Corrective Action Plans

Finding 47882 (2022-001)

Material Weakness 2022

MI

Student Financial Aid Material Weakness Reporting

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attribut...

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding. 1. Of the 40 students tested, there was 15 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew/graduated whose status change were not reported to the NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: Following guidance provided via Plante Moran and the Dept, of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective Fall 2022 to address correct enrollment status change reporting by: ? Adopt the use of the published academic semester end date for enrollment reporting vs using the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that published end of an academic semester, per the Academic Calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ? Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date at which Registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated, due to having attended at least 60% of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting as last date of attendances are supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure accuracy of identifying students who are unofficial withdrawals at the end of an academic semester and adjust staffing resources as necessary to account for critical time periods such as the period between CMU?s Fall and Spring semesters when the university is closed. This will be necessary due to using the published last date of the semester instead of the end of the payment period date that was used in prior years. ?Planned timeline to complete corrective actions is February 2023 to account for end of Fall 2022 grading processes and manual updating of NSLDS as necessary for identified unofficial withdrawals. ?Contact person responsible for corrective action: Keith Malkowski, Registrar ?Anticipated Completion Date: February 2023 following end of semester grading and subsequent student record updating per our Date of Determination process.

View Audit 53360

Finding 47877 (2022-001)

Significant Deficiency 2022

Philadelphia Industrial Development Corporation

PA

Allowable Costs / Cost Principles Cash Management Questioned Costs

Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Manage...

Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Management will continue to rely on its existing controls in place; however, noting that Management will closely monitor loans and loan disbursements where the funding source has changed closely to ensure that disbursements are in accordance with funding terms and approval limits. Management will continue to rely on its existing controls that are in place, including the ongoing communication with the City for any changes in transactions that require their approval. In the circumstances where management is pending a contract amendment from the City for loans requiring additional funding, management will determine if there are unrestricted funding sources to support the change in the approved amount of the loan until the amended contract is finalized. Questioned Program: CFDA #14.218 Community Development Block Grants (CDBG)

View Audit 52296 Questioned Costs: $1

Finding 47865 (2022-001)

Significant Deficiency 2022

Mission Consolidated Independent School District

TX

Matching / Level of Effort / Earmarking Questioned Costs Subrecipient Monitoring § 200.303

The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential av...

The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential avenues of relief: 1. 5-year flexibility: If a District is non-compliant with FY 2022 ESSA LEA MOE (determinations that FFCR will issue in Spring 2023) but was compliant in FYs 2017, 2018, 2019, 2020, and 2021 then the District would not have its FY 2024 (the school year 2023?2024) ESSA allocations reduced. However, the District would still be considered non-compliant, and FY 2023 expenditures would be compared to FY 2021. 2. USDE waiver: A non-compliant District can submit a waiver request to the U.S. Department of Education (USDE), as TEA does not have the authority to waive ESSA LEA MOE. USDE considers each request on a case-by-case basis and has not shared the criteria they use to evaluate requests. If a District is non-compliant, even if they are eligible for the 5-year flexibility, FFCR staff contact the impacted Districts to advise them on the steps to submit a waiver request to USDE. The District met ESSA LEA MOE in fiscal years 2017, 2018, 2019, 2020, and 2021. Therefore, the District will utilize the allowable 5-year flexibility and submit the USDE waiver. The District will continue to run the state aid template every six weeks to monitor student enrollment and attendance to project revenue. The District will facilitate meetings with the program directors, Human Resources, and Payroll department. In addition, the District will monitor actual expenditures compared to the budget every six weeks to ensure that MOE tests are met by year-end. Contact person: Joel Garcia, Assistant Superintendent for Finance Proposed Completion Date: November 15. 2022 "See full CAP in report"

View Audit 51195

Finding 47834 (2022-002)

Significant Deficiency 2022

Morrow County

OH

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.208 § 200.305

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We ...

