffed, a thorough review of project files has occurred. Properties that were funded through CDBG or HOME Entitlement funds are fully documented. Properties that are not owned by the City of Woonsocket or received funding from CDBG or HOME entitlement funds are not documented in this office. Properties owned by the Redevelopment Agency of Woonsocket, Woonsocket Housing Authority, or properties that HUD have foreclosed on are not documented by this office. Proposed Completion Date: 06/30/2023

View Audit 29946

Finding 35160 (2022-004)

None 2022

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

FINDING 2022-004? COD Disbursement Dates Program Name: TEACH Grant Federal Pell Grant Program ALN and Program Expenditures: 84.379 ($9,410) 84.063 ($684,817) Award Number: P379T223315 P063P213315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Th...

FINDING 2022-004? COD Disbursement Dates Program Name: TEACH Grant Federal Pell Grant Program ALN and Program Expenditures: 84.379 ($9,410) 84.063 ($684,817) Award Number: P379T223315 P063P213315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for two of the three students receiving TEACH Grants and two of the thirty students receiving Federal Pell Grant funds in our sample. A total of four students were affected by this finding. Corrective Action Plan: The Student Financial Aid Director created a ticket with the third party administrator to have them correct the disbursement dates for the students in question in COD in November 2022. The corrections were made in December 2022. Going forward, the Student Financial Aid Director will verify the disbursement dates agree when the payments are made. Anticipated Completion Date: The corrective action was completed in December 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

View Audit 33952

Finding 35157 (2022-005)

None 2022

Randall University

OK

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

FINDING 2022-005 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,119,033) Award Number: P268K223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was repo...

FINDING 2022-005 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,119,033) Award Number: P268K223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for nine of the forty students selected for testing. Corrective Action Plan: Management agrees with this finding The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2022. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

View Audit 33952

Finding 35155 (2022-002)

None 2022

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2022-002 ? Exit Interview Program Name: Federal Direct Student Loan Program TEACH Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.379 ($9,410) Award Number: P268K223315 P379T223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: ...

FINDING 2022-002 ? Exit Interview Program Name: Federal Direct Student Loan Program TEACH Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.379 ($9,410) Award Number: P268K223315 P379T223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Nine of the forty federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete. Corrective Action Plan: Exit interview instructions were sent to the students in question in October and November 2022. Procedures have been improved to ensure an exit interview is completed when a student withdraws from the University. The process implemented is that a spreadsheet has been created that compares the enrolled credit hours for each student for the Fall -vs- Spring semester of the current Academic Year and the Spring -vs- Fall semester of the next Academic Year. This spreadsheet will identify which students should be receiving exit interview notifications, as well as, any student who needs to have NSLDS enrollment status updated. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

View Audit 33952

Finding 35153 (2022-002)

Material Weakness 2022

City of Seymour

IN

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

Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of thi...

Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of this report is auto populated by the website. My responsibility was to confirm the data, respond if we are using the Standard Allowance, and a brief description of our plan to distribute. Moving forward, all US Treasury reports will be reviewed by either the Mayor or 2nd Deputy, and signed off on once submitted by the Clerk/Treasurer. A copy will be maintained with initials/signatures in the Treasury File in the Clerk/Treasure?s office. Anticipated Completion Date 7/2023

View Audit 38024

Finding 35146 (2022-001)

Material Weakness 2022

Goodwill Industries of Middle Georgia, Inc. and Affiliates

GA

Student Financial Aid Special Tests & Provisions Eligibility

Audit Finding Number: 2022-001-Enrollment Reporting: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar's Office and the Financial Aid Office. This plan was developed in Au...

