Corrective Action Plans

Finding 30992 (2022-007)

Material Weakness 2022

NM

Special Tests & Provisions Student Financial Aid Material Weakness § 200.303

Auditors? Recommendation - We recommend the Registrar and/or Admission?s Office strengthen controls over enrollment reporting as well as the requirements under 34 CFR 690.83(b)(2) and 685.309 to ensure accurate reporting to the US Department of Education. Views of Responsible Officials and Planned C...

Auditors? Recommendation - We recommend the Registrar and/or Admission?s Office strengthen controls over enrollment reporting as well as the requirements under 34 CFR 690.83(b)(2) and 685.309 to ensure accurate reporting to the US Department of Education. Views of Responsible Officials and Planned Corrective Action - The College agrees with the finding. The College notes that specific steps were taken during the fiscal year to correct the deficiency; however, the process developed did not work. The College will review and modify its existing procedure to remedy the reporting deficiencies. Responsible Official - Ivan Lopez, Provost, Janice Baca, Registrar, Carmella Sanchez ,Director of Institutional Research, Scott Stokes, Chief Information Officer, and Emma Hashman, Admissions Timeline and Estimated Completion Date - June 30, 2024

View Audit 30350

Finding 30973 (2022-001)

Significant Deficiency 2022

California Lutheran University

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigati...

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

View Audit 30198

Finding 30971 (2022-002)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.400 § 200.401

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 202...

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 21.023. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021 the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity has been expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30968 (2022-001)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.400 § 200.401

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years ...

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 14.231. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, MHDC undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021, reviewed applications to identify potentially fraudulent applications during fiscal year 2022 and expects to conclude its investigation of identified cases during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30881 (2022-009)

None 2022

Okaloosa Walton Homeless Continuum of Care, Opportunity, Inc.

FL

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

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the...

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the relevant audited period. The former Executive Director?s employment with HHA was terminated on October 10, 2022. The former Finance Director?s employment with HHA was terminated on October 20, 2022. The third employee?s employment with HHA was terminated on October 11, 2022. Additionally, all but two of the Board of Directors who served during the period in which the irregularities occurred have been replaced. HHA appointed the current Executive Director, Crystal Harrison (?Executive Director?), on October 10, 2022, as Interim Executive Director and promoted her to the position of Executive Director on October 26, 2022. The current Executive Director has diligently searched for all documents and records for all purchases, expenses, and cash distributions at issue during the former Executive Director?s tenure as Executive Director. However, no such documents or records were located on site at HHA?s offices or on HHA?s computers or devices. In early April 2023, HHA?s attorney served the former Executive Director, former Finance Director, and former employee with a demand to produce the missing documents and records but each responded that they had no such documents or records in their possession. Unfortunately, because of the actions of the former Executive Director, Finance Director, and employee, HHA lacks sufficient operating funds to pursue a civil suit to recover the losses caused by these former employees. Further, HHA?s errors and omissions insurance policy only covers third-party claims. As such, HHA has directed its attorney to take all appropriate action to pursue criminal charges of grand theft/embezzlement and fraud against these former employees upon completion of the audit. HHA?s attorney has already reached out to law enforcement to begin this process. Once the formal criminal complaint is filed, law enforcement will be empowered to subpoena the missing documents and records (should said documents and records still exist) from the former employees, as well as their banking and financial records (including tax returns) to track the suspicious expenses and cash distributions at issue. The current Executive Director, with the full support of HHA?s Board, is committed to taking all action necessary to ensure compliance with the rules and procedures already in place regarding expenses and cash distributions, as well as to enact new enhanced procedures for periodic reviews of these procedures to timely detect deficiencies and ensure compliance going forward. In addition, the current Executive Director will implement a process to ensure that backup records are maintained electronically as well as in a paper form.

