Corrective Action Plans

Finding 528139 (2024-001)

Material Weakness 2024

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary porti...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary portion of the Title I application, which is how Title I funding is determined. It is recommended that the school corporation’s management strengthen its system of internal controls to ensure that data in the Eligible School Summary section of the Title I application has been verified for accuracy to the corresponding period’s Pupil Enrollment (PE) report data. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Real time reporting will be compiled by the Data Management Specialist (currently Stephanie Jackson) and will be reviewed by the Title I Grant Coordinator (currently Dr. Brady Scott). Annual Financial reports will be compiled by the Director of Business Affairs (currently John Szabo), and prior to submission those reports will be reviewed by the Title I Grant Coordinator. Anticipated Completion Date: July 2025

View Audit 346210

Finding 528108 (2024-001)

None 2024

Catholic Community Services of the Mid-Willamette Valley, INC

OR

Matching / Level of Effort / Earmarking

The Organization has created a tracking system that identifies when the last inspection was completed and when the next inspection should be due based on the number of units at each complex. NOTE: Inspections are not due until June through October of 2027 for complexes under the jurisdiction of the ...

The Organization has created a tracking system that identifies when the last inspection was completed and when the next inspection should be due based on the number of units at each complex. NOTE: Inspections are not due until June through October of 2027 for complexes under the jurisdiction of the City of Salem.

View Audit 346180

Finding 527060 (2024-002)

None 2024

Case Western Reserve University

OH

Student Financial Aid Matching / Level of Effort / Earmarking

The University acknowledges that the template used for the disbursement notification previously did not explicitly state the deadline for cancellation. The template has been revised as of November 2024 to include a separate section clearly outlining both the procedure and deadline for canceling Titl...

The University acknowledges that the template used for the disbursement notification previously did not explicitly state the deadline for cancellation. The template has been revised as of November 2024 to include a separate section clearly outlining both the procedure and deadline for canceling Title IV funding. This revised template is already being used for disbursement notifications. Primary responsibility for implementing the correction action plan for this finding rests with Mike Collins, Director of University Financial Aid, 216-368-6579.

View Audit 346174

Finding 527058 (2024-001)

None 2024

Case Western Reserve University

OH

Student Financial Aid Eligibility Reporting

The University acknowledges and agrees with this audit finding. During the months of August and September 2024 (concurrent with PwC’s audit fieldwork), enrollment data was reviewed by the Office of the University Registrar in preparation for the Completers List reporting related to Gainful Employmen...

The University acknowledges and agrees with this audit finding. During the months of August and September 2024 (concurrent with PwC’s audit fieldwork), enrollment data was reviewed by the Office of the University Registrar in preparation for the Completers List reporting related to Gainful Employment/Financial Value Transparency requirements. During the Completers List reconciliation process, it was determined by the Office of the University Registrar that all August 2024 graduates needed to have their status dates updated. Those updates took place in early October 2024. The Office of the University Registrar will run a query shortly after each conferral date to compare all graduates using all three program-level match criteria (credential level, CIP, program length) at the time of graduation to data submitted to NSC during the last enrollment file. The Office of the University's Registrar will also compare degree data sent to NSC against the student information system degree awarded data. The Office of the University's Registrar will continue to ensure that all error reports are resolved in a timely manner according to NSC and NSLDS timing guidelines. These processes were initiated for December 2024 graduates. The Office of the University Registrar will complete these comparison processes within 30 days of each degree conferral date and will take immediate action to directly update NSC and NSLDS if any discrepancies are found. Primary responsibility for implementing the corrective action plan for this finding rests with Amy Hammett, University Registrar and Associate Vice Provost for Student Information Systems, 216-368-4310

View Audit 346174

Finding 526997 (2024-001)

Significant Deficiency 2024

Positively Third Street Housing Development Fun Co., Inc.

NY

HUD Housing Programs Student Financial Aid Cash Management

Project Legal Name: Positively Third Street HDFC HUD Project No.: 012-EE287 Audit Firm: CohnReznick LLLP Period covered by the audit: July 1, 2023 through June 30, 2024 Corrective Action Plan prepared by: Name: Matthew LoCurto Position: CFO Telephone Number: 212-453-5257 The following is a recommend...

