Corrective Action Plans

Finding 538162 (2024-001)

Material Weakness 2024

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Yea...

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion 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. Context: For the three projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the companies that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The total amount disbursed and reported on the SEFA during the audit period is $2,799,607 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Dawn Cook, Corporation Treasurer; Joel Mahaffey, Superintendent Contact Phone Number: (260) 692-6193 Description of Corrective Action Plan: When utilizing federal funding for capital projects, ACCS will require and retain evidence that contractors, subcontractors, and other relevant agents comply with the federal wage rate requirements set forth in the Davis-Bacon Act. Anticipated Completion Date: Implementation is immediately.

View Audit 349196

Finding 538161 (2024-001)

Significant Deficiency 2024

Maine Maritime Academy

ME

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Findings and Questioned Costs for Federal Awards: Finding 2024-001: Student Financial Assistance Cluster – Special Tests and Provisions – Enrollment Reporting Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Management’s Views and Corr...

Findings and Questioned Costs for Federal Awards: Finding 2024-001: Student Financial Assistance Cluster – Special Tests and Provisions – Enrollment Reporting Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Management’s Views and Corrective Action Plan Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. o In at least one case, a student was initially listed in NSLDS as “Z – No Record Found” on September 21, 2023, suggesting that NSC added the student to the Academy’s roster. The student withdrew after Fall 2023, but no enrollment update was submitted to NSLDS. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction.b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.

View Audit 349195

Finding 538159 (2024-001)

Material Weakness 2024

Mooreland Independent School District #2

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

All future construction projects exceeding a cost of $2,000.00 and funded through Federal monies will adhere to the Davis-Bacon Act requirements. Procedures have been put in place with flyers, information documents , and checklists to determine eligibility and requirements of all expenditures. The...

All future construction projects exceeding a cost of $2,000.00 and funded through Federal monies will adhere to the Davis-Bacon Act requirements. Procedures have been put in place with flyers, information documents , and checklists to determine eligibility and requirements of all expenditures. The Superintendent is in charge of ensuring compliance.

View Audit 349183

Finding 538145 (2024-002)

Significant Deficiency 2024

Coe College

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Finding: The change in student status for 1 of students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew at the end of the spring term. Explanation for Finding: The previous registrar created a corrective action plan 6 days before leaving the ...

Finding: The change in student status for 1 of students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew at the end of the spring term. Explanation for Finding: The previous registrar created a corrective action plan 6 days before leaving the college and did not pass the information to the correct parties. The previous position of Assistant Director of Academic Data & Records which was listed as in charge of the actions in the Registrar’s plan was cut from the staffing of that office causing a void of all potential personnel to handle the previous plan. Corrective Actions Taken or Planned: The Registrar will run a report on the 15th of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. The Assistant Registrar will review the work of the Registrar and verify any discrepancies between Coe’s records and those stored in the National Student Clearinghouse for correction. The Registrar will then ensure timely and accurate submission of student records from the Clearinghouse to NSLDS after all the data has been reviewed. Office of the Registrar additional staffing will be trained on this process to ensure this verification policy will be executed even when there are staffing changes in the future. Persons Responsible and Completion Date: Registrar, Assistant Registrar. The actions outlined above has been added to the Withdrawal & Exit Procedure (NSC-NSLDS) as of 10/23/2024

View Audit 349151

Finding 538135 (2024-102)

Material Weakness 2024

Navajo County

AZ

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Concur. The County is working with the contracted subrecipient for WIOA Youth Activities to expand unpaid work experience (WEX) in order to meet the earmarking requirement. This includes adjusting the 4-year plan to specifically require the provider to expand WEX activities and target the earmarking...

Concur. The County is working with the contracted subrecipient for WIOA Youth Activities to expand unpaid work experience (WEX) in order to meet the earmarking requirement. This includes adjusting the 4-year plan to specifically require the provider to expand WEX activities and target the earmarking requirement. The recommended solutions include improved tracking and monitoring of the WEX activities to include both paid and unpaid work experiences, increasing all youth outreach, partnering with other local youth programs, and enrolling youth with barriers pursuant to the policy. In order to expand unpaid work experience (WEX) as part of the four-year plan, the WIOA administration is dedicated to promoting WEX.