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We will implement procedures to ensure all quarterly reports are submitted timely under this grant. December 31, 2023 Director of Morrow County Job and Family Services and Morrow County Area Transit

View Audit 46816

Finding 47832 (2022-001)

Significant Deficiency 2022

Collaborative for Children

TX

Equipment & Real Property Management Matching / Level of Effort / Earmarking Special Tests & Provisions

Finding #2022-001 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Passed through Houston-Galveston Area Council Child Care and Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care and Developme...

Finding #2022-001 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Passed through Houston-Galveston Area Council Child Care and Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing #: 93.575/93.596 Contract Numbers: 301-22, 301-23 Contract Years: 10/01/21 ? 09/30/22, 10/01/22 ? 12/31/22 Recommendation: Re-emphasize CFC?s policies and procedures related to equipment and real property purchased under the contracts. Planned corrective action: During staff training, we have clearly stated the requirement for a physical inventory to be performed annually. To ensure that a physical inventory is performed in accordance with written policies and procedures, we have taken the following measures: ? Designated a responsible person to oversee the physical inventory process. ? Created a checklist of steps to be followed during the physical inventory process. ? Trained staff on how to perform the physical inventory process. Responsible officer: Chief Financial Officer, Alisa Ealy Estimated completion date: September 30, 2023

View Audit 45789

Finding 47825 (2022-001)

Material Weakness 2022

Lancaster City School District

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions

CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with fed...

CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with federal ESSER funds. School Districts are usually not required to pay prevailing wages (state/local funds). The District had not used federal funds for construction in the past and was unaware of the requirement. Due to using an architect firm for the HVAC and window projects that were familiar with the requirements, the District had paid prevailing wage and had the required Davis-Bacon documentation for two of the three projects spent out of ESSER funds. The remaining project was in the amount of $46,870 for Locker Room Floor Renovations at the High School. The District was not aware of the Davis-Bacon requirements when the Business Manager originally contacted Kiefer in 2020 about the rubber flooring (no guidance was available). Due to COVID and delays in materials, the project was pushed back and this requirement was not reconsidered. District Administration has been made aware of the requirements using Federal ESSER funds going forward. In addition, the District policy (DJF) regarding purchasing procedures, that did not specifically include Davis-Bacon language, was updated to include Davis-Bacon requirements (Board approved 9/27/22). Further, the District intends to closely follow internal controls pertaining to federal grant management in order to prevent future issues as described in Finding 2022-001. Anticipated Completion Date: 09/27/22 Responsible Contact Person: Julie Taylor, Treasurer

View Audit 41547

Finding 47811 (2022-044)

Material Weakness 2022

State of Oregon

OR

Matching / Level of Effort / Earmarking § 200.303

2022-044 Oregon Health Authority Implement a consistent methodology for calculation of maintenance of effort Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for ...

