Corrective Action Plans

Finding 370602 (2021-015)

Material Weakness 2021

KS

Material Weakness Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2021-015 Commingling CRF and ARP Funds Individual(s) Responsible: Grace Ross, Tribal Treasurer, Accounting Director Action: Ensure that funds are separated so that federal funds are spent appropriately. Anticipated Completion Date: Ongoing

View Audit 292271

Finding 370595 (2021-008)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

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

Finding 2021-008 Matching, Level of Effort and Earmarking Individual(s) Responsible: Grace Ross, Tribal Treasurer, Department Director Action: Make sure all reporting requirements are met. Anticipated Completion Date: January 2022

View Audit 292271

Finding 370584 (2021-011)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Allowable Costs / Cost Principles Material Weakness Significant Deficiency

Finding 2021-011 Allowable Costs and Activities Individual(s) Responsible: Grace Ross, Tribal Treasurer, Accounting Director Action: Current Tribal Council will ensure that all documentation is maintained as backup for all purchases and payroll items. Anticipated Completion Date: September 2023

View Audit 292271

Finding 370512 (2021-004)

Material Weakness 2021

Elmore County Commission

AL

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303

The County also produced reimbursement requests well in excess of not only the subject amount referenced above, but also well over the state allocated CARES Act funds the County was eligible to receive in reimbursement. Regardless, the County will increase efforts to provide internal review of these...

The County also produced reimbursement requests well in excess of not only the subject amount referenced above, but also well over the state allocated CARES Act funds the County was eligible to receive in reimbursement. Regardless, the County will increase efforts to provide internal review of these type items to ensure clarity of reimbursement s and/or costs moving forward on state and federally funded projects.

View Audit 292133 Questioned Costs: $1

Finding 370054 (2021-009)

Material Weakness 2021

Delaware County

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.403

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

View Audit 291562 Questioned Costs: $1

Finding 370053 (2021-008)

Material Weakness 2021

Delaware County

OK

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

The Board of County Commissioners will work with all Count Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

View Audit 291562

Finding 369845 (2021-010)

Material Weakness 2021

Trinity Community Housing CORP

IL

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for ...

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291369 Questioned Costs: $1

Finding 369844 (2021-009)

Material Weakness 2021

Trinity Community Housing CORP

IL

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that insurance policies are available for examination purposes to determine that the Project has the proper insurance coverage. Responsible party: Ken Dickerson, Chairman Planned completion date fo...

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that insurance policies are available for examination purposes to determine that the Project has the proper insurance coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291369 Questioned Costs: $1

Finding 369842 (2021-007)

Material Weakness 2021

Trinity Community Housing CORP

IL

HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that insurance policies are available for examination purposes to determine that the Project has the proper insurance coverage. Responsible party: Ken Dickerson, Chairman Planned completion date fo...

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that insurance policies are available for examination purposes to determine that the Project has the proper insurance coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291369

Finding 369824 (2021-011)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291368 Questioned Costs: $1

Finding 369823 (2021-010)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for ...

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291368 Questioned Costs: $1

Finding 369821 (2021-008)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

HUD Housing Programs Matching / Level of Effort / Earmarking

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for ...

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that fidelity bond is available for examination purposes to determine that the Project has the proper fidelity bond coverage. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291368

Finding 369744 (2021-008)

Material Weakness 2021

New Vision Foundation

MN

Matching / Level of Effort / Earmarking Cash Management Material Weakness § 200.303

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization retain clear documentation of meal count sheets, including labeling of the particular month they relate to. We also recommend the Organization reconcile the meal count sheets with the...

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization retain clear documentation of meal count sheets, including labeling of the particular month they relate to. We also recommend the Organization reconcile the meal count sheets with the clicker reports, and retain specific documentation as to the variances. Explanation of disagreement with audit finding The Child and Adult Care Food Program was created as an emergency response during the COVID-19 pandemic. In such an emergent situation, management believes the federal government acted in good faith to meet the needs of the country by contracting with regional sponsoring organizations. New Vision Foundation was selected by the sponsoring organization to be a community-based food provider to culturally-specific populations. All activities related to the program were expressly approved by the sponsoring organization. The finding of material noncompliance is overstated. Management followed all guidelines and fulfilled all obligations outlined by Feeding Our Future. Documentation of meal count sheets and clicker reports were accepted and approved by the sponsoring organization. Additional documentation was not requested nor were any changes to management’s practices. Action taken in response to finding The program noted was discontinued at the end of 2021. If the Organization enters into any other federal funding, we will consult with experts on compliance requirements from the start of the grant. Name of the contact person responsible for corrective action Hussein Farah, Executive Director Planned completion date for corrective action plan N/A

View Audit 291230

Finding 369742 (2021-006)

Material Weakness 2021

New Vision Foundation

MN

Questioned Costs Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.303

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization attend training, review federal requirements, and fully understand the documentation and meal requirements of the program if they apply for funding with this program again. Explanatio...

