Corrective Action Plans

Finding 13045 (2022-006)

Material Weakness 2022

CO

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

2022-006 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Correcti...

2022-006 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need to update the City financial system Workday, for budget modifications or the like that could result in a delay of payment. In an effort to determine these items ahead of time we?ve updated our internal policies to require finance budget review prior to contract execution. Likewise, HOST is engaged in an application upgrade with Salesforce which is in the final User Acceptance Testing (UAT) phase to incorporate changes that now include status tracking for vendor invoice submissions and reimbursement payments. This will support a more comprehensive and accurate accounting of any legitimate postponed payments due to waiting on more required information from vendors, budget modifications, contract amendments, etc. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: Q1-2024

View Audit 17407

Finding 13044 (2022-005)

Material Weakness 2022

City and County of Denver

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

2022-005 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005 / Award Year: 2021 Status: Corrective action in progress Corrective Action:...

2022-005 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005 / Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2022. To remediate prior finding 2021-010, HOST updated the agency?s Grant Administrator Policies & Procedures, and our Contract & Performance Management Policies that now include language to ensure obligation of funding within the required deadlines. These policies were modified complete in June 2022 and July 2023. HOST?s current Notice of Funding Availability (NOFA) cycle for ESG funding will apply to subrecipient programs awarded beginning 01/01/2024, with anticipated contract executions in Q4 2023. Copies of both policies were provided to BDO on August 16, 2023, in response to the finding. This matter has been remediated, however, per the assessment this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: July 2023

View Audit 17407

Finding 13028 (2022-001)

Significant Deficiency 2022

City of St. Louis Municipal Library District

MO

Equipment & Real Property Management Special Tests & Provisions Subrecipient Monitoring

Finding No. 2022-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipm...

Finding No. 2022-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions.

View Audit 17433

Finding 13021 (2022-001)

Material Weakness 2022

Ripley County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.214 § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditor...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023

View Audit 17665

Finding 13002 (2022-007)

Material Weakness 2022

County of Allegheny, Pennsylvania

PA

HUD Housing Programs Equipment & Real Property Management Matching / Level of Effort / Earmarking

C. Corrective Action Plan: We review each invoice monthly as they are submitted. Most of the review is insuring the items being invoiced are eligible under HUD and making sure the amounts are added correctly. We will review more closely the match submitted. Match for HUD is now reported based on the...

C. Corrective Action Plan: We review each invoice monthly as they are submitted. Most of the review is insuring the items being invoiced are eligible under HUD and making sure the amounts are added correctly. We will review more closely the match submitted. Match for HUD is now reported based on the entire funding and not by individual grants. All match from all HUD programs is added together and submitted on one ?nal report at the end of each funding year. The requirement is 25% on all budget lines except for Leasing. However, if one program?s match is short of the 25% requirement, the overall CoC is responsible for the full match so additional DHS Admin costs are used to represent the additional match needed.

View Audit 17689

Finding 12997 (2022-002)

Material Weakness 2022

County of Allegheny, Pennsylvania

PA

Matching / Level of Effort / Earmarking Program Income Special Tests & Provisions

B. Corrective Action Plan: Any corrections that have not already been made will be made in a timely manner. ACED typically waits to receipt certain Program Income in order to be in compliance with CDBG program regulations. ACED will develop a schedule for receipting Program Income that will result i...

B. Corrective Action Plan: Any corrections that have not already been made will be made in a timely manner. ACED typically waits to receipt certain Program Income in order to be in compliance with CDBG program regulations. ACED will develop a schedule for receipting Program Income that will result in all Program Income being receipted in a timely manner.

View Audit 17689

Finding 12938 (2022-002)

Significant Deficiency 2022

Irvington Community Schools, Inc.

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.334

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of thre...

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Management Corrective Action: While the school?s annual total meals served for the 2021-22 audit year were more than the meals claimed for reimbursement, the school was unable to reconcile all of the individual months. The school has since implemented and automated system to record lunches served. This point-of-sale system will eliminate the ongoing monthly accounting required to support monthly claims assuring the numbers served reconciles with the numbers claimed. Chris Ashmore has already implemented this system and tested the subsequent year-to-date audit period to assure this corrective action has, in fact, eliminated the problem.