Project Legal Name: Positively Third Street HDFC HUD Project No.: 012-EE287 Audit Firm: CohnReznick LLLP Period covered by the audit: July 1, 2023 through June 30, 2024 Corrective Action Plan prepared by: Name: Matthew LoCurto Position: CFO Telephone Number: 212-453-5257 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-1 a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation put forth by the auditors Action(s) Taken or Planned The $93,461 of residual receipts noted in the 2023 audit and cited as a finding in the 2024 report was deposited into the residual receipt account on January 10, 2025. Our new Controller has established procedures to ensure that that the proceeds stemming from the retroactive budget based rent increase are used for their intended purpose prior to the end of the fiscal year that they are received. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations N/A

View Audit 346099

Finding 526979 (2024-005)

Material Weakness 2024

School City of Mishawaka

IN

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

FINDING 2024-005 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The steps were put in place to correct this finding in January 2023. Since then any exp...

FINDING 2024-005 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The steps were put in place to correct this finding in January 2023. Since then any expenditures of federal funding which included payments to contractors with payroll, certified payrolls have been required before payment is issued. Along with that their contracts have included language that fulfill the Davis-Bacon wage requirements. Anticipated Completion Date: The process was amended to meet these requirements in January 2023.

View Audit 346062

Finding 526973 (2024-003)

Material Weakness 2024

School City of Mishawaka

IN

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

FINDING 2024-003 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Exceptional Learner Departmental staff going forward will work with the Payroll dep...

FINDING 2024-003 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Exceptional Learner Departmental staff going forward will work with the Payroll department to account for all individuals that are to be paid from Federally Funded Grants and other funding sources. From these lists of employees, the EL Departmental staff will designate the individuals working public and non-public students. Time and Effort records will be kept for all employees along with documents listing the impacted employees. These lists will then be reviewed during the certification process by the person creating the listing with Payroll personnel, the Exceptional Learner Director and the Director of Business Services to ensure that all employees are accounted for. Anticipated Completion Date: This new process will begin with the next semi-certification process.

View Audit 346062

Finding 526969 (2024-002)

Significant Deficiency 2024

School City of Mishawaka

IN

School Nutrition Programs Eligibility Significant Deficiency § 200.303

FINDING 2024-002 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Food Service Director will print out the Direct Certification report and ...

FINDING 2024-002 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Food Service Director will print out the Direct Certification report and review for its accuracy. She will then provide the report to the Food Service Director for her review. After both individuals have reviewed the reports that were produced, they both will sign and date the reports to provide the documentation that the information was reviewed and verified. Anticipated Completion Date: This new process will begin at month end of February 2025.

View Audit 346062

Finding 526946 (2024-002)

Material Weakness 2024

Community School Corporation of Southern Hancock County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Sarah Gizzi, Business Manager Contact Phone Number and Email Address: (317) 861-4463 x1014, sgizzi@newpal.k12.in.us Condition and Context: An effective internal con...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Sarah Gizzi, Business Manager Contact Phone Number and Email Address: (317) 861-4463 x1014, sgizzi@newpal.k12.in.us Condition and Context: An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements: Reporting The School Corporation had not designed, nor implemented, a system of internal controls to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were prepared by the Deputy Treasurer and the Grant Administrator, then reviewed and approved by the Business Manager; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors was performed during the audit period. This resulted in errors on the ESSER I Year 3 from the original submission in April 2023 not being detected and corrected until July 2024. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The federal award reporting procedures and internal controls of New Palestine Community Schools have been improved to ensure all reporting documents will have a multistep review process to include a reviewer separate from the preparer. The reports will also have multiple signers documenting proper review of the information being reported, ensuring accuracy and compliance. Anticipated Completion Date: These procedures have been implemented effective immediately, March 3, 2025, and will be reflected on all future reports.

View Audit 346044

Finding 526903 (2024-002)

Material Weakness 2024

Clark-Pleasant Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.303

FINDING 2024-002 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions Summary of Finding: Three employees did not have a signed agreement on file to indicate required training was received over Special Tests and Provisions compliance requirement, Assessment Sy...