2022-044 Oregon Health Authority Implement a consistent methodology for calculation of maintenance of effort Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Matching, Level of Effort, Earmarking Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 42 USC 300x-2(a)(1)(C); 42 USC 300x-4(b)(1); 42 USC 300x-9(c)(1); 42 USC 300x-22(b)(1)(C); 42 USC 300x-30(a); 2 CFR 200.303 The Mental Health Block Grant and Substance Abuse Block Grant are subject to various Maintenance of Effort and Earmarking requirements. These requirements ensure the department meets minimum expenditure thresholds. Federal regulations require recipients of federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Based on auditor recalculations, we determined the department was in compliance with the applicable Maintenance of Effort and Earmarking requirements during state fiscal year 2022. However, we noted the following control weaknesses in the department?s calculations and demonstration of their compliance with the requirements: The department is required to expend 10% of the federal award for early serious mental illness and a first episode psychosis treatment services under the Mental Health Block Grant. The 10% set aside is calculated and budgeted when federal awards are granted. However, tracking of expenditures is not performed to ensure compliance is achieved. The department is required to maintain state expenditures for community mental health services and authorized substance abuse activities at a level not less than the average expenditures of the prior two state fiscal years. The department is also required to ensure expenditures for systems of integrated services for children with serious emotional disturbance and substance abuse treatment for pregnant women and women with dependent children is not less than the amount expended for these services in fiscal year 1994. The applicable expenditures were not consistently or accurately calculated by the department in each of the state fiscal years included in the Maintenance of Effort determinations. Additionally, no written procedures exist for the calculations. The department is at risk of noncompliance without controls in place to help ensure expenditures are tracked and calculations are consistently applied across fiscal years. We recommend department management implement controls to ensure applicable expenditures are adequately tracked and calculations applicable to the maintenance of effort requirements are consistently performed across fiscal years. We further recommend department management work with the federal awarding agency to submit corrected maintenance of effort totals to ensure appropriateness of future maintenance of effort determinations. MANAGEMENT RESPONSE: We agree with this recommendation. There were inconsistencies in how Maintenance of Effort (MOE) has been calculated. The applicable expenditures were not consistently or accurately calculated in each state fiscal year. The use of Marijuana paid expenses were not consistently used for both Mental Health and Substance Abuse Block Grant. We have met with SAMHSA MHBG State Project Office (SPO) for clarification on how Marijuana funds can be utilized in the calculation for the MOE. We have received guidance and clarification. We have recalculated MOE for the Block grants for SFY2022, SFY2021, and SFY2020 and are still doing data checks on these recalculations. With any changes to be made to previous years? MOE calculations, we must resubmit the request and reasons behind the changes to the SAMHSA project officers. HSD Budget is working on a written desk procedures to ensure applicable expenditures are adequately tracked and calculated to the maintenance of effort requirements and are consistently performed. Anticipated Completion Date: February 28, 2024 Contact: Annabelle Atalig, Budget and Fiscal Manager

View Audit 45093

Finding 47799 (2022-032)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.332

2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Fami...

2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6 , 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.332(a) ? (h) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward to determine the extent and scope of subrecipient monitoring activities. Monitoring activities should be based on the results of a given subrecipient?s determined risk. Pass-through entities must also communicate certain award information to subrecipients as the time of the subaward. The department, as the pass-through entity, has long-established subrecipient monitoring procedures broken into two categories: program and fiscal monitoring. Program monitoring is performed by program-specific staff and focuses on requirements related to certain aspects of Activities Allowed and Client Eligibility. During FY2022, the department performed program monitoring activities as planned. Fiscal monitoring reviews compliance requirements related to Allowable Costs, Activities Allowed, and Earmarking. However, fiscal monitoring activities were limited due to staff turnover. As a result, limited fiscal monitoring procedures were performed for 5 of 17 subrecipients, and fiscal monitoring risk assessments were not performed for any of the 17 subrecipients. Without the performance of subrecipient risk assessments and adequate fiscal monitoring, the department risks distributing program funds to subrecipients out of compliance with federal program requirements. Additionally, we reviewed 5 randomly selected subrecipients to determine whether all required grant award information was communicated at the time of the subaward. For all of the 5 subrecipients reviewed, only some of the required information was communicated at the time of the award. The required information missing in the original grant agreements was communicated via agreement amendments several months later. Without timely communication of required grant information, subrecipients may not have all the information they need for the subaward they received. We recommend department management ensure subrecipient risk assessments are performed for all subrecipients and ensure required fiscal monitoring activities are performed based on the results of the risk assessments. We also recommend department management ensure all required award information is communicated to subrecipients at the time of the subawards. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS lost critical fiscal monitoring staff and was unable to complete all risk assessments and fiscal monitoring due to this. OHCS is on track to complete fiscal monitoring and risk assessments for all subrecipients of LIHEAP in FY23. Additionally, OHCS has established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller or Michelle Cole, Assistant Director of Energy Services

View Audit 45093

Finding 47756 (2022-003)

Material Weakness 2022

Union Township School Corporation

IN

School Nutrition Programs Cash Management Material Weakness § 200.303

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed ...

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed off on between the submitter and the Food Service Consultant or Kitchen Manager(s) in order to ensure accuracy. Anticipated Completion Date: January 23, 2023.

