Corrective Action Plans

Finding 41638 (2022-001)

Significant Deficiency 2022

CT

HUD Housing Programs Eligibility Matching / Level of Effort / Earmarking

1. Finding 2022-001 a. Comments on the Finding and Each Recommendation We recommend that the Board of Directors continues to work with HUD to resolve the outstanding balance. b. Action(s) Taken or Planned on the Finding The Board of Directors has continued to work with HUD to resolve the outstan...

1. Finding 2022-001 a. Comments on the Finding and Each Recommendation We recommend that the Board of Directors continues to work with HUD to resolve the outstanding balance. b. Action(s) Taken or Planned on the Finding The Board of Directors has continued to work with HUD to resolve the outstanding balance. The last communication from HUD was on July 28, 2022 noting the issue is currently under review.

View Audit 38931

Finding 41637 (2022-002)

Material Weakness 2022

Wayland Baptist University

TX

Questioned Costs Student Financial Aid HUD Housing Programs

Incorrect and Late Returns of Title IV Funds (R2T4) Planned Corrective Action: Executive Director of Financial Aid has reviewed and updated policy and COD system set-up to ensure correct calculations. Executive Director of Financial Aid provided in-house R2T4 training specific to WBU for all staff ...

Incorrect and Late Returns of Title IV Funds (R2T4) Planned Corrective Action: Executive Director of Financial Aid has reviewed and updated policy and COD system set-up to ensure correct calculations. Executive Director of Financial Aid provided in-house R2T4 training specific to WBU for all staff as well as will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. Audit report is now generated weekly to identify students who have withdrawn and reviewed by appropriate staff to ensure timely R2T4 completions. Executive Director of Financial Aid is working with IT (and others) to integrate BlackBoard course activity data with PowerCampus for most accurate record of course attendance and last date of academically related activity for all students. This implementation is being piloted during Fall 2 session, with plans for full implementation for the Spring 2023 term. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

View Audit 40639 Questioned Costs: $1

Finding 41632 (2022-001)

None 2022

Okaloosa - Walton Jobs and Education Partnership, Inc.

FL

Matching / Level of Effort / Earmarking

In an effort to meet the expenditure requirements CareerSource Okaloosa -Walton has modified their Two Year Plan allowing more funds to be spent on In School Youth. That plan was approved in January 2023. It has been difficult to find Out of School Youth. The change in our plan gives us more flexibi...

In an effort to meet the expenditure requirements CareerSource Okaloosa -Walton has modified their Two Year Plan allowing more funds to be spent on In School Youth. That plan was approved in January 2023. It has been difficult to find Out of School Youth. The change in our plan gives us more flexibility to work with In School Youth. Staff have started actively searching for In School Youth to enroll in work experiences. Management will track the expenditure rate and make adjustments of effort no less than once a quarter.

View Audit 40014

Finding 41624 (2022-001)

Significant Deficiency 2022

Concordia University Irvine

CA

Questioned Costs Student Financial Aid Significant Deficiency

Concordia University Irvine An Educational Institution of The Luther Church - Missouri Synod Schedule of Findings and Questioned Costs June 30, 2022 Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Age...

Concordia University Irvine An Educational Institution of The Luther Church - Missouri Synod Schedule of Findings and Questioned Costs June 30, 2022 Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University's interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections. Anticipated completion date is May 1, 2023 Contact Lori McDonald at lori.mcclonald@cui.eclu or 949-214-3074

View Audit 39365 Questioned Costs: $1

Finding 41615 (2022-004)

None 2022

Mount Saint Mary's University

CA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-004: Nursing Student Loans Program: Nursing Student Loans (NSL) Assistance Listi...