Audit Finding Number: 2022-001-Enrollment Reporting: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar's Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government's NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the HSLDS because available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse, and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule. Luke Schultheis, Executive Vice President of Education 6/13/23

View Audit 38022

Finding 35139 (2022-001)

Material Weakness 2022

Devils Lake Public School District No. 1

ND

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

2022-001 COVID 19 - EDUCATION STABILIZATION FUND ? INTERNAL CONTROLS AND WAGE RATE REQUIREMENTS ? ALN 84.425D ? MATERIAL WEAKNESS AND MATERIAL NON-COMPLIANCE Condition: Devils Lake Public School District did not comply with the wage rate requirements applicable to the Elementary and Secondary Scho...

2022-001 COVID 19 - EDUCATION STABILIZATION FUND ? INTERNAL CONTROLS AND WAGE RATE REQUIREMENTS ? ALN 84.425D ? MATERIAL WEAKNESS AND MATERIAL NON-COMPLIANCE Condition: Devils Lake Public School District did not comply with the wage rate requirements applicable to the Elementary and Secondary School Emergency Relief Fund (ESSER) funding received for the renovation of a current building into a childcare and preschool center. Further, Devils Lake Public School District did not establish and maintain effective internal controls to ensure certified payrolls are received from the contractors. Corrective Action Plan: We agree, Devils Lake Public Schools will make sure to check with North Dakota Department of Public Instruction and correct federal departments to insure that we are following the proper guidelines and requirements of the grant. Anticipated Completion Date:. We will start implementation on 7/1/2023 and continue with this moving forward.

View Audit 37113

Finding 35133 (2022-003)

Material Weakness 2022

Jemez Mountain School District

NM

Equipment & Real Property Management Special Tests & Provisions Procurement, Suspension & Debarment

Section II ? Financial Statement Findings 2022-001 [2021-001] ? Internal Control Issues for Payroll (Significant Deficiency) Repeated and Modified Responsible Official?s Plan: Business Manager will review payroll files to ensure that employee contributions are being calculated and withheld properly...

Section II ? Financial Statement Findings 2022-001 [2021-001] ? Internal Control Issues for Payroll (Significant Deficiency) Repeated and Modified Responsible Official?s Plan: Business Manager will review payroll files to ensure that employee contributions are being calculated and withheld properly. ? Timeline for completion of corrective action plan: February 1, 2023 ? Employee position(s) responsible for meeting the timeline: Payroll and Kimberly Cordova, Business Manager 2022-002 [2020-001] ? Purchase Orders Payment Authorization and Supporting Documentation (Significant Deficiency) Repeated and Modified Responsible official?s view: District will continue to train and remind employees on the District and State policy in regard to payment of goods and services. ? Timeline for completion of corrective action plan: February 1, 2023 ? Employee position(s) responsible for meeting the timeline: Kimberly Cordova, Business Manager Section IV ? 12-6-5 NMSA 1978 Findings 2022-004 [2020-006] ? Improper Approval of Budget Adjustment (Other Non-compliance) Repeated and Modified Responsible Official?s Plan: District will ensure that all budget adjustments are recorded in the accounting system once they have been approved. ? Timeline for completion of corrective action plan: February 1, 2023 ? Employee position(s) responsible for meeting the timeline: Kimberly Cordova, Business Manager Section IV ? 12-6-5 NMSA 1978 Findings (Continued) 2022-005 [NM 2020-005] ? Improper Cash Controls Outstanding Warrants (Other Non-Compliance) Repeated and Modified Responsible Official?s Plan: Management will adequately monitor outstanding warrants and ensure that they are removed within the one-year time. ? Timeline for completion of corrective action plan: February 1 2023 ? Employee position(s) responsible for meeting the timeline: Vada Ortega, Accounts Payable/Payroll and Kimberly Cordova, Business Manager Section IV ? 12-6-5 NMSA 1978 Findings (Continued) 2022-006 ? Improper Reimbursement of Travel Expense (Other Non-Compliance) Responsible Official?s View: Management will ensure that they are reimbursing employees properly for qualified expenses and ensure that policies are consistent for all employees. ? Timeline for completion of corrective action plan: February 1, 2023 ? Employee position(s) responsible for meeting the timeline: Vada Ortega, Accounts Payable and Kimberly Cordova, Business Manager Section III ? Federal Findings 2022-003 Failure to Follow Davis Bacon and Capital Expenditure Requirements (Material Weakness and Other Matters) Responsible Official?s Plan: The District will establish a policy and implement internal control procedures regarding the review of all grant award letters to ensure that the District is aware of all requirements that are imposed on the District with accepting the funds. The District will work with the contractor to obtain weekly wage certifications going back from the beginning of the project forward to be able to demonstrate that the appropriate wages are paid during the full time-frame of the project ? Timeline for completion of corrective action plan: February 1, 2023 ? Employee position(s) responsible for meeting the timeline: Troy Green, Maintenance Supervisor/Kimberly Cordova, Business Manager