View Audit 41100

Finding 47749 (2022-004)

Material Weakness 2022

Liberty-Perry Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring Cash Management § 200.303

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will...

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023

View Audit 54302

Finding 47742 (2022-003)

Material Weakness 2022

Three Rivers Community Schools

MI

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

Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budge...

Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Ultimately a reconciliation was performed and approximately $ 99,000 was overcharged to Title I and subsequently reclassified as a non- grant expenditure. However, the School District requested and received reimbursement for this amount during the year- end June 30,2022. Planned Corrective Action: The School District will implement procedures to complete a review and reconciliation process to support the amount charged to Title I based on budget estimates is reasonable when compared to actual time expended on federal and state grants, specifically Title I Reconciliation will occur more than once a year to be able to align grant budgets, as needed. Contact person responsible for corrective action: Jennifer Graber, Director of Curriculum and Instruction and Blair Brindley, Director of Business Operations Anticipated Completion Date: 6/30/2023

View Audit 53995

Finding 47733 (2022-003)

Material Weakness 2022

Dugger Union Community Schools CORP

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.327

Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Ba...

Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction) (2CFR section 200.327; Appendix II D to 2 CFR Part 200). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payroll) (29 CFR section 5.5 and 5.6; the A-102 Common Rule(section 36(i)(S)): 0MB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.327). Condition: A LEA must use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics that must meet Davis-Bacon prevailing wage requirements. Cause: The School failed to timely notify a certain contractor about the Davis-Bacon Act contract clause requirements related to the prevailing wage rate for contractors and subcontractors. As a result, the contractor did not provide the certified payrolls or statement of compliance. Potential Effect: The contractor may not have complied with the wage requirements. Questioned costs: $214,716.62. Context: A total sample of one (1) item related to a certain contractors HVAC project was selected as part of allowable cost testing for the Education Stabilization Fund. Recommendation: We recommend that the School provide timely communication related to the prevailing wage rate requirements for contracts with future contractors and subcontractors. The School should also ensure that the proper prevailing wage rate clauses are included in future contracts. We further recommend that the School ensure the contractors and subcontractors compliance with the required federal compliance requirements. Action: We concur with the recommendation and will implement the appropriate language identifying the prevailing wage rate requirements in future contracts with both contractors and subcontractors. Furthermore, certified payrolls and statements of compliance with be required and tracked for each project.

View Audit 53695 Questioned Costs: $1

Finding 47720 (2022-001)

None 2022

City of Gloucester, Massachusetts

MA

Questioned Costs Matching / Level of Effort / Earmarking § 200.302

Condition: The subsidiary ledger for community development rehabilitation loans maintained by the Department did not agree to the City?s general ledger. Corrective Action Planned: A thorough review of the Grants Division?s loan files was conducted by the City?s Fiscal Analyst in 2018/2019. Correctio...

Condition: The subsidiary ledger for community development rehabilitation loans maintained by the Department did not agree to the City?s general ledger. Corrective Action Planned: A thorough review of the Grants Division?s loan files was conducted by the City?s Fiscal Analyst in 2018/2019. Corrections and notations from that analysis will be included when the loan data is imported into the current grant management software. Once the import has been completed, the Grants Division will provide the relevant City Offices with the most current loan data. Ideally, loan balances will also be managed using the accounts receivable module in MUNIS. Anticipated Completion Date: June 2023 Contact: Jaimie Corliss, Grants Administrator

View Audit 52709

Finding 47715 (2022-001)

Material Weakness 2022

Morgan County

IN

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

FINDING 2022-001 Contact Person Responsible for Corrective Action: Linda Pruitt Contact Phone number: 765-342-1001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Morgan County Commissioners adopted Ordinance No. 2023-10 which establishes interna...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Linda Pruitt Contact Phone number: 765-342-1001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Morgan County Commissioners adopted Ordinance No. 2023-10 which establishes internal control procedures related to the expenditure of ARPA funds. This ordinance also requires reports to be reviewed by the Auditor?s office prior to submission and a printed copy with the County Administrator?s signature and the County Auditor or Deputy Auditor?s signature shall be retained. This ordinance took effect upon passage on April 17, 2023. Anticipated Completion Date: Has already been corrected.