FINDING 2024-002 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions Summary of Finding: Three employees did not have a signed agreement on file to indicate required training was received over Special Tests and Provisions compliance requirement, Assessment System Security. Contact Person Responsible for Corrective Action: Brian Lovell Contact Phone Number and Email Address: 317-535-7579; blovell@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The corporation test coordinator will work with our Director of Operations to review these expectations and test security for all appropriate staff. Anticipated Completion Date: March 14, 2025

View Audit 346022

Finding 526901 (2024-003)

Material Weakness 2024

Clark-Pleasant Community School Corporation

IN

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

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Resp...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number and Email Address: 317-535-7579; afruits@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We have formulated a plan to include the business office in Non-pub meetings moving forward so that open funds are being clearly communicated with the Non-public schools. If the funds are not spent, we will apply for the waiver to move the budget to the corporation. Anticipated Completion Date: March 1, 2025

View Audit 346022

Finding 526895 (2024-003)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection repor...

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection reports were completely and accurately submitted. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number and Email Address: 812-866-6244 (o), 812-599-0627 (c), jwatson@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-003 includes, but is not limited to, the following: 􀁸 Beginning immediately, the grant coordinator will prepare the reports for any future ESSER reports. 􀁸 The reports prepared will be shared with Assistant Treasurer 1 for the initial review. Assistant Treasurer 1 will complete his/her review, adding comments and suggestions as needed. 􀁸 If corrections to the report are required: o Assistant Treasurer 1 and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with the grant coordinator. o The Grant Coordinator will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer reviews have been completed and indicates as such via eSignatures. 􀁸 Anticipated Completion Date: March 1, 2025􀀃

View Audit 345996

Finding 526891 (2024-002)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

School Nutrition Programs Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the S...

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the Special Tests and Provisions-Non-Profit School Food Service Accounts compliance requirement. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Katie King, Food Services Director Contact Phone Number and Email Address: 812-866-6254, kking@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-002 includes, but is not limited to, the following: 􀁸 Beginning immediately, Assistant Treasurer 1 will prepare a DocuSign envelope monthly with the following financial reports to be reviewed: o Appropriation Report o Expenditure Report o Revenue Report o Fund Detail Report o Fund Report 􀁸 The DocuSign Envelope will be routed to the Food Services Director, for the initial review. 􀁸 The Food Service Director will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 The DocuSign Envelope will then be routed to Assistant Treasurer 2 for an additional review. 􀁸 Assistant Treasurer 2 will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 If corrections to the report are required: o The Food Service Director and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with Assistant Treasurer 1. o Assistant Treasurer 1 will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer 2 reviews have been completed and indicates as such via eSignatures. 􀁸 After the above steps have been taken, the report will be submitted 􀁸 The Grant Coordinator indicates its completion by eSignature in the appropriate location. INDIANA STATE BOARD OF ACCOUNTS 33 􀀃 􀀃 Anticipated Completion Date: March 1, 2025

View Audit 345996

Finding 526882 (2024-001)

Significant Deficiency 2024

Westfield State University

MA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Corrective Action Plan: The Registrar’s Office will conduct a comprehensive review of the scheduled enrollment reporting dates currently listed in the National Student Clearinghouse (NSC). This review will focus specifically on calculating a fifty-day schedule of enrollment reporting to ensure enrol...

Corrective Action Plan: The Registrar’s Office will conduct a comprehensive review of the scheduled enrollment reporting dates currently listed in the National Student Clearinghouse (NSC). This review will focus specifically on calculating a fifty-day schedule of enrollment reporting to ensure enrollment reports are submitted within the required time frame as mandated by the National Student Loan Data System (NSLDS). The reporting date adjustment will allow additional days for NSC to report to NSLDS within the required sixty-day reporting period to maintain compliance. NSC emails a “Delivery Receipt” each time an enrollment report is submitted to the Registrar, Associate Registrar and Technology Support Specialist in the Registrar’s Office. The Executive Director of Institutional Research and Assessment will be added to the email notification and will have access to review enrollment report submissions. The Registrar will also be creating a calendar with a schedule of when the NSLDS enrollment files will be sent to help ensure the files are submitted on-time. Timeline for Implementation of Corrective Action Plan: The review of scheduled enrollment dates will begin immediately. Adjustments to the dates will be made as needed to ensure adherence to the sixtyday reporting requirement. Contact Person: Monique Lopez, Registrar and Simone Backstedt, Director, Financial Aid

View Audit 345977

Finding 526875 (2024-001)

Significant Deficiency 2024

Sweet Briar Institute

VA

Student Financial Aid Special Tests & Provisions Reporting

Individual/s Responsible for Corrective Action Plan: Susan Kennon, Registrar Corrective Action Plan: The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took severa...