View Audit 18123

Finding 12895 (2022-002)

Material Weakness 2022

City of East Chicago

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Additional Internal controls to address Finding 2022-002: A.- 1....

FINDING 2022-002 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Additional Internal controls to address Finding 2022-002: A.- 1. East Chicago SLFRF reporting personnel, will be expanded to include a review of Quarterly Project and Expenditure Reports by a city senior accountant. 2. All personnel will jointly review Quarterly Project & Expenditure Report when completed, before proceeding to submission in portal. 3. Review by city personnel of previous Quarterly Reports to include the initial Interim Report (SLT-4798, 8-31-21) to address issues. 4. To address possible error in reporting tier will e-mail Treasury (SLFRF@treasury.qov.) for guidance and direction. Per Project and Expenditure Report User Guide April 1, 2023. B.- 2. East Chicago SLFRF reporting personnel will include the project ledger to future SLFRF Compliance Quarter Reports to ensure accurate reporting within the proper timeline / period. Note: In addition, with further discussion, we will continue to work on finding other proposals to improve internal controls issues related to Finding 2022-002. Anticipated Completion Date: Corrective actions should be in place for next SLFRF Quarterly Report (2nd Qtr. 2023).

View Audit 17648

Finding 12889 (2022-003)

Significant Deficiency 2022

Cambridge Community Unit School District No. 227

IL

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Significant Deficiency § 200.501 § 200.516

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regard...

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regarding this discrepancy. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: The District agrees that the expenditures claimed on the June 30, 2021 expenditure report was overstated by $10,678 and in the future will review and reconcile the expenditure reports to the accounting records before submitting to ISBE.

View Audit 17428

Finding 12879 (2022-005)

Material Weakness 2022

Brown County

IN

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

FINDING 2022-005 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditors office will have a member of the subrecipient review and sign off and date that the...

FINDING 2022-005 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditors office will have a member of the subrecipient review and sign off and date that the invoice was approved with allowable service, prior to coming to the auditor?s office for payment. Anticipated Completion Date: December 31, 2023

View Audit 17582

Finding 12878 (2022-004)

Material Weakness 2022

Brown County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-004 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: Auditor?s office will Generate a report with a date range and keep the report on file for verifi...

FINDING 2022-004 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: Auditor?s office will Generate a report with a date range and keep the report on file for verification to confirm report. The Auditor?s office will verify report before submission. Anticipated Completion Date: December 31, 2023

View Audit 17582

Finding 12867 (2022-004)

Material Weakness 2022

Wagner Community Memorial Hospital

SD

Special Tests & Provisions Subrecipient Monitoring Cash Management § 200.303

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of t...

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of the United States Finding Summary: Management maintained a reserve account in a pooled investment fund which includes marketable securities backed by the full faith and credit of the United States, but based on the portfolio mix of the investment pool, was not adequate to cover the entire reserve requirement. In addition, we had not established a separate bookkeeping account and/or a separate bank account. Responsible Individuals: Bryan Slaba, Chief Executive Officer Corrective Action Plan: A separate savings account backed by the full faith and credit of the United States and bookkeeping account will be established. Anticipated Completion Date: 12/31/2022

View Audit 17145

Finding 12866 (2022-003)

Material Weakness 2022

Wagner Community Memorial Hospital

SD

Reporting Material Weakness Matching / Level of Effort / Earmarking

Finding 2022-003 Federal Agency Name: Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Preparation of the Schedule of Expenditures of Federal Awards Finding Summary: Eide Bailly LLP prep...

Finding 2022-003 Federal Agency Name: Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Preparation of the Schedule of Expenditures of Federal Awards Finding Summary: Eide Bailly LLP prepared our draft Schedule of Expenditures of Federal Awards and accompanying notes to the schedule. Responsible Individuals: Lisa Weisser, Director of Finance Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the Schedule of Expenditures of Federal Awards. We requested that our auditors, Eide Bailly LLP, prepare the Schedule of Expenditures as part of their Single Audit. We have designated members of management to review the drafted Schedule and accompanying notes. Anticipated Completion Date: Ongoing

View Audit 17145

Finding 12858 (2022-005)

Material Weakness 2022

Veterans Northeast Outreach Center, Inc.

MA

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

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resour...