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization attend training, review federal requirements, and fully understand the documentation and meal requirements of the program if they apply for funding with this program again. Explanation of disagreement with audit finding The Child and Adult Care Food Program was created as an emergency response during the COVID-19 pandemic. In such an emergent situation, management believes the federal government acted in good faith to meet the needs of the country by contracting with regional sponsoring organizations. New Vision Foundation was selected by the sponsoring organization to be a community-based food provider to culturally-specific populations. All activities related to the program were expressly approved by the sponsoring organization. The auditor was provided meal logs, invoices and documents signed by program participants as evidence of meals delivered. However, this documentation was not accepted by the auditor even though it had been approved by the sponsor organization. The auditor requested delivery driver schedules and/or volunteer assignments for specific deliveries which were not available since the sponsor organization never requested such documents be kept. The finding of material noncompliance is overstated. Management followed all guidelines and fulfilled all obligations outlined by Feeding Our Future. Action taken in response to finding The program noted was discontinued at the end of 2021. If the Organization enters into any other federal funding, we will consult with experts on compliance requirements from the start of the grant. Name of the contact person responsible for corrective action Hussein Farah, Executive Director Planned completion date for corrective action plan N/A

View Audit 291230 Questioned Costs: $1

Finding 369487 (2021-004)

Significant Deficiency 2021

Ka Mana O Na Helu

HI

Procurement, Suspension & Debarment Reporting Matching / Level of Effort / Earmarking § 200.512 § 200.514

View of Responsible Officials and Planned Corretive Action Responsible Party: Executive Director The single audit requirement was new to KMNH as a result of ESG CV funding. KMNH completed the procurement process as required by HUD, but did not receive any response from qualified service providers de...

View of Responsible Officials and Planned Corretive Action Responsible Party: Executive Director The single audit requirement was new to KMNH as a result of ESG CV funding. KMNH completed the procurement process as required by HUD, but did not receive any response from qualified service providers despite proactive outreach on our part. We were informed that many of the audit firms were overwhelmed by the need to complete audits due to the increased level of federal funding due to COVID. KMNH has since been able to secure an audit firm to complete the audit after the stipulated due date. The same audit firm has been engaged to complete our audit for year ended December 31, 2022. The benefit to using the same audit firm is that their understanding of KMNH’s financial reporting and grant compliance processes learned during the 2021 audit should contribute to an expeditious 2022 audit. KMNH will work diligently with the audit firm with the goal of completing the audit as soon as possible.

View Audit 290718

Finding 369484 (2021-003)

Significant Deficiency 2021

Ka Mana O Na Helu

HI

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

Views of Responsible Officials and Corrective Action - Responsible Party: Director of Operations - KMNH has updated our draft policies and procedures to incorporate §200.318 through §200.327 of the Uniform Guidance procurement standards to ensure compliance with Federal standards. The policies and ...

Views of Responsible Officials and Corrective Action - Responsible Party: Director of Operations - KMNH has updated our draft policies and procedures to incorporate §200.318 through §200.327 of the Uniform Guidance procurement standards to ensure compliance with Federal standards. The policies and procedures will be sent for approval from the KMNH BOD during the next BOD meeting scheduled for April 26, 2024. ESG CV contractors selected were not impacted by the lack on inclusion of the procurement standards in our policies and procedures as KMNH was not responsible for the selection and/or procurement.

View Audit 290718

Finding 369391 (2021-003)

Material Weakness 2021

So Consortium

OH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.414 § 200.502 § 200.510

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track ...

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

View Audit 290596

Finding 369290 (2021-025)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an auto...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an automated solution to gather information and documentation required for Financial Aid Verification. Inceptia uses innovative technology to apply progressive rules for automatically or manually approving verification. Furthermore, it provides efficient and effective processes to help institutions remain compliant by organizing documents, streamlining award packaging, and allowing staff to manage the verification process. It provides the institution with the internal controls it needs over its Title IV funding. The Financial Aid Staff also can manually verify students if needed. With Colleague and Inceptia, SAU now has a more unified operating system for systematic processes. If a student has been flagged for verification, Colleague will not allow staff to award the student financial aid. One of the award eligibility rules is "Verification Complete." If students fail to pass this rule, they will not be awarded financial aid. Colleague gives the Financial Aid Staff greater control over the disbursal of Title IV funds and prevents the FAO from disbursing aid to students who are ineligible to receive it. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369288 (2021-023)

Material Weakness 2021

Saint Augustine's University

NC

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

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2022 going forward. The built in internal control will readily provide data on th...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2022 going forward. The built in internal control will readily provide data on those students who are eligible for aid and notify them of their opportunity to accept or decline aid. In addition, the notification documents will be stored in the ERP system and be available to retrieve. Within 15 days after disbursements students and parents are sent an email notifying them their loan has been disbursed to their account. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369287 (2021-022)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and ...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and business offices are directly involved with the COD processes weekly. This process sends originations and disbursement information for PELL and Federal loans to COD. Funds are transmitted to a student’s account through a two-part process called FATR between the two offices. With the implementation of Colleague, we have resolved those issues. Colleague's Financial Aid module provides the tools necessary to maintain, track, process, and report information associated with financial aid applicants and recipients to Colleague. The Financial Aid module helps manage the processing of financial aid, data, and reporting and will give SAU internal controls over their Title IV Student Financial Aid programs. Using this system, SAU can create and modify Grant records for submission to COD and import and reconcile Grant data. The financial aid office did not have these options in CAMS. The financial aid office no longer builds and or disburses aid manually in COD. Colleague and COD work together. The reconciliation process for Pell and Direct Loans to self-audit, ensuring the accuracy and validity of financial data sent and submitted to COD. The reconciliation process in completed monthly and any discrepancies are resolved prior to the next month. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369285 (2021-020)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Reporting

