Corrective Action Plans

Finding 32417 (2022-002)

Material Weakness 2022

Crawford County Community School Corporation

IN

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

Finding 2022-002 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: 84.425C, 84.425D, 84.425U P...

Finding 2022-002 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: 84.425C, 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 a building project. The construction payments represented 45% of the Education Stabilization Fund disbursements 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 a clause for federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. In the future, when Crawford County Community School Corporation utilizes federal funding to supplement construction costs, the construction manager will ensure awarded contracts include Davis Bacon language and be assigned the task of collecting weekly pay rate data on all contractors and subcontractors. A school employee will then review. Responsible party and timeline for completion: Brandon Johnson, Superintendent, will collect weekly pay rate data from the construction manager and review.

View Audit 27913

Finding 32412 (2022-001)

Material Weakness 2022

Board of Education of Collierville Schools

TN

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.326

2022-001: Material Weakness-Davis-Bacon Wage Rate Requirements Corrective Action: Corrective action has been taken. Management has started requiring weekly collection of payrolls from contractors for projects. These are reviewed on a weekly basis for compliance with Davis-Bacon requirements. Wage re...

2022-001: Material Weakness-Davis-Bacon Wage Rate Requirements Corrective Action: Corrective action has been taken. Management has started requiring weekly collection of payrolls from contractors for projects. These are reviewed on a weekly basis for compliance with Davis-Bacon requirements. Wage requirement clauses will be included in all contract agreements going forward. The responsibility for monitoring and reviewing certified payrolls and contracts has been assigned to the Chief of Operations or his designee. Contact Person: Anita Floyd Completion Date: December 2022

View Audit 28398

Finding 32402 (2022-001)

Material Weakness 2022

Enumclaw School District No. 216

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Ass...

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Assistance Listing Number(s): 84.425 Federal Program Name and Granting Agency: COVID-19 Education Stabilization Fund, U.S. Department of Education Pass-Through Agency Name: Office of Superintendent of Public Instruction Finding Caption: The District did not have adequate internal controls for ensuring compliance with Davis-Bacon Act (prevailing wage rate) requirements. Background: During the 2020-2021 school year, the District paid $658,502 from its ESSER II award to 11 contractors to repair and replace the roof at two schools, update HVAC controls in seven schools, and replace wet and rotting insulation to improve air quality and circulation to prevent the spread of COVID-19. Additionally, the District used its ESSER II award to replace faulty and broken bathroom sinks to allow for safe and consistent use of sinks for hand washing. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from the contractors to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit.

View Audit 27599

Finding 32393 (2022-003)

Significant Deficiency 2022

Cabrini University

PA

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

2022-003 Student Financial Assistance Cluster ? Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures around the retention of Perkins loans r...

2022-003 Student Financial Assistance Cluster ? Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures around the retention of Perkins loans records to ensure that all records for open loans are being properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will continue to identify open loan records with missing master promissory notes. As such loan records are identified, the University will take necessary measures to request permission to assign these loans to the Department of Education. As this work is ongoing, all current loan records will continue to be stored securely in the Bursar?s area. Name(s) of the contact person(s) responsible for corrective action: Rita Lambert, Bursar Planned completion date for corrective action plan: August 31, 2023

View Audit 27062

Finding 32391 (2022-002)

Significant Deficiency 2022

Cabrini University

PA

Reporting Student Financial Aid Significant Deficiency

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate e...

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar?s Office will review National Student Clearinghouse (NSC) information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Name(s) of the contact person(s) responsible for corrective action: Gerard J. Donahue, Registrar Planned completion date for corrective action plan: June 30, 2023

View Audit 27062

Finding 32385 (2022-001)

Significant Deficiency 2022

Elder Care Services, Inc.

FL

Matching / Level of Effort / Earmarking Reporting § 200.303

Beginning October 2023, prior to submission of required reports, clinical directors, Zoila Huston (Leon County) and Mariposa Wilson (Gadsden & Wakulla counties) will ensure the reports are reviewed and approval is documented through signature of the CEO, Jocelyne Fliger. Additionally, documentation ...