View Audit 33406 Questioned Costs: $1

Finding 30875 (2022-004)

Material Weakness 2022

Miami County

IN

Allowable Costs / Cost Principles Material Weakness Period of Performance § 200.1 § 200.303

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mary Brown Contact Phone Number: 765-472-3901 Ext. 1240 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the 2022, we were notified the reporting of the cumulative expenditures ...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mary Brown Contact Phone Number: 765-472-3901 Ext. 1240 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the 2022, we were notified the reporting of the cumulative expenditures for ARPA Funding was inaccurately reported. We have already contacted US Department of Treasury to correct the prior and current year reporting and awaiting a response. We will change the process for reporting to attempt to correct the prior years reporting to ensure we are providing complete transparency for the expenditure of funds. In addition, we will implement the internal control to require the reviewing individual sign the report. Anticipated Completion Date: January 2024

View Audit 33402

Finding 30844 (2022-001)

Material Weakness 2022

Alfond Youth & Community Center and Affiliates

ME

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

December 22, 2022 CORRECTIVE ACTION PLAN U.S. Department of Health and Human Services Alfond Youth & Community Center and Affiliate?s respectfully submits the following corrective action plan of the year ended March 31, 2022. Name and address of independent public accounting firm: One River CPA...

December 22, 2022 CORRECTIVE ACTION PLAN U.S. Department of Health and Human Services Alfond Youth & Community Center and Affiliate?s respectfully submits the following corrective action plan of the year ended March 31, 2022. Name and address of independent public accounting firm: One River CPAs 46 FirstPark Drive, Oakland, ME 04963 FINDING ? FINANCIAL STATEMENT AUDIT None FINDING ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Health and Human Services 2022-001 ? All Awards Material Weakness in Internal Control Over Major Programs: Management?s spreadsheet for tracking federal grants subject to Uniform Guidance Single Audit and related expenditures for the fiscal year did not include all grants subject to Single Audit. As a result, management initially determined that the Organization was below the threshold for Single Audit for the year ended March 31, 2022. Audit procedures found additional grants with expenditures during the fiscal year that were subject to Single Audit. These additional grants put the Organization over the Single Audit expenditure threshold of $750,000. Recommendation: As agreements are awarded, the Organization should analyze them for the presence of federal funding. In many instances there is a mix and the Organization should review the agreement for clarification of funding allocations. If unclear, the Organization should work with the grant?s administrator at the funder to determine the source of the funds. If not in the agreement, the Organization should also work with the funder to identify the federal CFDA number the federal funds fall under. The Organization should ensure all identified federal grants make it to the tracking spreadsheet. Management should strengthen its review of that tracking document to ensure it includes all federal grants with expenditures subject to Single Audit each fiscal year. Responsible Person for Corrective Action: Heather Neal, CFO Corrective Action to be Taken: AYCC has taken steps to strengthen fiscal oversight and tracking of federal grants subject to meet Uniform Guidance. These steps include hiring a new Chief Financial Officer with significant grant management and audit experience. Additionally, cross training staff to increase skills and knowledge surrounding the receipt, use, and tracking of federal grants. These steps combined with updated internal controls, improved systems and collaboration between the finance department and the grant department will remedy this finding and prevent further findings in the future. The anticipated completion date for this corrective action is March 31, 2023. If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Heather Neal, CFO at 207-873-0684 or hneal@clubaycc.org. Sincerely, Ken Walsh, Chief Executive Officer

View Audit 31201

Finding 30838 (2022-002)

Significant Deficiency 2022

McPherson College

KS

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

Finding 2022-002: National Student Loan Data System (NSLDS) Enrollment Reporting Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The student affairs department will receive training on the requi...

Finding 2022-002: National Student Loan Data System (NSLDS) Enrollment Reporting Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The student affairs department will receive training on the requirements related to status change effective dates in accordance with the Department of Education regulations. In addition, the financial aid department and the registrar?s office are working together to confirm student rosters to verify that enrollment reporting is timely and accurate. Contact Person Responsible for Corrective Action: Shana Meyer, VP for Student Affairs; Andy Olsen, Director of Financial Aid; Rhianna Reed, Assistant Registrar Anticipated Completion Date: Corrective action is in progress as of August and will be completed by December.