View Audit 51137

Finding 47679 (2022-001)

Significant Deficiency 2022

Wittenberg University

OH

Student Financial Aid Matching / Level of Effort / Earmarking

Identifying Number: 2022-001 Finding: During the course of testing, the University incorrectly calculated Pell grant on one student from a sample of 40, incorrectly calculated a Title IV refund on one student from a sample of 2, and did not complete a Title IV refund within 14 days on one student ...

Identifying Number: 2022-001 Finding: During the course of testing, the University incorrectly calculated Pell grant on one student from a sample of 40, incorrectly calculated a Title IV refund on one student from a sample of 2, and did not complete a Title IV refund within 14 days on one student from a sample of 25. Corrective Action Taken or Planned: Wittenberg University's Office of Financial Aid has seen changes in staffing over the last two years with new employees having limited experience regarding student financial aid federal, state and institutional regulations. These changes have caused delays and misunderstandings related to Pell grant calculations and Title IV refund calculations. As of November 2021, one part-time financial aid employee was hired and in December 2021, the other open position (full-time status) was filled. With new employees being continuously trained and developed on federal, state and institutional guidelines, the Director of Financial Aid, or their designee, will review all calculations performed by employees moving forward. The institution will also implement reporting tools to ensure Pell, Title IV refunds, and other calculations are correct based on federal, state and institutional guidelines. Wittenberg University's Office of Student Accounts has also seen changes in staffing over the last two years with new employees having limited experience regarding accounts receivables and Title IV regulations. These changes have caused misunderstandings around Title IV refunds. The Office will implement new reporting tools where all credit balances on students' accounts will be reviewed and, if applicable, refunded at least once per week. The weekly reports and refunds will be monitored and reviewed by the Controller, or their designee, per week in consultation with the Office of Student Accounts. Completed Date: Fiscal year 2023

View Audit 46772

Finding 47659 (2022-002)

Material Weakness 2022

Oconto County, Wisconsin

WI

Questioned Costs Procurement, Suspension & Debarment Material Weakness § 200.320

The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective a...

The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director

View Audit 51115 Questioned Costs: $1

Finding 47657 (2022-003)

Material Weakness 2022

Oconto County, Wisconsin

WI

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 2023 Name of the contact per...

The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director

View Audit 51115

Finding 47649 (2022-002)

Material Weakness 2022

South Knox School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The food service director will prepare and sign the monthly reimbursement claim then...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The food service director will prepare and sign the monthly reimbursement claim then have the claim reviewed by another cafeteria worker or the corporation treasurer who will then sign off on the claim to be submitted. Anticipated Completion Date. Immediately

View Audit 47743

Finding 47645 (2022-007)

Material Weakness 2022

South Adams Schools

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

CORRECTIVE ACTION PLAN FINDING 2022-007 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district provided documentation of the email correspondence with the design build project manager...

CORRECTIVE ACTION PLAN FINDING 2022-007 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district provided documentation of the email correspondence with the design build project manager. The project manager emailed the district once a month with two separate invoices showing what work had been completed on the project. Once the email was received we had an individual internally check the invoices line for line to confirm that all costs were included in both invoices. Verbal authorization was given to accounts payable to proceed with payment. The district did not have documentation of email verification attesting approval of the invoices. Description of Corrective Action Plan: We have spoken to PSI about a process. We have determined the following, PSI requires subcontractors to submit the certified payroll reports along with their billings. PSI accounting team collects and verifies dates of the CP reports. PSI does not fund the subcontractors? billings until receipt of reports. Once PSI had verified their process the billings will be sent to the district and approval from the Superintendent or Business Manager will be determined before bills will be submitted to the Business Office Manager for submission of payment for the School Board Approval. Anticipated Completion Date: Immediately

View Audit 48846

Finding 47644 (2022-006)

Significant Deficiency 2022

South Adams Schools

IN

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

CORRECTIVE ACTION PLAN FINDING 2022-006 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: The district does not concur with this finding. The reason is as follows: According to the federal grant guidelines you must not ...