Beginning October 2023, prior to submission of required reports, clinical directors, Zoila Huston (Leon County) and Mariposa Wilson (Gadsden & Wakulla counties) will ensure the reports are reviewed and approval is documented through signature of the CEO, Jocelyne Fliger. Additionally, documentation of submission of those reports will be obtained through either appropriate signature, electronic confirmation or equivalent.

View Audit 28092

Finding 32370 (2022-003)

Significant Deficiency 2022

Inova Health System

VA

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and pr...

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and procedures will be created outlining processes and control activities to ensure reporting to federal awarding agencies and pass-through entities are complete and accurate. During the current fiscal year, Inova began implementing enhancements to Oracle?s Grants Accounting module. Once completed, this will assist management to automate certain processes and procedures that were not available after the initial implementation. The enhanced reporting capabilities will include automated reporting that will identify grants that expended federal awards. Grants Accounting will schedule quarterly meetings with Finance and GMO leadership present. The purpose of these meetings will be to review federal funding received that will ultimately be used in the preparation of financial reports submitted to the appropriate governing agencies. The Director of Grants Accounting will guide the meetings and obtain approvals from department leaders confirming amounts to be reported for federal grant awards. In preparation of the meetings, the Director of Grants Accounting will prepare an agenda to guide discussions of grant terms and conditions and applicable FAQs, more explicitly for awards received outside of Inova?s normal course of business (i.e., COVID-19). These meetings will also provide an opportunity for Finance, GMO, and Grants Accounting leaders to review the unique characteristics of the federal grant award programs on at least a quarterly basis. Meeting minutes will be maintained to document discussions and actions to be taken. The minutes will also serve as support for accounting memos related to special awards received that document Inova?s understanding of the award and related reporting requirements. All accounting memos will be prepared by the Director of Grants Accounting and reviewed by the Senior Director of Financial Reporting. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2023.

View Audit 27876

Finding 32369 (2022-001)

Significant Deficiency 2022

Inova Health System

VA

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

Recommendation: Management should design internal controls related to the documentation of the review of the expenditures for the HRSA portal submission to ensure that the reported amounts are accurate. View of Responsible Officials: Management concurs with the finding and will implement procedures ...

Recommendation: Management should design internal controls related to the documentation of the review of the expenditures for the HRSA portal submission to ensure that the reported amounts are accurate. View of Responsible Officials: Management concurs with the finding and will implement procedures to ensure that HRSA reporting reports are prepared by individuals with HRSA reporting experience and reviewed by management prior to submission. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Planned Completion Date for Corrective Action Planned: Ongoing with a completion date of December 31, 2023.

View Audit 27876

Finding 32367 (2022-001)

Material Weakness 2022

Vermont State Colleges

VT

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year:2022 Corrective Action Plan: An external consultant (Higher Education Assistance Group) was contracted to bring current ...

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year:2022 Corrective Action Plan: An external consultant (Higher Education Assistance Group) was contracted to bring current NVU?s required reporting for enrollment and student program status changes through the Spring 2022 term. This work was complete September 9. Letters/Notifications were issued to United Educators (August 10) and impacted students (week of September 5). Ongoing, NVU has received support from the registrar at our sister institution Community College of Vermont (CCV). CCV?s registrar has coordinated with the National Student Clearinghouse and submitted the first of term enrollment file for Fall 2022 on 10/3/22. NVU plans to hire a registrar soon and ongoing enrollment reporting will fall within the responsibilities of this new hire. Additionally, the Vermont State Colleges System registrar team will perform monthly checks to confirm that enrollment reporting for NVU has been completed. Timeline for Implementation of Corrective Action Plan: September 2022 Contact Person Sharron Scott, CFO

View Audit 28359

Finding 32356 (2022-002)

Significant Deficiency 2022

Viroqua Area School District

WI

Questioned Costs Cash Management Matching / Level of Effort / Earmarking

2022-002 ? Education Stabilization Fund ? Prevailing wage rate requirements Condition: There was one Education Stabilization Fund construction project performed by a contractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $33,000. There was not a prevailing w...