View Audit 35595

Finding 30836 (2022-003)

Significant Deficiency 2022

McPherson College

KS

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

Finding 2022-003: Perkin?s Loan Recordkeeping and Record Retention Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our filing processes to ensure that loan files are maintained in an organized manner so all files can be located as needed. The missing file is paid in fu...

Finding 2022-003: Perkin?s Loan Recordkeeping and Record Retention Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our filing processes to ensure that loan files are maintained in an organized manner so all files can be located as needed. The missing file is paid in full. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was completed in October.

View Audit 35595

Finding 30813 (2022-001)

None 2022

Fahrney-Keedy Memorial Home, Inc.

MD

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Action: Management agrees with the above finding and has implemented a three-phase plan to reduce overhead and managerial costs while maintaining a Skilled Nursing Census in the mid to high 80s.

View Audit 33289

Finding 30776 (2022-002)

Significant Deficiency 2022

Los Angeles Community College District

CA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

A. Incorrect Calculation of Return of Title IV Funds The student in question has an unusual circumstance because the college canceled the last enrolled class. The student was correctly identified as a withdrawal through an external student information system (SIS) query designed to identify student...

A. Incorrect Calculation of Return of Title IV Funds The student in question has an unusual circumstance because the college canceled the last enrolled class. The student was correctly identified as a withdrawal through an external student information system (SIS) query designed to identify students with unusual circumstances not currently identified by the R2T4 program. Unfortunately, the R2T4 worksheet was not manually added to the SIS due to an inadvertent oversight. We believe this is an isolated incident, but in order to automate the manual process, CFAU requested the Office of Information Technology to incorporate the external query logic into the R2T4 program. The worksheet has been manually added. Note that the internal controls have been substantially strengthened which has reduced the number of students impacted year-over-year. B. Untimely Notification of Grant Overpayment to Students and Secretary The college inadvertently failed to report the student overpayment to NSDLS timely. Due to SIS communication limitations with this last batch for the summer 2022 term, the District was unable to send the notification through SIS and had to send the R2T4 OP notification outside of SIS manually resulting in the late notification. C. Distance Education Courses ? Lack of Formal Process to Determine Accuracy of Student Withdrawal Date With regards to student withdrawal dates as it relates to DE courses, the District will provide communications to all faculty throughout the semester instructing them to assess individual student participation in the class and to exclude students from the class if prior to exclusion deadlines, or drop students if exclusion deadlines have passed. The communications will refer to the Academic Senate guidelines on regular and substantive interaction and use of authentic assessments to ensure that active participation is being effectively evaluated. Communications will be times around core deadlines for enrollment and financial aid processes. The DE Coordinators will be informed of the new standard to supplement the existing required and optional trainings currently provided to teaching faculty. This process will be implemented in Fall 2022. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected Date of Implementation: Fall 2022

View Audit 27427 Questioned Costs: $1

Finding 30775 (2022-001)

Significant Deficiency 2022

Los Angeles Community College District

CA

Questioned Costs Student Financial Aid Eligibility § 200.303

The District has already developed an automated summer Pell solution. The solution has been tested by the field and Central Financial Aid Unit (CFAU) and will be implemented Summer 2023. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Ma...

The District has already developed an automated summer Pell solution. The solution has been tested by the field and Central Financial Aid Unit (CFAU) and will be implemented Summer 2023. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected date of Implementation: Summer 2023

View Audit 27427 Questioned Costs: $1

Finding 30728 (2022-005)

None 2022

Clinton Prairie School Corporation

IN

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

Finding 2022-005 ?Medicaid ? Eligibility Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corp switched Medicaid provi...

Finding 2022-005 ?Medicaid ? Eligibility Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corp switched Medicaid providers in FY23, and will monitor the new provide to ensure compliance with the federal requirements. Anticipated Completion Date: June 30, 2023

View Audit 26817 Questioned Costs: $1

Finding 30725 (2022-004)

Material Weakness 2022

Clinton Prairie School Corporation

IN

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

Finding 2022-004 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-004 ESSER...