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolve...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolved. Utilizing Colleague's software, the financial aid office can now accurately assess our students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Criteria (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds. Items this rule checks for include half-time enrollment, completion of Entrance Interview, Satisfactory Academic Progress, etc. AEC is primarily used as a criterion a student must pass before aid can be transmitted to Accounts Receivable. There are two sets of rules on the AEC form: Eligibility Criteria for Awarding and Eligibility Criteria for Transmitting. These rules monitor students' aggregate loan limits, SAP, as defined by Uniform Guidance rules and requirements for federal awards, and provide SAU with the internal controls needed for their Title IV program. The Financial Aid Director follows Ellucian Colleague’s best practice recommendations. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369278 (2021-024)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Subrecipient Monitoring Cash Management

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run throug...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run through Colleague's CODE (Common Originators Disbursement Ellucian) system, which is used to send origination requests and disbursement information for Pell and Federal loans to COD. Funds are transmitted to a student's account through a two-part process run between the Financial Aid Office (FAO) and the Business Office. The Finanical Aid Office is responsible for sending loan originations and disbursments to COD within 15 days. The data extraction process will be more consistent using the workflows provided by the new ERP system. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369276 (2021-019)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was ...

Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was without a Registrar during the 2019-2020 award year however, in August 2020 this position was filled. In addition more staff was hired to assist in these reporting functions. The Registrar had to submit the missing reports before submitting new ones. This backlog led to late status changes being reported. Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Accounts will prevent this from recurring. Professional development is encouraged for the University’s staff to stay current on compliance, regulatory and legal guidelines and adopt industry best practices. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369247 (2021-021)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid ...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid while informing other institutions of those changes through the National Student Loan Data System (NSLDS). This issue has been resolved with the implementation of Colleague. The Financial Aid Director can now perform transfer monitoring in Colleague to track transfer students and any changes to their financial aid while informing other institutions of those changes. Colleague sends information files to the National Student Loan Data System (NSLDS), which notifies NSLDS of our transfer students and serves as a request to put SAU's transfer students on the NSLDS maintained Transfer Monitoring list. The inform file is also a request for a Financial Aid History file for each student listed. With Colleague, we can determine which students to monitor, send the information to NSLDS, transfer the files, and view students' NSLDS information as necessary. The Financial Aid Director runs transfer monitoring at the beginning of the semester for everyone enrolled and then runs TMXP, which creates a file to monitor those who are newly awarded, Students are run through the process in December for new transfer student can be monitored. With Colleague, the Financial Aid Director/Staff can easily adhere to the "Inform, Monitor, Alert" process since this system can efficiently and effectively run this process. Prior to awarding a transfer for spring the Financial Aid Staff as alternative option review NSLDS and manually add a student to the transfer monitoring file. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369244 (2021-015)

Material Weakness 2021

Saint Augustine's University

NC

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: University administration recognizes the significant role of internal controls throughout the institution including fiscal, administrative and programmatic operations. ...

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: University administration recognizes the significant role of internal controls throughout the institution including fiscal, administrative and programmatic operations. The university’s internal control objectives and related risks can be broadly classified into one or more of the following three categories: • Operations - Effectiveness and efficiency of operations • Reporting - Reliability of reporting for internal and external use • Compliance - Compliance with applicable laws and regulations Based on the institutions internal control objective’s, the Office of Sponsored Program has prepared its internal control plan in a framework which addresses the five components and 17 principles of internal controls as outlined in GAO’s Standard for Internal Controls. Additionally, retention policies have been put in place to ensure all drawdowns are supported by allowable expenditures and the records are maintained in accordance with the standards of the granting agencies. The grants accountant in coordination with the office of sponsored programs manages external grant awards through the creation of internal spending accounts, performs quarterly monitoring of financial activity in Colleague Finance (or more frequently when dictated by reporting requirements), obtains grant payments from sponsors, and creates and submits its financial reports. The Office of Sponsored Programs has updated the External Award Policy and Procedures Manual which outlines the process for conducting reconciliations of grants for reporting and yearend processes. Updated policy and procedures manuals, Internal control policies and retention control policies as it relates to sponsored programs have been established to ensure the reliability and integrity of financial information. The Institutions internal control policy will ensure that management has accurate, timely, and complete information, including accounting records, in order to plan, monitor and report grant awards accurately. Anticipated Completion Date: June 30, 2024

View Audit 290538

Corrective Action Plans

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