View Audit 349149 Questioned Costs: $1

Finding 538099 (2024-004)

Material Weakness 2024

South Dearborn Community 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 – Earmarking Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Des...

FINDING 2024-004 Finding Subject: Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

View Audit 349120

Finding 538093 (2024-002)

Material Weakness 2024

South Dearborn 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: Shawn Spindler, Business Manager Contact Phone Number and Email Address: 812.926.2090, shawn.spindler@sdcsc.k12.in.us Views of Responsible Officials: We concur with t...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager Contact Phone Number and Email Address: 812.926.2090, shawn.spindler@sdcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ESSER data collection will be completed by the Business Manager and reviewed by the Superintendent. This review will be documented either via print out and signature or via email. Anticipated Completion Date: March 2025

View Audit 349120

Finding 538091 (2024-001)

Material Weakness 2024

South Dearborn Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsibl...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will verify our enrollment from the prior year October ADM count and have it reviewed and signed off by another staff member. For the non-pubs, the Title I Director will require student rosters as well as poverty information. This information will then be reviewed and signed off on. Anticipated Completion Date: June 2025

View Audit 349120

Finding 538084 (2024-001)

Significant Deficiency 2024

Spencer-Owen Community Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thoro...

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thorough and more fully documented process should be in place and that it needs to cover the full school year and not be done just the one time towards the beginning of the year. Description of Corrective Action Plan: The􀀃Technology􀀃and􀀃Food􀀃Service􀀃Reporting􀀃Assistant􀀃(TFSRA)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃the􀀃initial􀀃processing􀀃of􀀃applications􀀃and􀀃 Direct􀀃Certification􀀃(DC). The􀀃Claims/Deputy􀀃Treasurer􀀃(C/DT)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃a􀀃random􀀃check􀀃on􀀃applications􀀃to􀀃confirm􀀃that􀀃eligibility􀀃is􀀃applied􀀃 accurately. This􀀃check􀀃should􀀃happen􀀃four􀀃(4)􀀃times􀀃a􀀃year: 1. Around􀀃the􀀃Fall􀀃Membership􀀃Count􀀃Day􀀃(first􀀃few􀀃days􀀃in􀀃October)􀀃 2. Christmas􀀃Break􀀃(around)􀀃 3. Spring􀀃Break􀀃(around)􀀃 4. First􀀃part􀀃of􀀃May􀀃 The􀀃TFSRA􀀃will􀀃put􀀃the􀀃list􀀃of􀀃students􀀃and􀀃their􀀃eligibility􀀃from􀀃the􀀃food􀀃service􀀃software􀀃(currently􀀃Titan)􀀃at􀀃the􀀃point􀀃of􀀃each􀀃 check.􀀃The􀀃first􀀃pull􀀃of􀀃students􀀃in􀀃October􀀃will􀀃be􀀃all􀀃students􀀃while􀀃the􀀃subsequent􀀃pulls􀀃will􀀃be􀀃for􀀃the􀀃dates􀀃between􀀃the􀀃 previous􀀃pull􀀃and􀀃that􀀃date􀀃with􀀃the􀀃intention􀀃of􀀃catching􀀃any􀀃new􀀃students􀀃or􀀃new􀀃student􀀃eligibility. The􀀃C/DT􀀃will􀀃select􀀃a􀀃random􀀃sampling􀀃of􀀃students􀀃to􀀃verify.􀀃They􀀃will􀀃work􀀃with􀀃the􀀃TFSRA􀀃to􀀃look􀀃at􀀃the􀀃records􀀃in􀀃Titan􀀃for􀀃 applications􀀃and􀀃CNPWeb􀀃for􀀃the􀀃DC􀀃students􀀃to􀀃see􀀃applications􀀃or􀀃the􀀃DC􀀃eligibility􀀃as􀀃appropriate.􀀃Forms􀀃will􀀃be􀀃printed􀀃or􀀃 screen􀀃shot􀀃to􀀃create􀀃a􀀃file􀀃that􀀃will􀀃be􀀃saved􀀃by􀀃both􀀃parties. Anticipated Completion Date: March 14, 2025

View Audit 349113

Finding 538073 (2024-002)

Significant Deficiency 2024

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Reporting Significant Deficiency

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E P063P130272 (7/1/2023 – 6/30/2024)...

