Corrective Action Plans

Finding 47389 (2022-001)

Significant Deficiency 2022

Johnson City Energy Authority Dba Brightridge

TN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Questioned Costs

Corrective Action Plan: The USDA Rural Economic Development Loan (REDL) is an 80%/20% loan, where the ultimate recipient is responsible for 20% of the cost of each dollar spent up to the maximum loan amount. For this finding, the ultimate recipient was approved for a $1,000,000 loan that requires $1...

Corrective Action Plan: The USDA Rural Economic Development Loan (REDL) is an 80%/20% loan, where the ultimate recipient is responsible for 20% of the cost of each dollar spent up to the maximum loan amount. For this finding, the ultimate recipient was approved for a $1,000,000 loan that requires $1,250,000 to be spent to receive the full loan of $1,000,000. BrightRidge, the intermediary, paid out 100% of the first $866,307 of receipts provided by the ultimate loan recipient instead of 80% which would have been $693,045.60. In doing so, BrightRidge intended to pay a lessor percentage on the remaining receipts provided by the ultimate recipient to ensure an 80%/20% sharing was complied with on the total loan amount of $1,000,000. The loan is secured by an irrevocable standby letter of credit provided by the ultimate recipient. BrightRidge was made aware by our independent auditors that regardless of the intent, payments of any monies should be supported by the 80%/20% split based on receipts from the ultimate recipient. BrightRidge agrees and understands that payments to the recipient must not exceed 80% of the receipts from approved expenditures on any future USDA REDL loan. At June 30, 2022, the loan is not fully paid out due to delays in the delivery of cutting machinery that will account for most of the final payment. The remaining $133,693 of USDA funds will be paid out to the ultimate recipient when receipts of $383,693 are provided by the ultimate recipient. BrightRidge will continue to monitor the final payments to the ultimate recipient and will adhere to payout requirements on any future USDA Rural Development Loans. BrightRidge has had four USDA REDL loans in the history of the organization making these an infrequent occurrence. As of June 30, 2022, BrightRidge has no other pending USDA REDL loan applicants.

View Audit 41564 Questioned Costs: $1

Finding 47388 (2022-001)

None 2022

St. Simeon II Housing Development Fund Company, Inc.

NY

Questioned Costs HUD Housing Programs Reporting

St. Simeon II Housing Development Fund Company, Inc. respectfully submits the following Corrective Action Plan for the year ended July 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard,...

St. Simeon II Housing Development Fund Company, Inc. respectfully submits the following Corrective Action Plan for the year ended July 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2022-001 Corrective Action Planned ? Management will insure the audited financial statement are filed into the REAC system within 90-days after year-end. Contact Person(s) Responsible ? Jennifer McEvoy-Riley, Executive Director Anticipated Completion Date ? April 11, 2023 Auditee Disagreements ? N/A This corrective action plan was prepared by St. Simeon Properties, the management company, on behalf of St. Simeon II Housing Development Fund Company, Inc.. St. Simeon Properties 9 Hilltop Court, Suite 1 Poughkeepsie, NY 12601

View Audit 45906

Finding 47381 (2022-003)

Material Weakness 2022

Southwest Behavioral Health Services, Inc. and Subsidiaries

AZ

Allowable Costs / Cost Principles Questioned Costs Material Weakness § 200.405

Item: 2022-003 Assistance Listing Number: 14.241 Programs: Housing Opportunities for Persons with Aids Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 144347 Award Year: July 1, 2021 ? June 30, 2022 ...

Item: 2022-003 Assistance Listing Number: 14.241 Programs: Housing Opportunities for Persons with Aids Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 144347 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? June 30, 2023 Compliance Requirement: Allowable Activities and Costs Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish additional policies and procedures to ensure adequate review of cell phone bills occurs and terminated and transferred employees are removed immediately. Additionally, we will implement proper review controls over the cost reimbursement reports to identify issues like these timely.