2022-002 ? Education Stabilization Fund ? Prevailing wage rate requirements Condition: There was one Education Stabilization Fund construction project performed by a contractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $33,000. There was not a prevailing wage clause in the contract and certified payrolls were not received. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts, subject to wage rate requirements, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $33,000 Auditor?s Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District will comply with the wage rate requirements for the Education Stabilization Fund going forward. Contact Person: Michael Brendel Anticipated Completion: June 30, 2023

View Audit 27330 Questioned Costs: $1

Finding 32277 (2022-001)

Significant Deficiency 2022

State of North Dakota

ND

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Department of Commerce Finding: 2022-001 Department of Commerce Response/Corrective Action Plan: The Department of Commerce agrees with this finding. These grants were conducted outside of our normal scope of operations and new grant processes had to be designed and implemented to manage this ...

Department of Commerce Finding: 2022-001 Department of Commerce Response/Corrective Action Plan: The Department of Commerce agrees with this finding. These grants were conducted outside of our normal scope of operations and new grant processes had to be designed and implemented to manage this grant programmatically and fiscally. These grant payments were paid by a batch file process through the Office of Management and Budget and not fiscally managed by the agency?s fiscal department. The agency does not intend to manage grant processes programmatically or fiscally with these processes again. Of the eight duplicate grant payments identified two of the payments were voided, two payments have been returned to the department and turned back to the Office of Management and Budget, and the remaining payments the department has either been in contact with the beneficiary on returning the funds or the beneficiaries have been turned over to the Attorney General?s Office for further follow-up. The department will turn over the remainder of the beneficiaries to the Attorney?s General?s Office if payment is not made timely. Contact Person Shawn Kessel, COO/Deputy Commissioner Anticipated Completion Date There is no anticipated completion date for enhancing our internal controls to ensure duplicated payments are not made to the recipients of federal funds due to the fact the agency does not intend to manage a grant within our department programmatically or fiscally with these processes again.

View Audit 36677 Questioned Costs: $1

Finding 32272 (2022-020)

Significant Deficiency 2022

State of North Dakota

ND

Questioned Costs Matching / Level of Effort / Earmarking Reporting

Finding: 2022-020 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. These services were provided by a contracted vendor in two separate sites in different cities for over ten years. In October 2018, due to staffing performance concerns...

Finding: 2022-020 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. These services were provided by a contracted vendor in two separate sites in different cities for over ten years. In October 2018, due to staffing performance concerns and licensing investigations, the state ended the contract with this vendor in one city. In April 2019 the vendor ended the contract in the second city. Three Requests for Proposals have been issued since that date and no proposals were received. Market research was conducted with several potential providers and due to lack of interest, capacity concerns, workforce issues as well as the effects of the COVID-19 pandemic, the department has been unable to meet the expenditure requirements. The Department has met several times with the Federal Substance Abuse and Mental Health Services Administration regarding this issue. Currently the Department is requesting funding from the North Dakota Legislative Assembly to develop of a Pregnant and Parenting Women?s Residential Treatment Program within the Department. If approved, the Department will work to secure locations and renovate spaces that is not allowable with the Federal Funds. Contact Person: Lacresha Graham, Manager Addiction Treatment and Recovery Program and Policy Anticipated Completion Date: September 2023

View Audit 36677 Questioned Costs: $1

Finding 32267 (2022-011)

Significant Deficiency 2022

State of North Dakota

ND

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

Finding: 2022-011 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the access and security reviews. Contact Person: Tory Brabandt, Medicaid Enterprise Directo...

Finding: 2022-011 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the access and security reviews. Contact Person: Tory Brabandt, Medicaid Enterprise Director Anticipated Completion Date: June 30, 2023

View Audit 36677

Finding 32266 (2022-010)

Significant Deficiency 2022

State of North Dakota

ND

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

Finding: 2022-010 Department of Human Services Response/Corrective Action Plan: The Department agrees with the finding. When the Department had to re-procure the Medicaid Expansion MCO contract for a January 1, 2022, start date, the contract was overhauled and made much more specific in terms o...