View Audit 35377

Finding 35121 (2022-001)

Significant Deficiency 2022

The Institute of World Politics

DC

Student Financial Aid Allowable Costs / Cost Principles Cash Management § 200.303

Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management ...

Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management agrees with the recommended corrective action for which the Institute immediately began to remediate. This relates to the National Student Loan Data System (NSLDS) site modernization resulting in NSLDS functionality/operational pauses that included the data flow from National Student Clearinghouse (NSC) to NSLDS. This issue has been resolved. The Institute has established a procedure to ensure this does not happen again. It should also be noted that as of December 2022, the Director of Financial Aid and Registrar have implemented procedures and controls to ensure that all required reporting to the NSLDS is performed accurately and in a timely manner. Each month?s enrollment data submission to National Student Clearinghouse by the Registrar will be reviewed by the Director of Financial Aid to verify the consistency of the data in NSLDS; The Director of Admissions and the Registrar will review submission of the 10 business days after the original submission and on the 14th of each month prior to the submission of the next batch of enrollment data to the National Student Clearinghouse. This will allow IWP to correct any inaccurate reporting and verify timely submissions to both systems, providing a preventive control in addition to the resolution of the NSLDS functionality pause.

View Audit 30178

Finding 35104 (2022-002)

Material Weakness 2022

The Housing Authority of the City of Slidell

LA

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

Action Taken: HACS Interim Executive Director has reviewed the applicable HUD notices and will prepare and recommend a change to its current procurement policy by 3/30/2023 to codify this action for future engagements.

View Audit 31989 Questioned Costs: $1

Finding 35007 (2022-001)

None 2022

Town of Hinsdale

NH

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.302 § 200.305 § 200.318 § 200.319 § 200.320

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Kathryn Lynch, Town Administrator Corrective Action Plan: The Town will be updating the Town?s procedures and policies...

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Kathryn Lynch, Town Administrator Corrective Action Plan: The Town will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Anticipated Completion Date: June 30, 2023

View Audit 37865

Finding 35001 (2022-004)

Significant Deficiency 2022

Stevenson University, Inc.

MD

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

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will identify student loan...

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will identify student loan distributions which exclude the appropriate communication code. Additionally, responsibility for all loan correspondence has been moved to the loan coordinator position to ensure completion. Anticipated Completion Date: March 31, 2023

View Audit 36678

Finding 34992 (2022-005)

None 2022

Stevenson University, Inc.

MD

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

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University has implemented this Student Self Service component of Colleague. Beginning in academic year 2022-2023, this system was used by students for acceptance of all loan awards and distribu...

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University has implemented this Student Self Service component of Colleague. Beginning in academic year 2022-2023, this system was used by students for acceptance of all loan awards and distributions. Acceptance of the awards will be automatically captured by the system. The Associate Director of Financial aid will run weekly Informer and Blackboard system reports to confirm student withdrawal dates. The Associate Director will then calculate based on the withdraw date to ensure an accurate return of funds calculation. The Director of Financial Aid will verify all return of funds calculations performed by the Associate Director within the required time period. Anticipated Completion Date: July 1, 2022

View Audit 36678

Finding 34991 (2022-003)

None 2022

Stevenson University, Inc.