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

View Audit 17771

Finding 12832 (2022-002)

Material Weakness 2022

National Council of Urban Indian Health

DC

Cash Management Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.305

Views of Responsible Officials and Planned Corrective Actions: During this fiscal year, management experienced a turnover in the financial functions as well as new staffing and a new Director of Finance. In addition, the organization changed drastically in size and scope, thereby going through a sub...

Views of Responsible Officials and Planned Corrective Actions: During this fiscal year, management experienced a turnover in the financial functions as well as new staffing and a new Director of Finance. In addition, the organization changed drastically in size and scope, thereby going through a substantial adjustment period. Corrective actions: 1. Management hired an Assistant Director of Finance in order to share the workload, add an extra layer of review for all documentation, account reconciliations, finance staff oversight, and banking functions. 2. Management hired an Associate VP of the Programs and Operations Division which has oversight over the Finance Department. 3. Monthly reconciliations and reviews and approval processes have been put in place to ensure proper recording of all expenses, revenues, and accompanying Federal Fund drawdowns and AP payments. 4. The federal department this occurred within was notified and the funds were spent on costs incurred in the next fiscal year.

View Audit 17751

Finding 12809 (2022-003)

Significant Deficiency 2022

Milwaukee Area Technical College

WI

Questioned Costs Student Financial Aid Period of Performance

Finding No. 2022-003 ? R2T4 Return Calculation Errors Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: For returns of Title IV Funding when a stud...

Finding No. 2022-003 ? R2T4 Return Calculation Errors Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: For returns of Title IV Funding when a student does not complete the enrollment period for which funds were disbursed, the amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student's withdrawal date. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew (34 CFR 668.22(e)). Condition / Context: The auditor selected 21 unenrolled students who had Title IV returns for testing. For each student selected, the return amount was incorrectly calculated because the payment period was not used as the basis for the determination. Our sample was statistically valid. Cause: Unauthorized break periods and start dates were used to determine the base period for calculation. MATC's review process was not effective to detect and correct this error. Staff responsible for calculating R2T4 returns were not properly trained in the requirements. Questioned Costs: $5,097 Effect: MATC has determined that a total of 425 returns were incorrectly calculated, with an estimated net error of $5,097. Recommendation: We recommend MATC re-evaluate its review process for Title IV returns, and provide additional training for management and staff to ensure the calculations and compliance requirements are understood and that control processes are operating effectively to ensure proper returns. District Response: MATC agrees with the finding and has developed, documented and implemented a process and correct the student record errors, provide updated training and update R2T4 procedures to ensure proper calculation going forward. Al Pinckney, Executive Director of Financial Aid 12/6/2022

View Audit 17732 Questioned Costs: $1

Finding 12808 (2022-004)

Significant Deficiency 2022

Milwaukee Area Technical College

WI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No. 2022-004 ? Reporting Discrepancies - Enrollment Repeat Finding: 2021-001 ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: Institutions are required to re...

Finding No. 2022-004 ? Reporting Discrepancies - Enrollment Repeat Finding: 2021-001 ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP). Condition / Context: We selected a sample of 25 Pell and Direct Loan students from the institution's records that had a reduction or increase in attendance levels, graduated, withdrew, dropped out or enrolled but never attended during the audit period. We compared the data in the students' NSLDS Enrollment Detail to the students' academic files and other institutional records and verified that the institution is accurately reporting the significant Campus-Level and Program-Level enrollment data elements that ED considers high risk. Of the 25 sampled, 10 had discrepancies between the status documented in MATC's institutional records and the status reported on the NSLDS. Our sample was not statistically valid. Cause: In April 2021, the National Student Clearinghouse made a change to its reporting process, which resulted in errors in MATC's data uploads. MATC has begun the process of testing and correcting its process, but this was not completed as of June 30, 2022. MATC believes this update error has caused the continued discrepancies between MATC and the NSLDS. Questioned Costs: Unknown Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Incorrect reporting of enrollment status could result in incorrect distribution of Title IV funds to institutions or individuals. Recommendation: We recommend MATC continues its review process for enrollment statuses, and provide additional training for management and staff to ensure the correct statuses are reported and that control processes are operating effectively to ensure proper returns. District Response: The Office of the Registrar has developed and is implementing an action plan to ensure correct reporting through the National Clearinghouse and NSLDS. The process includes additional staff training, review and update of the submissions process and schedule and enlisting support from specific contacts at the Clearinghouse. These steps were completed by September 2022. Additional steps, including review of the reporting setup the SIS system with the IT department, discussing and resolving existing issues with the Clearinghouse, performing checks of individual current and prior year students to identify and correct additional gaps, incorporating a regular review of a sample of students for proper reporting and hiring additional staff for reporting enrollment ? all to be completed by December 2022. Beginning in 2023, staff will also create and submit an additional report to the Clearinghouse for each submission of graduates and creating a position to lead enrollment reporting. Dr. Sarah Adams, Dean of Enrollment Services 12/6/2022