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-004: Nursing Student Loans Program: Nursing Student Loans (NSL) Assistance Listing Number (ALN): 93.364 Federal Agency: U.S. Department of Education Federal Award Identification Number: Unknown Federal Award Year: June 30, 2022 Criteria: U.S. Department of Education regulations require for a NSL loan, repayment must begin nine months after the student ceases to be a full-time or half-time student, except as required in 42 CFR 57.310(a). For NSL loans after November 13, 1998, the 10 ?year repayment period may be extended for ten years for any student borrower who, during the repayment period failed to make consecutive payments and who, during the last 12 months of the repayment period, has made at least 12 consecutive payments. Institutions must exercise due care and diligence in the collection of loans. Many institutions engage third-party servicers for billing, collection, and processing deferment and cancellation requests, although these institutions remain responsible for compliance. Institutions are required to timely convert loans to repayment, establish repayment plans, process cancellation requests, and service loans as required. Condition: Seven of seven students who were tested had errors. The University had difficulty providing a listing of students who entered repayment on their NSL during fiscal year 2022. ? For one student, selected from an initial listing that ended up not being correct, the system screen showed the student separated from the University on May 8, 2020, however, the student was not noted as graduated for reporting to the NSLDS or provided with exit counseling to establish the repayment plan. ? Two students were noted as missing from the final listing provided and the servicer screen showed their status as `in school?, however they should have been indicated as `in repayment?. For one of these students, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For three students that had separated from the University, the dates differed between system screens and servicer screens and exit counseling. One of these students was provided exit counseling but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For one additional student, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. The sample was not a statistically valid sample as the auditors ended up testing the entire population. Cause: The University?s processes are not ensuring that information for NSL students is correct in the University or servicer systems, or that exit counseling is being performed or repayment plans established. Effect: Students with NSL are not being converted to repayment timely with established payment plans that can result in loans not being repaid. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve issues in a timely manner to facilitate compliance with NSL regulations. Management?s Response: The University agrees with the recommendation and will review system, reporting functionalities and business processes contributing to these errors and implement corrective measures. Correction Action: The University will dedicate a Student Accounts staff to manage the loan program by providing addition policy training on processes and technology training with the third party loan processor. Student Account Staff will perform timely reconciliations on all Federal nursing loan programs with the external loan servicer to ensure the student?s status is accurate. We will be exploring the possibility of reporting directly to the NLDS.

View Audit 38874

Finding 41614 (2022-003)

None 2022

Mount Saint Mary's University

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-003: Enrollment Reporting Program: Federal Direct Loan Program Assistance Listin...

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-003: Enrollment Reporting Program: Federal Direct Loan Program Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221157 Federal Award Year: June 30, 2022 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 a 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. Condition: Five of the twenty-five students who were tested had incorrect statuses, status dates or program information reported to NSLDS. One student was reported correctly as graduated on the campus level reporting but was not reported as graduated on the program level. Two other students that graduated were not reported as graduated on campus or program level reporting. Two students were reported with the status effective date on both the campus and program level reporting that did not agree to the University?s system support, subsequently for one student the registrar changed the system date noting it had not been updated in error. The sample was not a statistically valid sample. Cause: The University?s processes did not ensure accurate reporting to NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: The University agrees with the recommendation and will review system and business processes contributing to these errors and implement corrective measures. Correction Action: MSMU will add an additional enrollment and degree report to our current schedule of one per month. This will allow for more frequent enrollment reporting that will correct this type of enrollment reporting error going forward. In addition, Registrar?s Office will update procedures to verify status start dates for any enrollment changes to specifically match the student?s enrollment in the student information system. MSMU will continue to explore the possibility of reporting directly to the NSLD rather than having to abide by the Clearing House policies. In the meantime, when graduating a student Registrar staff will check to see if the student is currently enrolled at MSMU, and if they are not, the staff member will go to the Clearing House and manually mark that program as graduated with a G. The Registrar?s Office will have multiple staff members verify the degree data uploaded to the Clearing House.

View Audit 38874

Finding 41612 (2022-001)

Significant Deficiency 2022

Mount Saint Mary's University

CA

Questioned Costs Student Financial Aid Eligibility

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Stude...