Finding 2022-004 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-004 ESSER - we do not have GEER grants - We have reviewed all files of previous Treasurer and Superintendent and did not find documentation. We will make sure going forward that documentation stays with the Grant file at all times in case of staffing changes. Anticipated Completion Date: June 30, 2023

View Audit 26817

Finding 30687 (2022-003)

None 2022

Dallas Christian College

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding Number: 2022-003 Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: date FA office will verify that disbursement date in COD matches the disbursement date on the student account. Person Responsible for Corrective Action Pla...

Finding Number: 2022-003 Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: date FA office will verify that disbursement date in COD matches the disbursement date on the student account. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

View Audit 25908

Finding 30686 (2022-002)

None 2022

Dallas Christian College

TX

Reporting Student Financial Aid Eligibility

Finding Number: 2022-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Change the academic software set up to more accurately reflect the last date of attendance for DCC Online classes by adding the last date possible for the student to att...

Finding Number: 2022-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Change the academic software set up to more accurately reflect the last date of attendance for DCC Online classes by adding the last date possible for the student to attend at the end of the last week (rather than the beginning of the week only). And, once the term has ended, exit anyone who has not registered (or pre-registered) for the next semester within two weeks of the end of the term. Person Responsible for Corrective Action Plan: Crystal Laidacker, Registrar Anticipated Date of Completion: Immediate

View Audit 25908

Finding 30685 (2022-001)

None 2022

Dallas Christian College

TX

Student Financial Aid Matching / Level of Effort / Earmarking

Finding Number: 2022-001 Return of Title IV (R2T4) Calculations Planned Corrective Action: FA Office will review the timing of the withdrawal to verify if the student earned 100% of the disbursed aid. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administra...

Finding Number: 2022-001 Return of Title IV (R2T4) Calculations Planned Corrective Action: FA Office will review the timing of the withdrawal to verify if the student earned 100% of the disbursed aid. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

View Audit 25908

Finding 30660 (2022-004)

Material Weakness 2022

Umpqua Public Transportation District

OR

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.302

Finding 2022-04 ? Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following. Identification, in its accounts, of all Federal awards received and ...

Finding 2022-04 ? Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following. Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: During the audit of Umpqua Public Transportation District for Fiscal Year 2021-2022, the district provided auditor with Separate and Identifiable General Ledger reports that showed a clear division between Federal, State and Local expenditures and revenues. However, the separation was done retroactivity and was not been completed for the entire fiscal year or life of grants. This deficiency was instrumental in causing the general ledger to be inadequate for financial and Federal Award Reporting. Cause: The District had originally relied on unskilled individuals for structuring and recording activities in their general ledger. District management did not have sufficient staff or monitoring policies to recognize and correct the deficiency. While trained staff have been hired at Umpqua Public Transportation District, and improvements made to the general ledger and recording of Federal grants, improvements are still necessary to meet the full requirements of CFR Part 200.302.b Auditee Responsibilities. Effect or Potential Effect: Potential for incorrect financial reporting, and untimely results, with the inability to rely on the general ledger for correct and timely information. Questioned Cost: No Context: While federal grant revenues and expenditures are now tracked using the general ledger ?jobs? indicators, additional recording is needed to track the matching portions of the costs and revenues of those federal grants. The lack of completed effort at separating revenues or expenditures by grant may lead to errors in reporting expenditures for Federal Awards. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2021-11 Recommendation: We recommend that Umpqua Public Transportation District improve their general ledger structure to meet the requirement for separate accounts for Federal awards for program revenues and program expenditures. We also recommend that the district establish policies and procedures to ensure that all program revenues and expenditures are reported in the correct fiscal year. In addition, we recommend that the district establish a training program and policies and procedures for staff and management to receive appropriate training for administering and recording Federal Grant revenues and expenditures. District's Response: The District concurs with the recommendation. General ledger accounts separating Federal, State, and Local revenues and related expenditures will be designed and implemented. Corrective Action Plan: The District has hired a Finance Manager to oversee the day-to-day financial operations of the district. The Finance Manager has developed an accounting system for separating Federal, State, and Local revenues and related expenditures. This will allow the activities of the district to be recorded in a manner that allows for reporting in compliance with federal requirements. Planned Implementation Date: July 1, 2022 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 35618