Individual/s Responsible for Corrective Action Plan: Susan Kennon, Registrar Corrective Action Plan: The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes: • Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades. o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access. • Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records. • Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors. • Consistent reporting per the NSC transmission schedule so data is reported correctly and timely. • Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure. • The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester. • Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity. Anticipated Completion Date: Several training sessions have been completed by the Registrar since February 2024. Additional training on reporting was completed on March 4, 2025, and another training is scheduled for late March 2025. The assistant registrar has been trained on how to generate a report and resolve issues to allow for continuity in reporting. A recent review of processes (February 2025) helped us discover that there was a coding issue that was incorrectly reporting graduated students as withdrawn in subsequent reports. At least one student in this audit had this finding. Training and review of records is ongoing.

View Audit 345973

Finding 526872 (2024-002)

Material Weakness 2024

South Montgomery Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.303

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kristin Charles, CFO and HR Director Contact Phone Number and Email Address: (765) 866-0203 and Kristin.charles@southmont.k12.in.us Views of Responsible Officials: We...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kristin Charles, CFO and HR Director Contact Phone Number and Email Address: (765) 866-0203 and Kristin.charles@southmont.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: ESSER Yearly Reports to be completed by CFO and printed and will review with the superintendent. Anticipated Completion Date: ESSER III Annual Report due April 2025

View Audit 345971

Finding 526869 (2024-002)

Significant Deficiency 2024

National Museum of Women in the Arts

DC

Subrecipient Monitoring Reporting Significant Deficiency § 200.328

Views of Responsible Officials: The delay in submitting the report was primarily due to oversight. To ensure that similar delays do not occur in the future, we are implementing the following measures: 1. Improved Project Management: We will review our internal processes and set clearer timelines for...

Views of Responsible Officials: The delay in submitting the report was primarily due to oversight. To ensure that similar delays do not occur in the future, we are implementing the following measures: 1. Improved Project Management: We will review our internal processes and set clearer timelines for report preparation. We will assign specific personnel responsible for ensuring that all required reports are submitted on time. 2. Enhanced Communication: We will improve communication with all departments involved in the report preparation process to ensure that necessary information is gathered and validated promptly. 3. Monitoring Progress: We will establish a more robust internal monitoring process to track the progress of report preparation and ensure timely submission.

View Audit 345969

Finding 526865 (2024-001)

Significant Deficiency 2024

Bentley University

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

The finding has been remediated concerning status changes during required academic periods as of June 30, 2024. The University has improved staff access for enrollment reporting to the National Student Clearinghouse (NSC) to meet the compliance requirements of NSLDS for status changes reported durin...

The finding has been remediated concerning status changes during required academic periods as of June 30, 2024. The University has improved staff access for enrollment reporting to the National Student Clearinghouse (NSC) to meet the compliance requirements of NSLDS for status changes reported during the semester the student is enrolled. The University continues to adjust reporting timelines to ensure accurate and timely reporting of status changes to NSLDS for status changes reported outside of required academic periods in which the student is enrolled.

View Audit 345963

Finding 526863 (2024-002)

Significant Deficiency 2024

King's College

PA

Student Financial Aid Reporting Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its polic...

Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting. Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.

View Audit 345962

Finding 526862 (2024-001)

Significant Deficiency 2024

King's College

PA

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.303

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed awa...

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed away. This happened due to human error. We have a process in place to monitor corrected ISIR transactions to ensure that the EFC (SAI effective for award year 2024-25 and later) agrees with our documentation. The student record is then given to the director for final review and repackaging. We have added an additional step now whereby the Pell Grant administrator also reviews the output report for ISIR imports on a weekly basis.