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: Two students of five students tested had incorrect/missing calculations. One student was disqualified during the term after the first 8 week session in the Associate Degree of Nursing and could not continue into the second 8 week session. The University did not note the disqualification and withdrawal timely and did not perform an R2T4 calculation as required and the $2,473.53 of direct loans calculated by the auditor was not returned. One student's number of days attended (numerator) was calculated incorrectly at 25 days but should have been 26 days and therefore $59.53 too much Pell was returned. The auditors noted that a total of four students withdrew from the Associate Degree of Nursing program from the population file provided, and two students were not selected by the auditors. The University reviewed these students and noted one student completed more than 60.01% although the auditors learned that the student was disqualified at the end of the first 8 week session and therefore should have had an R2T4 calculation and return, and one student the R2T4 calculation was performed, however the auditor noted the number of days attended (numerator) was calculated incorrectly at 51 days but should have been 52 days and included a negative amount of Pell grant that ?could have been disbursed?. The University noted that an estimated term end date of May 7, 2022 was input in the system and was not updated to the actual term end date of May 6, 2022. As this could impact all students who withdrew during the Spring 2022 term, the auditors noted 21 students in the population file provided who withdrew during spring 2022, and four of those students were noted as withdrawing before 60% and were not tested by the auditors. The University reviewed these students and noted two additional students with incorrect denominators used in their calculations, the auditor reviewed only the denominators for these students and agrees. The sample was not a statistically valid sample. Cause: The University?s controls surrounding completing timely and accurate refund calculations did not operate as designed and resulted in exceptions. Effect: The calculations of funds to be returned to the Department of Education did not occur or were incorrect. Questioned costs: Questioned costs of $2,301.70 (ALN No. 84.268), and $59.53 (ALN No. 84.063) were noted during testing. Context: Exceptions were noted for 2 of the 5 students selected for testing. There were a total of 33 students who withdrew during fiscal year 2022 that received Title IV aid. Recommendation: It is recommended that University personnel review the calculations generated by the University's software system to ensure they are timely and accurate. It is also recommended that the control structure be reviewed to ensure all student who withdraw during a term are identified in a timely manner. Management?s Response: The University will review withdrawal controls and procedures so that students who withdraw are identified and correctly processed in a timely manner. The University will also engage our software system Consultant to examine system settings to ensure accurate and timely Return of Title IV calculations occur. Further, management reviewed and performed the same recalculations for the remaining 28 students in the population. Of those, 24 had no findings or errors and the remaining only had a small amount of excess available Pell funding or loan eligibility. The Pell amounts were awarded and students with loan availability were notified and asked to respond if they wished to borrow the additional funds. All amounts were not material. Correction Action: The Registrar?s Office will provide the Financial Aid Office with final academic calendars in advance to ensure that proper start and end dates of academic periods are correct in the Financial Aid System. Multiple employees (as opposed to a single person) in the Financial Aid office will be tasked with confirming the accuracy of the calendar set-up in advance of the start of each semester. We have also reminded the Nursing department of timely communication of student disqualifications to the Registrar?s office to assist in recognizing students who may fall into this category. In addition to these steps, the University is exploring systematic changes in colleague that will split the ADN and ABSN programs into two separate 8 week sessions with separate start/end dates, as opposed to one 16 week semester that has two sessions within. An RT24 output report will now be automatically generated and reviewed by the Director of Financial Aid every two weeks. Furthermore, the University will apply the same refund calculation policy to ADN students who are academically disqualified, as we do all other student populations. This will ensure accuracy when determining the number days attended and earned amounts of federal aid when processing R2T4 calculations. The University will dedicate additional resources, staff and technology, to manage withdrawal notifications and to process then in a timely manner.

View Audit 38874 Questioned Costs: $1

Finding 41583 (2022-001)

Significant Deficiency 2022

Lawrence Union Free School District

NY

School Nutrition Programs Procurement, Suspension & Debarment Cash Management § 200.303

2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Educat...

2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District?s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2023.

View Audit 38733

Finding 41579 (2022-007)

Material Weakness 2022

Shiloh Neighborhood Development Corporation

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

FINDING 2022-007: Non-compliance with Wage Rate Requirements Response: All contracted work related to construction or remodeling that uses Impact Aid funds will require contractors to provide weekly payroll reports that guarantee the Davis-Bacon Wage statute is followed. District Clerk and/or Busi...