View Audit 42283 Questioned Costs: $1

Finding 47380 (2022-002)

Material Weakness 2022

Southwest Behavioral Health Services, Inc. and Subsidiaries

AZ

Allowable Costs / Cost Principles Questioned Costs Material Weakness § 200.405

Item: 2022-002 Assistance Listing Number: 14.231 Programs: COVID-19 Emergency Solutions Grant ? Homeless Street Outreach Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 154962-0 Award Year: July 1, 2...

Item: 2022-002 Assistance Listing Number: 14.231 Programs: COVID-19 Emergency Solutions Grant ? Homeless Street Outreach Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 154962-0 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? September 30, 2022 Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. One employee's phone bill continued to be charged to the grant after they stopped working on the program. Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish additional policies and procedures to ensure adequate review of cell phone bills occurs and terminated and transferred employees are removed immediately. Additionally, we will implement proper review controls over the cost reimbursement reports to identify issues like these timely.

View Audit 42283 Questioned Costs: $1

Finding 47379 (2022-002)

Significant Deficiency 2022

Carlsbad Municipal School District

NM

School Nutrition Programs Significant Deficiency Matching / Level of Effort / Earmarking § 200.303 § 200.430

Auditors? Recommendation: The auditor recommends that the District implement controls for documenting and retaining information to indicate the District follows the requirements over 2 CFR section 200.430(i). Action Taken: The district will expand the internal controls over the timekeeping and payro...

Auditors? Recommendation: The auditor recommends that the District implement controls for documenting and retaining information to indicate the District follows the requirements over 2 CFR section 200.430(i). Action Taken: The district will expand the internal controls over the timekeeping and payroll processes by requiring all employee pay applications for the Child Nutrition program be reviewed and approved by the Human Resources Department. A schedule of Pay Rates will be created and submitted to the Board of Education for formal approval, along with the other Salary Schedules approved with the annual budget. In addition, the district is moving to an electronic timekeeping system that will eliminate the use of paper timesheets that must be manually processed for payroll purposes. All Board approved pay rates will be programmed into the electronic timekeeping system so that the need for manual pay rate entry and gross pay calculations will be eliminated. Due Date for Completion: July 1, 2023 Responsible Party: Lisa Rhoades, Food Service Manager Lisa Robinson, Assistant Superintended for Talen Acquisition, and Laura Garcia, Chief Financial Officer

View Audit 40907

Finding 47375 (2022-002)

Significant Deficiency 2022

The Geneva Foundation

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding 2022-002 : Significant deficiency in internal control over compliance for special tests and provisions. Contact Person(s): Matthew Rueckert, Chief Operating Officer and Ana Trujillo, Director, Finance and Accounting. Corrective action planned: Geneva management concurs with the recommendatio...

Finding 2022-002 : Significant deficiency in internal control over compliance for special tests and provisions. Contact Person(s): Matthew Rueckert, Chief Operating Officer and Ana Trujillo, Director, Finance and Accounting. Corrective action planned: Geneva management concurs with the recommendations. The Finance Office will review procedures and re-train staff to ensure monitoring of level of effort (LOE) for key personnel is reviewed monthly. Management believes that review of financial and LOE reporting are clearly defined, documented, and in compliance with accounting principles generally accepted in the United States of America and sponsor requirements; however, management will seek to strengthen the documentation, training, and communications between Finance and the Office of Award Management. If process deficiencies are identified or Standard Operating Procedures are not current, updates will be made, and end user compliance training will be rolled out to ensure a clear understanding. Anticipated completion date August 31, 2023

View Audit 40905

Finding 47352 (2022-002)

None 2022

Radford City School Board

VA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

The School Board will develop a process to review compliance requirement for future federally funded programs and will ensure that all requirements of same are met.

View Audit 51576

Finding 47338 (2022-003)

Significant Deficiency 2022

Peralta Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District Administration & Records will perform a study of the current business processes to identify data discrepancies. The District will engage the Clearinghouse and review the applicable reporting procedures with the financial aid offices to ensure sound internal controls over reporting and u...