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Related to the student status change which was reported to NSLDS outside of 60 days, the Rutgers Health and University Registrar will continue to provide training and support to University constituents through regular reporting and monthly check-in meetings to reiterate the importance of timely submissions. Related to the effective dates which did not match between the University record, Campus-Level Record and Program-Level Record, the Rutgers Health and University Registrar will continue work with the central Office of Information Technology, University Enrollment Services and Ellucian teams to refine the enrollment reporting process and will provide training to all involved to ensure accurate reporting. Anticipated Completion Date: The corrective action was in place as of March 1, 2025.

View Audit 349099

Finding 538063 (2024-001)

Material Weakness 2024

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Eligibility Material Weakness

2024-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pr...

2024-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Profession Student Loan Program (ALN 93.342), Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A132602 (7/1/2023 – 6/30/2024), E P033A132602 (7/1/2023 – 6/30/2024), E P038A132602 (7/1/2023 – 6/30/2024), E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024), E 01HP28821 02 02, E36HP26092, E36HP25751, E26HP25748, E11HP27284 (7/1/2023 – 6/30/2024), 1T08HP393200100 (7/1/2023 – 6/30/2024), 5 T08HP39320 03 00 (7/1/2023 – 6/30/2024) Contact Person: Ellen Law, AVP OIT Enterprise Application Services, 848-445-5064 Corrective Action: Management has documented and implemented system release management practices for the Oracle Student Financial Planning (OSFP) system. All change requests, updates and approvals for the OSFP system are tracked in a project tracking software. There is a dedicated OSFP administrator, segregating duties within the technical team, with the capability of deploying changes to production. A new access role was also implemented which limits the permissions, with only 4 administrators with the advanced privileges. Finally, a preliminary recertification process occurred in October 2023 and October 2024 without formal procedures which remained in development. Formalized procedures, which includes annual training, will be finalized in fiscal year 2025. Anticipated Completion Date: The corrective action for system release management, change management and system access were implemented as of June 30, 2024. The formalized procedures for recertification were developed by October 31, 2024, and the next recertification will be completed by October 31, 2025.

View Audit 349099

Finding 538047 (2024-003)

Material Weakness 2024

Fort Scott Community College

KS

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

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the C...

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and two (2) of five (5) tested had not been returned as of the date of fieldwork which exceeded the required timeframe to return funds. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know the student financial aid was returned to Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared OneDrive electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from Poise to monitor students who have withdrawal on their records so that this can be updated and proper calculations done. All financial aid staff will attend training to stay up to date on regulations and changes. Starting in July 2025 the new J1 system will be integrated with JFA (financial aid system). This will create operational efficiencies and reporting capabilities that are not currently available. Less manual transactions will also provide more accurate student reports. Measurable targets will be achieved by documenting the records within the OneDrive shared electronic folder between the Financial Aid office and the Business Office, who handles the return of funds. Daily changes and/or withdrawal of students will be monitored and funds will be returned as required. This will become of a part of the regular duties of staff.

View Audit 349075

Finding 538046 (2024-002)

Material Weakness 2024

Fort Scott Community College

KS

Special Tests & Provisions Student Financial Aid Cash Management

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to th...

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of policies and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalize the policies and procedures in the Financial Aid policy manual. The policies and procedures will have shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. A OneDrive electronic folder has been created with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system generates a listing of students. The list of students will be created for each draw-down that is initiated and will be placed in the shared folder in OneDrive. Draw-downs will not be initiated without a corresponding student list that shows the student account has been credited with the financial aid award. The documentation will be found in the shared OneDrive electronic folder, which has already been implemented. The transfer (interface) of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.

View Audit 349075

Finding 538002 (2024-001)

Material Weakness 2024

Cordell Independent School District #78

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Davis-Bacon Act Procedures: The Davis-Bacon Act requires contractors and subcontractors working on federally funded or assisted construction projects to pay their laborers and mechanics prevailing wages and benefits, as determined by the Department of Labor. For school districts involved in such ...