View Audit 345962 Questioned Costs: $1

Finding 526847 (2024-003)

Material Weakness 2024

North Central Behavioral Health Systems, Inc.

IL

Cash Management Matching / Level of Effort / Earmarking § 200.303

Identifying Number: 2024-003 Finding: NCBHS management stated that cash reimbursement requests were reviewed prior to submission to the grantor, but there was no verifiable evidence that reviews took place until March 2024. Internal controls over Federal awards that are not properly designed increas...

Identifying Number: 2024-003 Finding: NCBHS management stated that cash reimbursement requests were reviewed prior to submission to the grantor, but there was no verifiable evidence that reviews took place until March 2024. Internal controls over Federal awards that are not properly designed increases the risk of noncompliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement. Corrective Actions Taken or Planned: This issue is related to the previous year finding 2023-003. The monthly reimbursement requests were not being reviewed by the CEO or CFO before being sent to the State of Illinois. This process changed in March 2024 when it was brought to our attention by RSM. Since that time all reimbursement requests for both State of Illinois and federal grants are reviewed and approved by the CEO or CFO before they are sent to the appropriate parties for payment. In addition, NCBHS will review the “Compliance Supplement” issued by the Office of Management and Budget to help in the guidance of the requirements for the single audit.

View Audit 345941

Finding 526832 (2024-008)

Material Weakness 2024

New Prairie United School Corporation

IN

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

FINDING 2024‐008 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Wage Rate Requirements Summary of Finding: 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 ...

FINDING 2024‐008 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Wage Rate Requirements Summary of Finding: 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 requirement. The School Corporation did not ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract was paid from the COVID‐19 ‐ Education Stabilization Fund grant funds, totaling $1,278,001, during the audit period. This construction contract was subject to the wage rate requirements; however, the contract did not have the required prevailing wage rate clause included in the contract, nor were certified payrolls submitted by the contractor timely. Contact Person Responsible for Corrective Action: Jackie Conley Contact Phone Number and Email Address: 574‐654‐7273 jaclynconley@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Grants Manager will ensure future projects with construction contracts will have a prevailing wage clause while also monitoring payroll to verify compliance. Anticipated Completion Date: March 2025

View Audit 345909

Finding 526827 (2024-007)

Material Weakness 2024

New Prairie United School Corporation

IN

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024‐007 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School...

FINDING 2024‐007 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports, for a total of five reports. The School Corporation did not have a documented review of any of the annual reports submitted to the Indiana Department of Education. Contact Person Responsible for Corrective Action: Jackie Conley Contact Phone Number and Email Address: 574‐654‐7273 jaclynconley@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Future reporting will be prepared by the Grants Manager but reviewed by the Corporation Treasurer or Curriculum Director before submission. Anticipated Completion Date: March 2025

View Audit 345909

Finding 526817 (2024-004)

Significant Deficiency 2024

New Prairie United School Corporation

IN

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

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the gr...

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the grant awards until March 2023, total grant expenditures were posted as expended. The non‐public proportionate share expenditures were determined by applying a percentage to the non‐public school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the non‐public services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to IDOE from the beginning of the grant awards through March 2023, as required. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services instead of applying a percentage. The minimum amount per the grant award will be expended and properly report to the IDOE. New Prairie also plans on requesting biannual reports from the Cooperative on expenditures for nonpublic services. Anticipated Completion Date: March 2023

View Audit 345909

Finding 526815 (2024-001)

None 2024

Midway University, Inc.

KY

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

Management acknowledges this finding and will change the procedure to verify enrollment status changes to ensure that there are no issues of files not transferring from the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). Currently, the Financial Aid Director co...

Management acknowledges this finding and will change the procedure to verify enrollment status changes to ensure that there are no issues of files not transferring from the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). Currently, the Financial Aid Director confirms status changes in NSLDS at day 50, and as part of the process change a second status check will occur with a separate Financial Aid staff member before the 60 day timeframe has passed to ensure that no students were missed in the file transfer or that status changes occurred after the initial check. This plan will be overseen by Erin Teves, Director of Financial Aid, and will be implemented immediately.

View Audit 345905

Corrective Action Plans

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