The District Administration & Records will perform a study of the current business processes to identify data discrepancies. The District will engage the Clearinghouse and review the applicable reporting procedures with the financial aid offices to ensure sound internal controls over reporting and updating of NSLDS enrollment data. Planned completion date for corrective action plan: June 30, 2023.

View Audit 51569

Finding 47337 (2022-002)

Significant Deficiency 2022

Peralta Community College District

CA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The district has entered into a contract with Huron Consulting Group to address internal controls pertaining to reconciliation of Title IV funds, R2T4 processing, award packaging and verification. Huron has created more robust packaging and disbursement rules to ensure only eligible students are awa...

The district has entered into a contract with Huron Consulting Group to address internal controls pertaining to reconciliation of Title IV funds, R2T4 processing, award packaging and verification. Huron has created more robust packaging and disbursement rules to ensure only eligible students are awarded and paid. Additionally, the district has created business processes and procedures to improve internal controls over federal awards. While the cutoff date for the audit was missed for the 2021-2022 school year, corrective actions have been taken to ensure the reconciliation of Title IV funds and secondary reviews have been completed and are currently underway for 2022-2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2023.

View Audit 51569

Finding 47326 (2022-002)

Significant Deficiency 2022

Barstow Community College District

CA

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

View of Responsible Officials and Corrective Action Plan The District will implement processes to ensure that student withdrawal dates match what is reported to NSLDS, that enrollment status matches and is reported accurately.

View Audit 47210

Finding 47325 (2022-001)

Significant Deficiency 2022

Barstow Community College District

CA

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

View of Responsible Officials and Corrective Action Plan The District will implement procedures to ensure that the student withdrawal calculations are performed accurately and occur within 45 days from the end of the academic period.

View Audit 47210

Finding 47290 (2022-008)

None 2022

Carolina College of Biblical Studies

NC

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

FINDING 2022-008 ? Biennial Review of the Drug and Alcohol Abuse Prevention Program and Policies Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: J...

FINDING 2022-008 ? Biennial Review of the Drug and Alcohol Abuse Prevention Program and Policies Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The College administration did not complete the biennial review of their Drug Free Workplace Policy and drug free prevention process. Corrective Action Plan: Management will complete the biennial review after the drug free workplace and drug and alcohol abuse prevention polices have been updated and the required data has been tracked. Anticipated Completion Date: The corrective action will be completed by June 30, 2023 Contact Person: Richard Hovater, Vice President of Finance 910-323-5614

View Audit 47703

Finding 47289 (2022-007)

None 2022

Carolina College of Biblical Studies

NC

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

FINDING 2022-007 ? Drug Free Workplace Policy and Drug and Alcohol Abuse Prevention Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($509,387) 84.063 ($331,937) Award Number: P268K217533 P063P207533 Federal Award Year: July 1, 2020 t...

FINDING 2022-007 ? Drug Free Workplace Policy and Drug and Alcohol Abuse Prevention Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($509,387) 84.063 ($331,937) Award Number: P268K217533 P063P207533 Federal Award Year: July 1, 2020 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Drug Free Workplace Policy and other drug and alcohol abuse prevention material does not include all of the required documentation. Corrective Action Plan: Management will update the drug free workplace policy and drug and alcohol abuse prevention in the 2023 fiscal year. The information will be distributed to the staff and students. Anticipated Completion Date: The corrective action will be completed by June 30, 2023 Contact Person: Richard Hovater, Vice President of Finance 910-323-5614

View Audit 47703

Finding 47288 (2022-006)

None 2022

Carolina College of Biblical Studies

NC

Questioned Costs Student Financial Aid Reporting

FINDING 2022-006 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was report...

FINDING 2022-006 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for two of the sixteen students selected for testing. Corrective Action Plan: The Student Financial Aid Director corrected the enrollment status for the students in question in August 2022. Procedures are being improved to ensure that the student enrollment statuses are reported to NSDLS accurately and timely. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

View Audit 47703

Finding 47287 (2022-004)

None 2022

Carolina College of Biblical Studies

NC

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

FINDING 2022-004 ? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditures: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,22...