Finding 30658 (2022-002)

Material Weakness 2022

Umpqua Public Transportation District

OR

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302

Finding 2022-02 ? Fiscal Management System, Ensure Compliance with Federal Regulations Over Accounting Systems (Material Weakness) Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting. Internal controls should allow management or...

Finding 2022-02 ? Fiscal Management System, Ensure Compliance with Federal Regulations Over Accounting Systems (Material Weakness) Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting. Internal controls should allow management or employees in the normal course of performing their assigned functions to prevent or detect material misstatements in the financial reporting of all district funds. The Internal Control ? Integrated Framework, published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and the U.S. Government Accountability Office Standards for Internal Control in the Federal Government specify that a satisfactory control environment is only effective when there are adequate control activities in place. Effective control activities dictate that a review is performed to verify the accuracy and completeness of financial information reported. The Federal Grant Activity Schedule captures amounts that must be accurate and complete in order to ensure the accuracy of the financial and federal information reported on such schedule to verify the accuracy and completeness of financial information reported. CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following. Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: During the audit of Umpqua Public Transportation District for Fiscal Year 2021-2022, the district provided auditor with Separate and Identifiable General Ledger reports using QuickBooks Jobs feature, that showed identification between individual grant expenditures and revenues. Entries were prepared or recorded using the jobs feature, but not on a timely basis throughout the year, as portions were completed retroactively, and general ledger restated for the entire fiscal year. This deficiency was instrumental in causing the general ledger to be inadequate for financial and Federal Award Reporting for a large portion of the year. Cause: The District had relied on inadequately trained individuals to record activities and setup of their general ledger. The accounting records were retroactively constructed to meet Federal award reporting purposes, but late in the fiscal year. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Failure to record transactions timely into the general ledger for Umpqua Public Transportation District, and lack of proper accounting structure separating revenues and expenditures into each Federal and State or Local grant may result in transactions not being properly included in the district?s financial statements. The potential for incorrect financial reporting, and untimely results, with the inability to rely on the general ledger for correct and timely information, may also cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Restatement of the general ledger was necessary for proper reporting of grants for the Schedule of Federal Awards. Tracking of matching local and state grants remains ineffective. Repeat of a Prior-Year Finding: Yes, Financial Statement Findings 2021-4 Recommendation: We recommend that Umpqua Public Transportation District improve their general ledger structure to meet the requirement for separate accounts for Federal awards for program revenues and program expenditures. In addition, we recommend that the district establish policies and procedures to ensure that all required matching of grant expenditures be recorded in sufficient detail tracking to ensure that all matching program revenues and expenditures are reported correctly in the fiscal year. We also recommend that the district continue training program, policies and procedures for staff and management for administering and recording Federal Grant revenues and expenditures. District's Response: The District concurs with the recommendation. General ledger accounts separating Federal, State, and Local revenues and related expenditures will be adhered to and further training implemented. Corrective Action Plan: The District hired a Finance Manager to oversee the day-to-day financial operations of the district. The Finance Manager retroactively created accounting records to separate grant revenues and related expenditures, for both Federal grant records as well as State grant records. The Finance Manager will improve the general ledger to allow the recording of the matching identification for each federal grant. This will allow the activities of the district to be recorded in a manner that allows for reporting in compliance with federal requirements. Planned Implementation Date: July 1, 2022 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 35618

Finding 30628 (2022-013)

Material Weakness 2022

Charter County of Wayne, Michigan

MI

Questioned Costs Material Weakness Matching / Level of Effort / Earmarking § 200.303

Federal Program: ALN 21.023, Department of the Treasury, COVID-19 Emergency Rental Assistance Program Condition per Auditor: The County did not have adequate controls in place to ensure that payments to beneficiaries were calculated correctly. Planned Corrective Action: Management will implement a...