View Audit 17732

Finding 12771 (2022-004)

Significant Deficiency 2022

Charles County Public Schools

MD

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period o...

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Fiscal Services will improve internal controls over the procedures that ensure expenditures to a program are incurred within an award?s allowable period of performance. During the year-end close out process, the Lead Restricted Funds Accountant will review the close out of all restricted funds against the grant periods. If expenditures are inadvertently incurred outside of the grant period, the expenditures will be reclassified to an existing like grant if allowable or to the operating budget. If the Lead Restricted Funds Accountant is unavailable or has closed out grants themselves, this review will be done by the Budget Manager. The school district will implement a new financial system in July 2023. The implementation of this new system will allow for more automated internal controls. Name(s) of the contact person(s) responsible for corrective action: Rosa Aquino and/or Sherri Fisher-Davis Planned completion date for corrective action plan: December 31, 2022

View Audit 17731

Finding 12728 (2022-002)

Significant Deficiency 2022

Hot Springs County

WY

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding...

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding, the County is in the process of developing written policies and procedures relative to internal controls over federal awards, to help achieve: - County wide consistency over compliance regulations and standards - Decrease the risk of grant agreement noncompliance - Reduce the risk of undetected errors in processing of financial transactions relative to federal awards. Steps taken include: - Familiarization of requirements in 2 CFR 200.303 - Obtain draft examples of policies and procedures adopted by other Counties - Discussion with governance and county attorney regarding development and adoption of policies and procedures In addition, the County is continuing to suggest departments implement effective internal control structures to - Protect assets against theft and waste - Ensure accurate and reliable operating and accounting data The conditions noted in this finding were previously reported in finding 2021-002 Completion Date Estimated June 2023 - policy written, approved by Commissioners, and disseminated ot departments Training - ongoing County Contact Becky Kersten, County Clerk

View Audit 17708

Finding 12722 (2022-001)

Material Weakness 2022

Legacy Health

OR

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

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund porta...

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund portal. Additionally, Legacy claimed expenses that were duplicated within the reporting portal. The general distribution report for Legacy Health for Period 1 shows $35,760,843 in expenses applied against the PRF funds in the PRF portal report for Legacy as a consolidated entity. Separately, the stand-alone reports for targeted funds received by Emanuel Hospital & Health Center for Period 1, Legacy Silverton Medical Center for Period 1, Legacy Clinics, LLC for Period 1, and Legacy Meridian Park Hospital for Period 2 also include expenses totaling $12,291,293 that are included in the $35,760,843 listed in the consolidated report above. This results in duplicate reporting of the same expenditures. During testing over reporting and allowability it was observed that the lost revenues attributable to Coronavirus were reported in both the parent entity?s PRF reports on the general distribution payments and the subsidiary entities? PRF reports on the targeted distribution payments (i.e., lost revenues were duplicated). Lost revenues shown on the subsidiary reports as available to be applied against PRF that related to lost revenues also reported in the parent entity?s report were related to Emanuel Hospital & Health Center for Period 1 in the amount of $27,106,110 and Legacy Silverton Medical Center for Period 1 in the amount of $10,269,349. Actions Taken and Status As noted within the portal filing summary, for reporting period 1, Legacy consolidated COVID-19 expenses ($35,760,843) plus lost revenue ($150,037,450) totaled $185,798,293. Payments from the PRF totaled $89,818,954. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF funds received, regardless of the questioned costs above. Therefore, management believes no repayment of PRF funds received would be required. Further, management considered the finding. Reporting for the Legacy parent reporting entity was based on the ?Post-Payment Notice of Reporting Requirements (6/11/21)?, which includes the following requirement: ?Reporting entities will submit consolidated reports.? Neither the methodology utilized by Legacy or application of the methodology advocated by KPMG result in repayment of any of the funds received from the PRF. Management is implementing a process to identify and resolve situations in which reporting requirements are inconclusive, in conflict, or ambiguous. Outside subject matter expertise will be accessed as needed. Person responsible for the implementation of the corrective action plan: Tom Haywood Legacy Health 1919 NW Lovejoy St Portland OR 97219 503-415-5793 thaywood@lhs.org