FINDING 2022-004 ? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditures: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,227 Condition Found: The R2T4 was not calculated correctly for two of the sixteen students in the compliance testing sample. A separate sample was selected to test additional R2T4 calculations. The R2T4 was not calculated correctly for two of the three students in the R2T4 testing sample. Between the two samples, all of the R2T4s completed during the year were reviewed. Corrective Action Plan: All of the R2T4s completed during the year were recalculated in October 2022. On October 6, 2022, $3,381 of Federal Pell Grant Funds and $846 of Federal Direct Loan Funds were returned to the Department of Education. Procedures will be improved to ensure that R2T4s are calculated correctly. Anticipated Completion Date: The corrective action was completed by October 6, 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

View Audit 47703 Questioned Costs: $1

Finding 47286 (2022-003)

None 2022

Carolina College of Biblical Studies

NC

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2022-003 ? Exit Interview Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Two of the sixteen federal student financi...

FINDING 2022-003 ? Exit Interview Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Two of the sixteen federal student financial aid recipients in our sample did not complete an exit interview or were not sent exit interview instructions. Corrective Action Plan: An exit interview was sent to both of students in question on August 9, 2022. Procedures will be improved to ensure that an exit interview is completed when a student withdraws from the College Anticipated Completion Date: The corrective action was completed on August 9, 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

View Audit 47703

Finding 47285 (2022-002)

None 2022

Carolina College of Biblical Studies

NC

Student Financial Aid Cash Management Reporting

FINDING 2022-002 ? COD Disbursement Dates Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: ...

FINDING 2022-002 ? COD Disbursement Dates Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for five of the eight students receiving Federal Direct Loans and ten of the fourteen students receiving Federal Pell Grant funds in our sample. A total of twelve students were affected by this finding. Corrective Action Plan: The Vice President of Finance corrected the disbursement dates for the students in question in October 2022. Going forward, the Student Financial Aid Office and Business Office will coordinate the drawdown of funds, reporting to COD, and posting to student accounts. Anticipated Completion Date: The corrective action was completed in October 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

View Audit 47703

Finding 47242 (2022-001)

None 2022

Northern Kentucky University

KY

Student Financial Aid Special Tests & Provisions Reporting

Views of responsible officials and planned corrective action plan ? Northern Kentucky University will meet the requirements outlined by the U.S. Department of Education for treatment of Federal Aid funds (R2T4) when a student ceases to be enrolled prior to the end of a period of enrollment. The fol...

Views of responsible officials and planned corrective action plan ? Northern Kentucky University will meet the requirements outlined by the U.S. Department of Education for treatment of Federal Aid funds (R2T4) when a student ceases to be enrolled prior to the end of a period of enrollment. The following corrective action will be taken by NKU to ensure compliance: ? The University will return funds within 45 days. ? The University will review its Return of Funds procedures to ensure compliance.

View Audit 42317

Finding 47229 (2022-002)

Significant Deficiency 2022

Wyandanch Union Free School District

NY

Questioned Costs Eligibility Significant Deficiency

FINDING # 2022-002 (REPEAT FINDING OF #2021-002, 2020-003, and 2019-004) U.S. Department of Education ? Passed-through the NYS Education Department Special Education - Grants to States (IDEA, Part B); ALN 84.027; Project #0032-22-0877; Grant Period ? Fiscal Year Ended June 30, 2022 Special Educatio...