FINDING 2022-007: Non-compliance with Wage Rate Requirements Response: All contracted work related to construction or remodeling that uses Impact Aid funds will require contractors to provide weekly payroll reports that guarantee the Davis-Bacon Wage statute is followed. District Clerk and/or Business Manager will ensure each contractor submits their certified payroll for each job before any payments are distributed to contractors for work completed.

View Audit 51545

Finding 41574 (2022-001)

Significant Deficiency 2022

Bexar Rhf Housing, Inc. Dba Bexton Place 115-Ee078

CA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of Condition 2022-001 (Assistance Listing 14.157): During the year ended March 31, 2022, the Corporation paid expenses totaling $23,539 on behalf of an affiliated entity without HUD approval. Recommendation: The affiliated entity should repay $23,539 to the Corporation. Management Response...

Statement of Condition 2022-001 (Assistance Listing 14.157): During the year ended March 31, 2022, the Corporation paid expenses totaling $23,539 on behalf of an affiliated entity without HUD approval. Recommendation: The affiliated entity should repay $23,539 to the Corporation. Management Response: Agree. The affiliated entity repaid the Corporation $23,539 on April 7, 2022.

View Audit 47856 Questioned Costs: $1

Finding 41571 (2022-003)

Significant Deficiency 2022

Eastern Wyoming College

WY

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management § 200.327

2022-003 Reporting Condition: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review a...

2022-003 Reporting Condition: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Correction: With respect to item #1, internal controls will be implemented for a second review of all quarterly reports by a member of the business office to verify accuracy before being submitted to the Department of Education and uploaded to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021. Items #2-4 reference reports that were not reported in a timely manner. Reminders in the calendar have been created to ensure completion of the reports. Information has also been shared with the College webmaster as to when reports need to be uploaded for timely submissions. Internal controls will be used to verify accuracy of data with the financial aid office, but also a final review that shows actual submission of the reports to the Department of Education and to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021.

View Audit 48917

Finding 41549 (2022-001)

Significant Deficiency 2022

Three Rivers Education Foundation, INC

NM

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

2022-001 ? Employee Time and Effort Documentation (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Education Title: Teacher & School Leader Incentive Program Assistance Listing: 84.374 A Passthrough: N/A Award Year: 2022 Condition: The Foundation does not have...

2022-001 ? Employee Time and Effort Documentation (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Education Title: Teacher & School Leader Incentive Program Assistance Listing: 84.374 A Passthrough: N/A Award Year: 2022 Condition: The Foundation does not have a system of internal control to accurately track personnel costs when the individual works on more than one program. The Foundation makes a good-faith effort to budget an individual?s time based on their best estimate of the distribution of the employee?s time over the various programs. However, the Foundation?s employees were not required to track their time on a daily basis and identify which program was worked on during that day. The Foundation did not require those employees who are assigned to multiple cost programs to track and certify their time. The Foundation did not ?true-up? actual time versus budgeted time for the various programs during the year. Auditor?s Recommendation: The Foundation should implement internal control policies and procedures which require employees who work under two or more programs to track their time in a method that allows for proper allocation of expenses between those programs. Additionally, the Foundation should implement a process for employees to certify that their time is properly tracked and allocated. Finally, the Foundation should implement a time-frame to adjust budgeted salaries to actual salaries based upon the tracking performed by employees. Responsible official?s view: Specific corrective action plan for finding: Dr. Linda Coy in conjunction with James Coy, CFO and Patty Eaton, Business Manager have developed a revised process of collecting T & E data from employees affected by this action. Each affected employee will collectdaily activities tied to the percentage of time allocated to their respective positions and submit on a monthly basis to the business office. The business office will calculate the time spent on each project and provide that information back to the employee for adjustment during the following month. The documentation, for each employee that is part of this process will be available to the auditors during the next audit cycle. The HR department will maintain these files for inspection. Timeline for completion of corrective action plan: After consultation with the auditor, it was decided that the effective date for implementation is September 1, 2023. Employee position(s) responsible for meeting the timeline: Dr. Linda Coy, Three Rivers Education Foundation Director & James L. Coy CFO

View Audit 40021

Finding 41498 (2022-002)

Material Weakness 2022

Lighthouse Social Service Centers

CA

Subrecipient Monitoring Cash Management Material Weakness § 200.1 § 200.303

Finding 2022-002 The Corrective Action Plan (CAP) is designed to address audit recommendations related to revenue recognition, timely grant claims submission, and monthly expenditure reconciliation. To enhance revenue recognition, the Finance Department will review and update existing accounting pro...