CORRECTIVE ACTION PLAN FINDING 2022-006 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: The district does not concur with this finding. The reason is as follows: According to the federal grant guidelines you must not pay for any work, services, or products on a project until the work is completed. The $1,685,526 is what was completed within the timeframe of the audit. Asset Control company is who the district uses to complete their capital asset listing every 2 years. At the time of the visit Asset Control was made aware of our project. They had requested that we provide them with the entire project cost. Asset Control wanted to include the full price for insurance coverage because the project would still be ongoing. The district provided documentation of the invoices paid during the audit period to show the amount of the project was paid for federal grant funds at the time of the audit period. Description of Corrective Action Plan: The district has no corrective action plan because the project is now completed and Asset Control company has the full cost of the project list within our assets. Anticipated Completion Date: Immediately

View Audit 48846

Finding 47635 (2022-005)

Significant Deficiency 2022

South Adams Schools

IN

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

CORRECTIVE ACTION PLAN FINDING 2022-005 Contact Person Responsible for Corrective Action: Special Education Cluster/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Special Education Cluster to obtain the correc...

CORRECTIVE ACTION PLAN FINDING 2022-005 Contact Person Responsible for Corrective Action: Special Education Cluster/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Special Education Cluster to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Adams-Wells Special Services Co-op to ensure that the corrective action plan that was submitted will be followed. Anticipated Completion Date: Immediately

View Audit 48846

Finding 47623 (2022-003)

Material Weakness 2022

Shoals Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Ind...

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: For all four monthly claims selected for testing, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Tamara Florio, Director of School Nutrition, will prepare and submit the claims after they have been signed and reviewed by Kendra Wright, Treasurer. Kendra Wright, Treasurer, will also compare claims with reimbursements and will sign prepared monthly reimbursement claim reports. Responsible Party and Timeline for Completion: Tamara Florio, Director of School Nutrition, and Kendra Wright, Treasurer ? these changes will be implemented effective immediately.

View Audit 48844

Finding 47616 (2022-002)

None 2022

Eastern Center for Arts and Technology

PA

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

2022-002 HEERF Institutional Aid Portion ? Assistance Listing No. 84.425F, Grant Period May 20, 2020 through May 11, 2022; and Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ? Assistance Listing No. 84.425E, grant period April 25, 2020 through May 11, 2022 Recommendation: Easte...

2022-002 HEERF Institutional Aid Portion ? Assistance Listing No. 84.425F, Grant Period May 20, 2020 through May 11, 2022; and Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ? Assistance Listing No. 84.425E, grant period April 25, 2020 through May 11, 2022 Recommendation: Eastern Center for Arts and Technology should more closely monitor the timing of the expenditure of federal funds received. In addition, Eastern Center for Arts and Technology should return unexpended funds once the grant period has ended. Corrective Actions Plan: Moving forward, we will be creating a means of capturing federal grant costs by using funding sources that are provided through our financial software program to track and monitor federal grants. In doing this, it will allow us to account for the funds appropriately. The grant time frame for the expenditure of federal funds was extended to June 30, 2023. Due to this, we will not have to return any federal funding.

View Audit 46390

Finding 47614 (2022-001)

Significant Deficiency 2022

Western Maryland Consortium

MD

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

CORRECTION ACTION PLAN February 8, 2023 Oversight Agency for Audit: State of Maryland Department of Labor 1100 N01ih Eutaw Street Baltimore, MD 21201Western Maryland Cons01iium respectfully submits the following corrective action plan for the fiscal year ended June 20, 2022. Name and address of inde...