FINDING # 2022-002 (REPEAT FINDING OF #2021-002, 2020-003, and 2019-004) U.S. Department of Education ? Passed-through the NYS Education Department Special Education - Grants to States (IDEA, Part B); ALN 84.027; Project #0032-22-0877; Grant Period ? Fiscal Year Ended June 30, 2022 Special Education - Grants to States (IDEA Preschool); ALN 84.173; Project #0033-22-0877; Grant Period ? Fiscal Year Ended June 30, 2022 Significant Deficiency Compliance Requirement: Level of Effort Criteria: According to the OMB Compliance Supplement, IDEA Part B funds received by a school district cannot be used, except under certain limited circumstances, to reduce the level of expenditures for the education of children with disabilities made by the school district from local funds, or a combination of State and local funds, below the level of those expenditures for the preceding fiscal year. To meet this requirement, school districts must meet (1) the eligibility standard and (2) the compliance standard. Condition: The District did not maintain supporting documentation for the maintenance of effort calculator for compliance for actual amounts for the 2020/2021 fiscal year and thus, the District was unable to substantiate various amounts reported within the calculator. Cause: Due to turnover of multiple positions at the District, the District did not maintain the supporting documentation used to substantiate the amounts reported in the maintenance of effort calculator for compliance. Effect: The District did not maintain the supporting documentation used to substantiate the amounts reported in the maintenance of effort calculator for compliance. Questioned Costs: None. Recommendation: We recommend the District develop a system of internal controls to maintain support for the maintenance of effort calculator for compliance. District?s Response: Implementation Plan of Action: The District agrees with these findings; had recognized this matter prior to the start of this audit and took corrective action for maintenance of effort calculator?s. Going forward the business official will file the maintenance of effort reports which will reconcile with the ST-3. Implementation Date: March 30, 2023 Person Responsible for the Implementation: Richard Snyder, the School Business Official is responsible for the implementation of this policy and procedure.

View Audit 41085

Finding 47222 (2022-003)

Material Weakness 2022

Benedict College

SC

Student Financial Aid Reporting Questioned Costs

Finding Number: 2022-003 Condition: Of the 40 students selected for enrollment reporting testing, the College did not properly update student enrollment informaion for some students in a timely manner. ...

Finding Number: 2022-003 Condition: Of the 40 students selected for enrollment reporting testing, the College did not properly update student enrollment informaion for some students in a timely manner. Planned Corrective Action: The errors are attributed to incorrect programming embedded in the school's learning management system and delays by NSC in relaying information to NSLDS. To correct the findings, Benedict is implementing the following action plan: 1) The reporting process was temporarily moved to another campus office during a staff transition in the Registrar's Office. With a new registrar and assistant registrar in place, the process will be reassigned to the Registrar. 2) The college is scheduling a process maintenance session with representatives from Jenzabar EX to ensure proper coding in the school's learning management system. Individualized training will also be scheduled for the Registrar's staff to ensure a full understanding of the mechanics of the reporting system. 3) As NSC only reports status changes when the subsequent file is received (for example, May status changes are only reported to NSLDS when the June report is received), Benedict's NSC submission schedule will be amended to every 30 days throughout the entire calendar year, thereby ensuring that the triggering event allows NSLDS receipt within 60 days. Contact person responsible for corrective action: Dr. Kimberly Haynes-Stephens, AVP for Academic Support and Assessment; Roberta Davis, Registrar; Monique Rickenbaker, Director of Financial Aid; Chief Financial Officer. Anticipated Completion Date: April 30, 2023.

View Audit 53657

Finding 47217 (2022-002)

Significant Deficiency 2022

Argos Community Schools

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Edu...

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action?Argos Community Schools will ensure that going forward, all documents will be overseen by at least two parties in the Business Office, with signed documentation. Responsible party and timeline for completion: Federal regulation requires Kelli VanDerWeele, Corporation Treasurer/Director of Business Services and Ned Speicher, Superintendent, will be overseeing and putting corrective action plan in place immediately.

View Audit 52777

Finding 47216 (2022-001)

Material Weakness 2022

Argos Community Schools

IN

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

Finding 2022-001 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Thro...