Finding 2022-002 The Corrective Action Plan (CAP) is designed to address audit recommendations related to revenue recognition, timely grant claims submission, and monthly expenditure reconciliation. To enhance revenue recognition, the Finance Department will review and update existing accounting procedures, provide clearer guidelines, and conduct staff training. The timely submission of grant claims will be ensured through a monitoring mechanism, reporting structure, and an escalation process. Monthly reconciliation of revenue to expenditures will be established, with management reviewing and taking corrective actions as needed. Progress will be closely monitored and reported, with the goal of implementing these improvements immediately, involving the Finance Department, Grants Management Team, and relevant management personnel.

View Audit 38289

Finding 41497 (2022-003)

Significant Deficiency 2022

Columbia College Dba Columbia College Hollywood

CA

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

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent ...

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent to the prior employee, who by that time was no longer with the college. The new individual did not see the notice and was not aware that a refund calculation was required. There was a brief window when all notifications were switched to the new staff member, and this particular status change was processed during that transition. The refund has now been processed and all unearned aid for the term has been returned. We have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

View Audit 38278

Finding 41495 (2022-001)

Significant Deficiency 2022

Columbia College Dba Columbia College Hollywood

CA

Questioned Costs Student Financial Aid Eligibility

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent...

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

View Audit 38278 Questioned Costs: $1

Finding 41478 (2022-004)

Significant Deficiency 2022

Safe and Sound

CA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.1 § 200.303 § 200.403 § 200.414

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified t...

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023

View Audit 37696

Finding 41477 (2022-003)

Material Weakness 2022

Safe and Sound

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403 § 200.430 § 200.431 § 200.447

2022-003 ? Allowable Costs/Activities Allowed or Unallowed: Fringe Benefits and Shared Costs Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer Corrective Action: During the initial year of receiving our first direct federal grant, Safe & Sound calculated fringe benefits bas...

2022-003 ? Allowable Costs/Activities Allowed or Unallowed: Fringe Benefits and Shared Costs Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer Corrective Action: During the initial year of receiving our first direct federal grant, Safe & Sound calculated fringe benefits based on a percentage of the salaries allocated to the grant. Salaries were calculated based on time and effort. Safe & Sound has reviewed the current practices related to allocating fringe benefits and shared costs. Safe & Sound?s Finance team reviewed and verified that we have the adequate fringe benefit and shared costs to meet the costs allocated to this grant. To ensure we have the proper supporting documentation to meet the Uniform Guidance requirements in 2 CFR Sections 200.303 and 200.403, we will implement time and effort documentation for benefit and shared cost allocations on a monthly basis and will review for any necessary budget to actual adjustments. Date Completed: 8/31/2023

View Audit 37696 Questioned Costs: $1

Finding 41467 (2022-003)

Material Weakness 2022

Tri-Creek School Corporation

IN

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

Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity:...

Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Context: The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. 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. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, and Earmarking compliance requirements. 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. The lack of internal controls and noncompliance was isolated to the 19611-045-PN01 and 20611-045-PNO1 grant awards. The Non-Public Proportionate Share expenditures for the 19611-045-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools ona percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirement for the 19611-045-PNO1 grant award was $6,228. The Non-Public Proportionate Share expenditures for the 20611-045-PN01 and 21611-045-PNO1 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required.Views of Responsible Officials and Planned Corrective Actions: The district agrees with the finding and notes as a member of the Northwest Indiana Special Education Cooperative (NISEC), Tri-Creek School Corporation reported their proportionate share based on a percentage of expenditures and had successful audits in doing so. When the Tri-Creek School Corporation was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included a detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee's detailed time and effort report is then provided to the NISEC finance department for a second review and signature before being provided to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B grant in the payroll system bi-weekly based on the time and effort report pertinent to just Tri-Creek Non-Public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Tri Creek?s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Tri-Creek?s proportionate share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is submitted to the Department of Education. Responsible party and timeline for completion: Responsible parties: Lisa Rosinko, Northwest Indiana Special Education Cooperative Chief Financial Officer Anticipated Completion Date: The Northwest Indiana Special Education Cooperative discontinued reporting nonpublic proportionate share expenditures by percentage as of the 2022-2023 school year. An internal control procedure to report nonpublic proportionate share expenditures by detailed time and effort work and expenditures was implemented as of the 2022-2023 school year.

View Audit 37708

Finding 41461 (2022-001)

Significant Deficiency 2022

Sherrard Community Unit School District No. 200

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Response and Corrective Action Plan: The District will review current processes for identifying, coding and reporting federal expenditures and implement processes to ensure amounts reported are supported by the District?s general ledger.

View Audit 37733

Finding 41451 (2022-001)

Material Weakness 2022

Housing Authority of the City of Martinsburg

WV

Cash Management HUD Housing Programs Material Weakness

Finding 2022-001 ? Capital Fund Program Accounting ? Noncompliance & Material Weakness ? Cash Management & Program Compliance ? CFDA # 14.872 ? Grant Years 2018, 2019 Corrective Action Plan: The Martinsburg Housing Authority will review our procedure for requisitioning of funds for CFP payments. ...

Finding 2022-001 ? Capital Fund Program Accounting ? Noncompliance & Material Weakness ? Cash Management & Program Compliance ? CFDA # 14.872 ? Grant Years 2018, 2019 Corrective Action Plan: The Martinsburg Housing Authority will review our procedure for requisitioning of funds for CFP payments. We will establish a payment review and withdrawal procedure to align with the regulations for timely fund withdrawals from LOCCS and payment of funds. Person Responsible: Catherine Dodson, Executive Director Anticipated Completion Date: June 30, 2023

View Audit 37486

Finding 41444 (2022-001)

Significant Deficiency 2022

Southwest Kansas Area Agency on Aging, INC

KS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency § 200.318 § 200.319 § 200.326

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 Southwest Kansas Area Agency on Aging, Inc. respectfully submits the following corrective action plan for the fiscal year ended September 30, 2022. Name and address of independent public accounting firm: Kennedy McKee and Company LLP P...

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 Southwest Kansas Area Agency on Aging, Inc. respectfully submits the following corrective action plan for the fiscal year ended September 30, 2022. Name and address of independent public accounting firm: Kennedy McKee and Company LLP P.O. Box 1477 Dodge City, Kansas 67801 Audit period: October 01, 2021 through September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - Major Federal Award Programs Audit U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Title III Aging Cluster Title III B Supportive Services CFDA 93.044 Title III C Nutrition Services CFDA 93.045 Title III C Nutrition Services Incentive CFDA 93.053 Grant Period: Year ended September 30, 2022 Condition: The Organization did not have a written procurement policy to properly implement all the requirements of 2 CFR Section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Criteria: In accordance with 2 CFR Section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR 200.318 through 200.326 of the Uniform Guidance. Cause: The Organization?s procurement policy does not incorporate all the requirements of 2 CFR Section 200.318 through 200.326 of the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. Southwest Kansas Area Agency on Aging, Inc. Corrective Action Plan February 9, 2023 Recommendation: Management should continue to develop comprehensive written policies and procedures to administer all federal programs. Current written policies should be evaluated for inclusion of and compliance with Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements. If the Oversight Agency has questions regarding this plan, please call Rick Schaffer at (620) 225-8230. Sincerely yours, Rick Schaffer Executive Director 236 San Jose Drive Dodge City, KS 67801

View Audit 36909

Finding 41441 (2022-004)

Significant Deficiency 2022

Freeman Regional Health Services

SD

Equipment & Real Property Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Equipment and Real Property Management Finding Summary: Federal-funded equipment and real property is not disti...