CORRECTION ACTION PLAN February 8, 2023 Oversight Agency for Audit: State of Maryland Department of Labor 1100 N01ih Eutaw Street Baltimore, MD 21201Western Maryland Cons01iium respectfully submits the following corrective action plan for the fiscal year ended June 20, 2022. Name and address of independent public accounting firm: DeLeon & Stang CP As and Advisors 100 Lakeforest Blvd. Suite 650 Gaithersburg, MD 20877 Audit Period: July 1, 2021 through June 30, 2022 The findings from the Fiscal Year Ended June 30, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-Federal Award Programs Audits U.S. Deparment of the Treasury Passed through Dept. of Labor, Licensing and Regulation CFDA #21.127 - Coronavirus State & Local Fiscal Recovery Funds (ARPA) Finding 2022-001- Internal Controls over Suspension and Debarment Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires non-federal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000. A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person. Condition: During fiscal year 2022, there was one payment to a subrecipient and seven financial assistance payments to local businesses that were equal to or greater than $25,000. There were no checks of suspension and debarment prior to the payment for any of these transactions. Cause: During fiscal year 2022, there was turnover in the Fiscal Manager position and per inquiry, it appears suspension and debarment checks were an oversight. Effect: In August 2022, a suspension and debarment check was performed for the subrecipient, whom was not identified as an excluded party. The remaining seven businesses were checked as a result of the audit fieldwork in November 2022 and were not on the excluded parties list. Although none of the entities were found to be on the excluded parties list, the risk of noncompliance is heightened if the suspension and debarment checks are not completed on the front-end prior to payment. Questioned Costs: NIA Repeat Finding: No Recommendation: We recommend the Organization review its current policies to ensure they are following the suspension and debarment provisions set forth in the Uniform Guidance, lessening the risk that payments are made to parties who may be excluded from receiving federal funds. Action Taken: In response to Finding 2022-001- Internal Controls over Suspension and Debarment the management of the Western Maryland Consortium fully acknowledges and in agreement with the finding and with the need for corrective action. The following actions will be taken: The Fiscal Policy for the Western Maryland Consortium will be amended to include procedures to check intended payee entities for suspension or debarment in sam.gov. This policy shall be amended prior to the end of February 2023. 2) Future contracts with local businesses will include verbiage or a clause that covers their eligibility to receive federal funds and/or a certification will be obtained from the entity verifying their eligibility. This action shall take place immediately on all contracts. 3) All entities that have received funds from the Western Maryland Consortium during the period of time between the end of the audit period (June 30, 2022) and the date of the finding (February 8,2023) will be checked for exclusions and/or debarments immediately. This action shall take place prior to the end of Februaiy 2023. The names of the persons responsible for the above actions are the fiscal manager, Kimberly McMurtrie, and the director, Debora Gilbert, of the Western Maryland Cons01iium. If the State of Maryland Department of Labor has questions regarding this plan, please call (301) 791- 3076 and speak to either Kimberly McMurtrie, Fiscal Manager (xl20) or Debora Gilbert, Director (x l24) at the Western Maryland Consortium.

View Audit 46383

Finding 47608 (2022-002)

Significant Deficiency 2022

Shiloh Manor, Inc.

CT

HUD Housing Programs Questioned Costs Reporting

Finding 2022-002 ? Major Federal Award Programs Audit Comments on the Finding and Recommendation We concur with the auditors finding as follows: During the year ended December 31, 2022, the project overpaid payroll expenses in the amount of $2,212 from project cash without HUD approval. The amount...

Finding 2022-002 ? Major Federal Award Programs Audit Comments on the Finding and Recommendation We concur with the auditors finding as follows: During the year ended December 31, 2022, the project overpaid payroll expenses in the amount of $2,212 from project cash without HUD approval. The amount due to project as of December 31, 2022 is $2,212. Action(s) Taken or Planned on the Finding Employee had a payment plan put in place for repayment over a 26 month period. The employee continued with the employee repayment in 2023 and the last installment was made on the payroll date 8/11/2023. Regards Kimalee Williams Management Agent

View Audit 41992 Questioned Costs: $1

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