Federal Program: ALN 21.023, Department of the Treasury, COVID-19 Emergency Rental Assistance Program Condition per Auditor: The County did not have adequate controls in place to ensure that payments to beneficiaries were calculated correctly. Planned Corrective Action: Management will implement and follow a process of reviewing of consultant administered activity for accuracy by internal County representative. Anticipated Completion Date: 9/30/2024 Responsible Contact Person: Hassan Sheikh

View Audit 26048 Questioned Costs: $1

Finding 30615 (2022-004)

None 2022

University of California

CA

Student Financial Aid Eligibility Reporting

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Lo...

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 The mismatch between the enrollment effective dates on the campus-level and program-level reports identified by PwC auditors occurred due to a bug in the Campus Solutions system during the calculation of enrollment status change dates. The campus-level status date was sometimes incorrectly set as blank, which was then set to the term start date by NSLDS import process. As of September 14, 2022, the Office of the Registrar has modified the program that creates the NSLDS data file to correct the blank status dates, removing the mismatches that were found by PwC auditors. This ensures that the campus-level and program-level effective dates match. Campus 2 Historically, reporting to the National Student Clearinghouse (the ?Clearinghouse?) of students? enrollment status, e.g., full-time status, has been accomplished via enrollment files. These files are submitted at least every 30 days to ensure changes in enrollment status, especially withdrawals, are captured in a timely manner. To update enrollment status to graduated, two other processes have been relied upon: ? The first process uses Graduates Only files. Relying on the Clearinghouse?s advice, Graduates Only files are submitted for spring quarter only. ? The second process is the degree file submissions to support third-party verification of students? degrees through the Clearinghouse. When a degree file is submitted, the enrollment status should be updated to graduated. The issue exists with the second process where, for a variety of reasons, the Clearinghouse process does not successfully update every enrollment record with a graduated status when the degree file is submitted. These problems typically occur when students have been in more than one Clearinghouse branch, such as medical students in more than one degree program, students receiving their degree in a quarter in which they were not registered, and students who do not have a SSN. The campus began to recognize these problems in the summer of 2022 and had already decided to utilize a feature available in the quarterly Clearinghouse enrollment reporting to send a graduated status, rather than full-time status, whenever a student has graduated. This change, which is scheduled to be implemented in March 2023, will resolve most of the issues in which students may not have been reported to NSLDS as graduated. Effective immediately, error reports will be methodically checked and resolved after degree files are submitted to the Clearinghouse to ensure that enrollment records are updated for every student. By adjusting and coordinating the timing and sequencing of file submissions, the number of ?false? errors will be greatly reduced, and the error resolution process will be manageable. The resequencing of files submission will begin with the Spring 2023 semester. These two steps, in addition to the continuation of enrollment and degree reporting, should eliminate cases of students not being reported to NSLDS as graduated. For inquiries regarding this finding, please contact Cruz Grimaldo (510) 316-2932 and Jerry Lopez at (415) 476-4181 who are responsible for the corrective action.

View Audit 24869

Finding 30613 (2022-002)

None 2022

University of California

CA

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

2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal P...

2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Management provides robust, on-going training related to disbursement and federal reporting timeframes. Most recently, the COD reporting requirements were reviewed in the monthly Office of Financial Aid and Scholarships management meeting, inclusive of managers within each unit of the office and IT. The student records outside of the normal parameters identified challenges within our current SIS system and staffing limitations. The student information system in place is aging and lacks flexible controls. The Office of Financial Aid and Scholarships is migrating to a new student information system (Oracle SFP) for the 2024-25 academic year. We are reengineering our disbursement process to maximize the enhanced controls and automation within Oracle SFP to ensure compliance with disbursement and federal reporting timeframes. Until a more robust system is in place, management will develop exception reports to identify discrepancies in FAME versus COD disbursement dates beginning with the 2023 summer term. Exception reports will be reviewed bi-weekly to ensure compliance with the required reporting timeline. Additionally, management continues to request additional full-time professional staff to support the administration of federal student aid and ensure regulatory compliance in all areas as federal, state and institutional aid programs continue to expand and evolve. For inquiries regarding this finding, please contact Rebecca Sanchez at (949) 824-8262 who is responsible for the corrective action.