View Audit 17558 Questioned Costs: $1

Finding 12700 (2022-004)

Significant Deficiency 2022

Oklahoma State University

OK

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.305

Research and Development Assistance Listing No Various Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

Research and Development Assistance Listing No Various Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs. Departments are entrusted with considerable latitude in determining needs and purchasing products, services, and technical support required to perform educational and outreach duties as well as research with sponsored projects. Because of this, it is reasonable for departments to verify the delivery of these purchases, establish the quality and quantity of the items, and begin the process of paying the corresponding invoices. Delays in the workflow sometimes occur due to valid reasons, and other times are due to a breakdown in the administrative process. Information will be shared with departments regarding delays in invoice processing. This will include sharing the information with academic and research heads in the colleges that processing of invoices must occur quickly, discrepancies affecting the expedient payments will be noted on invoices, and explanations will be recorded. Name(s) of the contact person(s) responsible for corrective action: Robert Dixon, Director of Grants and Contracts Financial Administration Planned completion date for corrective action plan: Spring 2023

View Audit 18279

Finding 12668 (2022-002)

Significant Deficiency 2022

Center City Housing Corp.

MN

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

2022-002: Lack of Documentation for Review of Tenant Files Name of contact person: Nancy Cashman, Executive Director Corrective Action: The Corporation created written policies and procedures for affordable housing program compliance and review of the applicable tenant files in fiscal year 2023 and ...

2022-002: Lack of Documentation for Review of Tenant Files Name of contact person: Nancy Cashman, Executive Director Corrective Action: The Corporation created written policies and procedures for affordable housing program compliance and review of the applicable tenant files in fiscal year 2023 and is in the process of adopting these policies and procedures. Proposed completion date: The Organization plans to complete the plan by September 30, 2023.

View Audit 18183

Finding 12634 (2022-011)

Significant Deficiency 2022

Barclay College

KS

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328

SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not ...

SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Actions Taken As of March 23, 2023, evidence of public posting dates will be saved during the publishing process. In addition, a reconciliation has been implemented in which an individual other than the preparer will review the report for accuracy prior to submission or publication.

View Audit 17529

Finding 12631 (2022-007)

Significant Deficiency 2022

Barclay College

KS

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

SIGNIFICANT DEFICIENCY 2022-007 Student Financial Assistance Program Cluster ? Title IV ? Eligibility Condition During testing, it was discovered that two students were over awarded subsidized direct loans. Recommendation We recommend that the institution implement controls to ensure that direct ...

SIGNIFICANT DEFICIENCY 2022-007 Student Financial Assistance Program Cluster ? Title IV ? Eligibility Condition During testing, it was discovered that two students were over awarded subsidized direct loans. Recommendation We recommend that the institution implement controls to ensure that direct loan award amounts are reviewed for accuracy prior to making awards to students. Actions Taken As of March 23, 2023, the College has begun to implement a review of student awards that will include reviewing all aid and credits that the student is receiving and double checking NSLDS loan amount limits.

View Audit 17529

Finding 12628 (2022-006)

Significant Deficiency 2022

Barclay College

KS

Student Financial Aid Reporting Significant Deficiency

SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Reporting Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Recommendation We recommend that the institution review its reconciliation proce...

SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Reporting Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Actions Taken As of March 23, 2023, COD records have been updated for the two students in question. In addition, communication is ongoing with the College?s software provider in order to work towards a control that will ensure that this error does not occur again. Lastly, the College has implemented a review process to ensure that applicable students have completed their verification, and the third-party vendor who completes the verification process has been contacted about setting up a notification system to alert personnel when a student completes their verification.

View Audit 17529

Corrective Action Plans

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