Finding 2022-001 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance 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 Special Tests and Provisions ? Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors for building projects which include playground equipment and an outdoor classroom. As of June 30, 2022, $174,607 was disbursed related to these construction projects. The construction payments represented 17% of the Education Stabilization Fund expenditures for the audit period. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The construction contracts did not include clauses for federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action?Argos Community Schools will ensure that going forward any construction we have done, funded with federal dollars will be compliant with Davis-Bacon Act Reporting laws and ensure we received required documentation, as required by Federal Law. Responsible party and timeline for completion: Federal regulation requires Kelli VanDerWeele, Corporation Treasurer/Director of Business Services and Ned Speicher, Superintendent, will be overseeing corrective action plan on any future projects. As of today, we do not have any projects in place that would be require implementation of these laws.

View Audit 52777

Finding 47207 (2022-001)

Significant Deficiency 2022

Sandusky City School District

OH

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

Finding Number: 2022-001 Planned Corrective Action: Student withdrawal and graduation files will be updated in NSLDS at the time of occurrence. A monthly review of all files will occur in NSLDS at the end of each month. Anticipated Completion Date: 03/01/2023 Responsible Contact Person: Crystal Cook...

Finding Number: 2022-001 Planned Corrective Action: Student withdrawal and graduation files will be updated in NSLDS at the time of occurrence. A monthly review of all files will occur in NSLDS at the end of each month. Anticipated Completion Date: 03/01/2023 Responsible Contact Person: Crystal Cook, Financial Aid Coordinator, and Christine Stark, Director

View Audit 53506

Finding 47195 (2022-001)

None 2022

University of Pennsylvania

PA

Cash Management Questioned Costs Subrecipient Monitoring § 200.207 § 200.305

The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that ...

The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY22, we note that the overall number of exceptions has decreased. Furthermore, the payments identified as exceptions in the FY22 audit were almost all made to vendors within our institutional standard terms of net 45 days, with the exception of 1 which was made 51 days after the request for reimbursement. The Office of Research Services remains committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, during the fall of 2022, the University implemented certain enhancements to further minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. A custom process was implemented in the University?s financial system to update payment terms to `immediate? for vendor invoices on Line of Credit sponsored awards. In addition, the University added a new metric to the reporting dashboard for its Procure-to-Pay system to specifically highlight Purchase Order invoices for sponsored awards which were on hold, to assist the university business and grant managers in prioritizing the resolution of those holds preventing 2 invoices on sponsored awards from being paid immediately. We expect to see the impact of these enhancements in the FY23 audit.

View Audit 53797

Finding 47190 (2022-001)

Significant Deficiency 2022

Menno Haven, Inc.

PA

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

Finding 2022-001 Condition/Context During the audit of the program in the prior year, known questioned costs of $30,174 were identified related to expenses improperly applied to the funding. In the Period 4 submission, the Organization should have corrected the error by reducing lost revenues repo...

Finding 2022-001 Condition/Context During the audit of the program in the prior year, known questioned costs of $30,174 were identified related to expenses improperly applied to the funding. In the Period 4 submission, the Organization should have corrected the error by reducing lost revenues reported for the amount of known questioned costs identified in the prior year as instructed by the Health Resources and Service Administration (HRSA). Lost revenues reported in the Period 4 submission were not properly reduced for the known questioned costs identified. In addition, the Period 4 submission and lost revenue calculation did not contain a review and approval prior to submission to detect potential errors of this nature. This is not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The Organization agrees with the finding. The next required filing will be reduced by the $30,174 which should have been done in Period 4. Segregation of duties between the preparation of the reports and the review/approval of them, including reviewing all supporting documents, is in place. Going forward once the information is reviewed it will be clearly stated that everything has been reviewed and to the best of the reviewer?s knowledge everything is correct, dated and signed prior to filing the information. This will be reported to the Finance Committee and Board so that it will be in the minutes. Name(s) of Contact Person(s) Responsible for Corrective Action: Ryan Fritz, Chief Financial Officer Anticipated Completion Date: This will be corrected on the next required submission.

View Audit 52826

Corrective Action Plans

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