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Equipment and Real Property Management Finding Summary: Federal-funded equipment and real property is not distinguished separately from non-federal-funded equipment and real property within the Facility's fixed asset listing. Responsible Individuals: Phillip Husher, CFO, Freeman Regional Health Services Corrective Action Plan: Freeman Regional Health Services will review our fixed asset policies and procedures in order to identify expenditures for Federal-Funded equipment. We will update our current fixed asset listing to identify federally funded equipment. Anticipated Completion Date: December 31st, 2023.

View Audit 37685

Finding 41435 (2022-001)

Significant Deficiency 2022

Housing Authority of the City of Galveston, Texas

TX

HUD Housing Programs Reporting Significant Deficiency

2022-001 Housing Choice Vouchers - Assistance Listing No. 14.871 - Reporting Recommendation: The Authority should implement processes to ensure...

2022-001 Housing Choice Vouchers - Assistance Listing No. 14.871 - Reporting Recommendation: The Authority should implement processes to ensure the HUD-50058's are submitted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: During this time GHA's HCV program was extremely short staffed and GHA was using temporary employees to assist in program delivery. Specifically, the department suffered two staff- members deaths, one family emergency that removed dedicated staff from this task, and two resignations. GHA has hired and trained new staff and increased the form 50058 submissions times to daily. GHA also provided training to existing staff on the importance of timely completion of form 50058. There is now dedicated back-up staff to assist with this important task. Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: This is complete. GHA has hired and trained both new and existing staff in form 50058 submission. Form 50058's are submitted daily.

View Audit 37744

Finding 41428 (2022-002)

Material Weakness 2022

Safehouse Progressive Alliance for Nonviolence, Inc.

CO

Material Weakness Reporting Matching / Level of Effort / Earmarking

Finding 2022-002: U.S. Department of Justice ? Crime Victim Assistance - Assistance Listing No. 16.575. Reporting, Material Weakness Auditor Recommendation: During the December 31, 2022 Financial and Federal Single Audit procedures, it was noted that the Organization?s federal funding expenditure...

Finding 2022-002: U.S. Department of Justice ? Crime Victim Assistance - Assistance Listing No. 16.575. Reporting, Material Weakness Auditor Recommendation: During the December 31, 2022 Financial and Federal Single Audit procedures, it was noted that the Organization?s federal funding expenditures in prior years exceeded the threshold requiring a single audit and none were performed. Corrective Action: The Organization is currently reviewing the revenue recognition in prior years to attempt to identify which fiscal years met the threshold requiring a single audit. When the scope of the issue is fully identified, the Organization will reach out to the impacted funding agencies. The cost of performing those audits will be material to the Organization?s annual budget, but we will take any steps recommended by the funding agencies. Responsible Contact: Lisa Van der Veer (303) 449-8623 ext 124 lisav@safehousealliance.org Responsible Party: CEO & Finance Director Anticipated Completion Date: November 15, 2023 (all funding agencies contacted, any required prior year audits deadline tbd)

View Audit 37704

Finding 41412 (2022-014)

Significant Deficiency 2022

The Howard University

DC

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Name of Responsible Individual: Brenda Willis - Senior Director of Financial Grants and Contracts and Rawle Howard - Assistant Vice President and Chief Procurement Officer Corrective Action: The Controller?s Office and Grants and Contracts will work with Accounts Payable to ensure that payments to v...

Name of Responsible Individual: Brenda Willis - Senior Director of Financial Grants and Contracts and Rawle Howard - Assistant Vice President and Chief Procurement Officer Corrective Action: The Controller?s Office and Grants and Contracts will work with Accounts Payable to ensure that payments to vendors are applied timely in Workday. Accounts payable will be required to review all wire requests to ensure the invoices have not been previously paid by check prior to initiating wires. Anticipated Completion Date: June 30, 2023

View Audit 37632 Questioned Costs: $1

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