Finding: 2022-010 Department of Human Services Response/Corrective Action Plan: The Department agrees with the finding. When the Department had to re-procure the Medicaid Expansion MCO contract for a January 1, 2022, start date, the contract was overhauled and made much more specific in terms of the MLR requirements, so we do not anticipate the same issues happening again. Below is contract language that addresses this finding. Appendix E, Article 1 10. Reporting requirements 1. MCO shall submit two reports to STATE that includes at least the following information for each MLR Reporting Year, one of which excludes the adjustments identified in (I) and (C)(3)(d) above: 1. Total incurred claims. 2. Expenditures on quality improving activities. 3. Expenditures related to activities compliant with program integrity requirements (42 C.F.R. ?438.608(a)(1) through (5), (7), (8) and (b)). 4. Non-claims costs. 5. Premium revenue. 6. Taxes, licensing, and regulatory fees. 7. Methodology(ies) for allocation of expenditures. 8. Any credibility adjustment applied. 9. The calculated MLR. 10. Any remittance owed to STATE, if applicable. 11. A comparison of the information reported in this paragraph with the audited financial report required under 42 C.F.R. ?438.3(m). 12. A description of the aggregation method used under paragraph (F) of this article. 13. The number of Member Months. 2. MCO must require any third-party vendor providing claims adjudication activities to provide all underlying data associated with MLR reporting to that MCO within 180 days of the end of the MLR Reporting Year or within 30 days of being requested by MCO whichever comes sooner, regardless of current contractual limitations, to calculate and validate the accuracy of MLR reporting. 3. Prior to ten (10) months following the applicable MLR Reporting Year, MCO must submit the report required in paragraph (I)(1) of this article based on data including eight (8) months of claims run out. 4. MCO shall attest to the accuracy of the calculation of the MLR in accordance with requirements of this article when submitting the report required under this paragraph. 2. Prior to eleven (11) months following the applicable MLR Reporting Year or a mutually agreed upon alternative date, STATE shall finalize the MLR Reporting Year with any balance due to STATE as required in paragraph (H) of this article within sixty (60) days. Contact Person: Jared Ferguson, Medicaid Expansion Administrator Anticipated Completion Date: Already Completed

View Audit 36677

Finding 32265 (2022-009)

Significant Deficiency 2022

State of North Dakota

ND

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

Finding: 2022-009 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the risk analysis and security review for MMIS. Contact Person: Tory Brabandt, Medicaid Enterpr...

Finding: 2022-009 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the risk analysis and security review for MMIS. Contact Person: Tory Brabandt, Medicaid Enterprise Director Anticipated Completion Date: December 31, 2023

View Audit 36677

Finding 32264 (2022-008)

Significant Deficiency 2022

State of North Dakota

ND

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

Department of Human Services Finding: 2022-008 Department of Human Services Response/Corrective Action Plan: The department agrees to recover payments made on unsupported claims. The department will recover payments made on unsupported claims. Contact Person: Corey Kjos, Enterprise Operations ...

Department of Human Services Finding: 2022-008 Department of Human Services Response/Corrective Action Plan: The department agrees to recover payments made on unsupported claims. The department will recover payments made on unsupported claims. Contact Person: Corey Kjos, Enterprise Operations Manager Anticipated Completion Date: June 30, 2023

View Audit 36677 Questioned Costs: $1

Finding 32263 (2022-019)

Significant Deficiency 2022

State of North Dakota

ND

Questioned Costs Eligibility Cash Management

Finding: 2022-019 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. Due to Medicaid continuous enrollment requirements ending on March 30, 2023, the SPACES system will be converted back to its normal rules and this issue should not hap...

Finding: 2022-019 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. Due to Medicaid continuous enrollment requirements ending on March 30, 2023, the SPACES system will be converted back to its normal rules and this issue should not happen again. The Department will do a review of CHIP eligibility to ensure incorrect claims are identified and corrected. Claims paid in error will be adjusted to reflect the proper category of eligibility, so the applicable fund code is applied, which will apply the correct FMAP. Contact Person: Erik Elkins, Assistant Director, Medical Services Anticipated Completion Date: April 30, 2023

View Audit 36677 Questioned Costs: $1

Finding 32258 (2022-013)

Significant Deficiency 2022

State of North Dakota

ND

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

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the L...

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the Licensing Administrator will run a monthly report to assure unannounced visits are being completed by the Licensing Specialists. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: Completed January 2023

View Audit 36677

Finding 32257 (2022-012)

Significant Deficiency 2022

State of North Dakota

ND

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

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple sprea...

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple spreadsheets. The system allows each licensing specialist to see their workflow when they log into the system. It also notifies when a reinspection is needed and will escalate the notice if the reinspection is not done timely. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: The data system launched in December 2022.