View Audit 24869

Finding 30612 (2022-003)

None 2022

University of California

CA

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

2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing...

2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 Management provides robust, on-going training related to the Return of Title IV Funds. The Office of Financial Aid and Scholarships staffing levels have not sufficiently adjusted as student aid programs grow in size and complexity. Management is in the process of hiring additional staff and will continue to request additional full-time staff in our annual budget proposals. As additional federal and state financial aid programs are developed, there are simply not enough staff to complete all work required each week. Beginning fiscal year 2024, R2T4 reports will be reviewed in weekly team meetings and prioritized for processing to ensure compliance with regulatory timeframes. Long-term, the Office of Financial Aid and Scholarships is migrating to a new student information system (Oracle SFP) for the 2024-25 academic year. Enhanced controls and automation within Oracle SFP will ensure compliance with Return of Title IV Funds regulatory timeframes. The new student information system will increase efficiency and effectiveness by eliminating previous manual processes. Campus 2 As of October 2022, all disbursements are reported immediately, rather than the previous weekly cadence. Weekly review procedures are, and will be, a continued process to identify discrepancies and reconcile within 30 days. As an effort to address staff changes and the change in disbursement reporting, additional training was provided to staff in October of 2022. For inquiries regarding this finding, please contact Rebecca Sanchez at (949) 824-8262 and Trina Wilson at (530) 752-9278 who are responsible for the corrective action.

View Audit 24869

Finding 30590 (2022-002)

Significant Deficiency 2022

The Oaks School

CA

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

2022-002 Economic Injury Disaster Loan ? Assistance Listing No. 59.008 Recommendation: The School should implement procedures to ensure that information in the loan application is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action take...

2022-002 Economic Injury Disaster Loan ? Assistance Listing No. 59.008 Recommendation: The School should implement procedures to ensure that information in the loan application is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Operations Manager, Outside Accounting Firm, Head of School, and Board Chair will review loan applications to ensure accuracy prior to submission. Name(s) of the contact person(s) responsible for corrective action: Aaron Fielding (323) 850-3755 Planned completion date for corrective action plan: Completed as of April 4, 2023.

View Audit 32019

Finding 30589 (2022-001)

Significant Deficiency 2022

The Oaks School

CA

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

2022-001 Economic Injury Disaster Loan ? Assistance Listing No. 59.008 Recommendation: The School should implement procedures to ensure that the records are maintained for sufficient audit trail that the School is in compliance with the terms of the loan agreements. Explanation of disagreement with...

2022-001 Economic Injury Disaster Loan ? Assistance Listing No. 59.008 Recommendation: The School should implement procedures to ensure that the records are maintained for sufficient audit trail that the School is in compliance with the terms of the loan agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Obtained proper proof of Board approval of the receipt of loan. Though not formally documented previously, the Board of Trustees was fully aware and in agreement with obtaining the SBA loan for emergency relief for the school's operations at the time the loan agreement was signed. The School sent to the SBA proof of hazard insurance in March 2023. Though no proof was provided to the SBA previously and within the required timeline, the proper insurance was maintained and remained active during the required period per the agreement. Updates to obtaining loan contracts process includes a review of the agreement by Operations Manager, Outside Accounting Firm, Head of School, and Board Chair prior to signing. The School sent to the SBA financial reports in March 2023. Upon review, an action plan will be put in place to ensure that all requirements of the agreement are met timely. Name(s) of the contact person(s) responsible for corrective action: Aaron Fielding (323) 850-3755 Planned completion date for corrective action plan: Completed as of April 4, 2023.

View Audit 32019

Corrective Action Plans

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