MD

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from an entirely manual verification process to a hybrid automated electronic process utilizing a combination of both Informer and Colleague reports. These reports will...

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from an entirely manual verification process to a hybrid automated electronic process utilizing a combination of both Informer and Colleague reports. These reports will focus on certain aspects of ISIR information such as Adjusted Gross Income and Taxes paid. Communication management rules will be validated by the Enrollment Management office. Anticipated Completion Date: March 31, 2023

View Audit 36678

Finding 34947 (2022-001)

None 2022

Pacific School of Religion

CA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The find...

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary: and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Recommendation: The School should revise its procedures to ensure accurate enrollment information is sent to NSLDS with the required timeframe for all students. Corrective Action Plan: Procedural changes implemented by the school during the Spring 2022 semester that allow for more frequent and timely enrollment reporting will correct this type of enrollment reporting error going forward. In addition, school administration will update procedures to verify status start dates for any enrollment changes specifically match the student?s enrollment in the student information system. Sincerely, Natasha Lee Vice President for Finance and Administration

View Audit 34647

Finding 34945 (2022-001)

None 2022

Rose-Hulman Institute of Technology

IN

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

The Institute will examine the documented destruction date on other student related files related to federal compliance requirements to ensure accuracy of document destruction date.

View Audit 32794

Finding 34936 (2022-001)

Material Weakness 2022

Lebanon Community School Corporation

IN

Questioned Costs Internal Control / Segregation of Duties Cash Management § 200.303

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: 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 eligibility compliance...

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: 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 eligibility compliance requirements that are performed by the Special Education Cooperative on behalf of the School Corporation. Context: The School Corporation participates in a Special Education Co-op. In 2015, the Co-op provided an avenue through a third-party company, for the member school districts to obtain reimbursement for Medicaid services. It was discovered in 2021 that the yearly parental disclosure statements had not been completed for Medicaid eligibility compliance. Due to this oversight, each member school has had to voi transactions through the third-party company and pay back the amount of these transactions from August 9, 2015 through April 23, 2021. The School Corporation?s amount owed was $481,276 for the period identified during 2015-2021. The School Corporation completed a Voluntary Self-Disclosure of Provider of Overpayments Packet through the Indiana Family & Social Services Administration?s Office of Medicaid Policy and Planning Office to reimburse the amounts owed. The amount related to this period July 1, 2020 through June 30, 2022 was indeterminable. The full amount was paid back prior to June 30, 2021. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Parental disclosure statements are completed annually for Medicaid eligibility compliance. This has already been implemented. Responsible Party and Timeline for Completion: Madeline Sandberg, Director of BCNWH Joint Services, 7/1/2021

View Audit 32733 Questioned Costs: $1

Finding 34910 (2022-005)

Material Weakness 2022

Lebanon Community School Corporation

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.309 § 200.343 § 200.461

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: 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 equipment ...

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: 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 equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34909 (2022-004)

Material Weakness 2022

Lebanon Community School Corporation

IN

Equipment & Real Property Management Procurement, Suspension & Debarment Material Weakness § 200.303 § 200.313

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: 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 equipment r...

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: 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 equipment requirements of the Equipment and Real Property Management compliance requirement. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it indeterminable whether equipment purchases were made by the Cooperative with federal funds, or to identify equipment expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds was properly recorded and maintained in the School Corporation's equipment records. The Cooperative also did not maintain records for the disposition of equipment purchased with federal grant funds. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34902 (2022-003)

Material Weakness 2022

Garrett-Keyser-Butler Community School District

IN

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

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description ...

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls to make sure all timesheets have been received and signed by supervisors prior to payroll being completed. Anticipated Completion Date: Garrett-Keyser-Butler Community School District is no longer the LEA for the Head Start Program. However, this will be implemented immediately at the corporation.

View Audit 32731

Finding 34898 (2022-002)

Significant Deficiency 2022

Garrett-Keyser-Butler Community School District

IN

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

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Bu...

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

View Audit 32731

Corrective Action Plans

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