View Audit 36677

Finding 32237 (2022-003)

Significant Deficiency 2022

Heal the Hero Foundation

AZ

Internal Control / Segregation of Duties Cash Management Significant Deficiency § 200.303

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization implement policies and procedures surrounding the cash disbursement process that ensures disbursements to the chief executive officer are reviewed and approved by a se...

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization implement policies and procedures surrounding the cash disbursement process that ensures disbursements to the chief executive officer are reviewed and approved by a second, independent individual such as a board member. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement policies and procedures surrounding cash disbursement process ensuring disbursements to the chief executive officer are reviewed and approved by a second, independent individual such as a board member. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

View Audit 34813

Finding 32194 (2022-002)

None 2022

Universal Technology College of Puerto Rico, INC

PR

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

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria Accordi...

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

View Audit 30794

Finding 32145 (2022-002)

Significant Deficiency 2022

College of Mount Saint Vincent

NY

Student Financial Aid Special Tests & Provisions Eligibility

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updat...

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updated the students' records on the NSC and will monitor the NSLDS portal weekly to ensure that all student updates are processed and correct on both the campus and program levels. In regard to the publication of the length of the Master?s level program, the College is revising its documentation and publication of the length of the Master?s program to reflect adjustments to the program that reduced the amount of time needed to complete the program. In addition, the College?s student information system was reviewed/updated to accurately reflect the published length for each program. To assure that the information is being transmitted correctly, the College will monitor the next six months of enrollment updates to ensure that each student, in the different programs, has the correct publication program length.

View Audit 31463

Finding 32144 (2022-001)

Significant Deficiency 2022

College of Mount Saint Vincent

NY

Student Financial Aid Reporting Significant Deficiency

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for mo...

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for more timely drawdowns of federal funds. Those measures were and continue to be to extract and submit reporting to COD on a minimum weekly basis (with a goal of daily) to remain within the 15-day reporting requirement. Between the 2021-2022 aid years, the College?s Financial Aid department has experienced the leadership transition of three directors, and our current Director is identifying and implementing process refinements to previous steps taken to further improve internal controls. Further, the College has taken steps to both continue and enhance ongoing staff professional development sessions and training. In addition, the College contracted a Financial Aid consultant in the Fall of 2022 for an assessment of our system configurations and processes. The consultant has been retained to undertake a quarterly review of our setups and processes and assist in training the team. In accordance with best practices, Financial Aid?s goal is to continue to eliminate such errors. The findings continue to be addressed.

View Audit 31463

Finding 32088 (2022-004)

Significant Deficiency 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

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

Finding Reference: 2022-004 Federal Agency: Department of Treasury Compliance Requirement: Activities Allowed, Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: ...

Finding Reference: 2022-004 Federal Agency: Department of Treasury Compliance Requirement: Activities Allowed, Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAPI Charles County Condition/Context: SMTCCAC was unable to provide documentation to support review and approval for one (1) of the 40 transactions selected for testing. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: SMTCCAC was unable to locate the Expenditure Request Form that demonstrates the approval of an invoice. Effect: The risk of unallowed costs increases due to lack of supervisor review and approval of expenditures charged to the program. Questioned Costs: None Recommendation: We recommend that SMTCCAC maintain the documentation of review and approval of expenditures charged to the federal award programs. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240

Finding 32087 (2022-003)

Significant Deficiency 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding Reference: 2022-003 Federal Agency: Department of Treasury Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistanc...

Finding Reference: 2022-003 Federal Agency: Department of Treasury Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAPI Charles County Condition/Context: SMTCCAC did not provide proof of review of the shared document among participating ERAP agencies in Charles County to avoid duplication of benefits for four (4) of the 60 rental assistance claims selected for testing. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: SMTCCAC did not adequately monitor controls to ensure proper review of the shared document among participating ERAP agencies in Charles County resulting in the potential duplication of benefits. Effect: Failure to review the shared document used among participating ERAP agencies in Charles County could result in duplication of benefits. Questioned Costs: None Recommendation: We recommend that SMTCCAC consistently verify the shared document used among participating ERAP agencies in Charles County to avoid duplication of benefits. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240

Corrective Action Plans

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