Davis-Bacon Act Procedures: The Davis-Bacon Act requires contractors and subcontractors working on federally funded or assisted construction projects to pay their laborers and mechanics prevailing wages and benefits, as determined by the Department of Labor. For school districts involved in such projects, ensuring compliance with the Davis-Bacon Act involves several key procedures: 1. Project Planning and Contracting: Prevailing Wage Determination: Obtain the prevailing wage rates from the Department of Labor for the locality where the project is to be performed. Contract Clauses: Include Davis-Bacon Act clauses in all construction contracts and subcontracts. This should specify the obligation to pay prevailing wages, submit certified payrolls, and allow for site inspections. 2. Pre-Construction Conference: Training and Guidance: Conduct pre-construction meetings with contractors and subcontractors to explain Davis-Bacon Act requirements, including prevailing wage rates, payroll reporting, and compliance procedures. 3. Wage Decision Posting: On-Site Posting: Ensure that the applicable wage determination and the Department of Labor's "Employee Rights Under the Davis-Bacon Act" poster are posted at the job site in a conspicuous place accessible to all workers. 4. Certified Payrolls: Submission Requirements: Require contractors and subcontractors to submit weekly certified payrolls using Form WH-347 or an equivalent form. The payroll must include details on hours worked, wage rates, fringe benefits, and deductions. 5. Review and Verification: Payroll Review: Regularly review submitted certified payrolls to verify compliance with wage determinations. Cross-check the reported wage rates and classifications with the prevailing wage rates. Worker Interviews: Conduct periodic on-site interviews with workers to verify that they are receiving the appropriate wages and benefits as reported on the certified payrolls. 6. Enforcement Actions: Non-Compliance Follow-Up: If discrepancies or non-compliance are identified, promptly address these issues with the contractor. Require corrective actions and ensure that any underpayments are rectified. Withholding Payments: Withhold contract payments as necessary to ensure compliance or to cover any underpayments until the contractor corrects the violations. 7. Documentation and Recordkeeping: Maintan Records: Keep detailed records of all wage determinations, certified payrolls, enforcement actions, and communications related to compliance with the Davis-Bacon Act. Retain these records for at least three years after project completion. 8. Audit and Oversight: Internal Audits: Conduct internal audits and oversight activities to ensure ongoing compliance. This may involve random checks and reviews by the district's compliance officers or external auditors. 9. Reporting to Funding Agencies: Regular Reports: Submit required reports to the relevant federal or state agencies overseeing the project, demonstrating compliance with the Davis-Bacon Act requirements. Cordell Public Schools has implemented the above procedures in January 2024, we can ensure compliance with the Davis-Bacon Act, thereby protecting workers' rights and avoiding potential legal and financial penalties. The carryover from a fiscal year project will be reevaluated. The project still fell under our corrective action plan but was not a new project that was in line with the actions listed above. We closed out the fiscal year, opened the new year to continue the project, therefore we still were not in compliance with the Davis-Bacon Act or our procedures. However, all future projects have been in compliance. In the next overlapping project, we will consult our auditors and find the best way to leave open funds to finish the project, but not start over in a new fiscal year.

View Audit 349009

Finding 537987 (2024-005)

Material Weakness 2024

North Newton School Corporation

IN

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.1 § 200.303 § 200.308 § 200.403

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials...

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

View Audit 349004

Finding 537978 (2024-003)

Material Weakness 2024

North Newton School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business official or superintendent will review and sign off and date the eligibility reports. Anticipated Completion Date: September 30, 2025

View Audit 349004

Finding 537977 (2024-004)

Significant Deficiency 2024

White River Valley School District

IN

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

Context: For the one project sampled for Davis-Bacon requirements, the contract with the company did not include the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $784,155. The School Corporation did obtain the weekly payroll...

Context: For the one project sampled for Davis-Bacon requirements, the contract with the company did not include the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $784,155. The School Corporation did obtain the weekly payroll reports certifications from the company that performed renovations. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Future contracts will include Davis-Bacon requirements. Any future contracts will be reviewed by the Superintendent or his designee to ensure that the required language is included in the contract. Anticipated Completion Date: Immediate

View Audit 348999

Finding 537974 (2024-002)

Material Weakness 2024

White River Valley School District

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER II amounts reported for the reports covering the FY2...

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER II amounts reported for the reports covering the FY22 time period ($0 and $459,915 respectively) did not agree to the underlying expenditure records ($27,092 and $455,658 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($459,616 and $22,273 respectively) did not agree to the underlying expenditure records ($107,610 and $1,274,716 respectively) for the period of July 1, 2022 through June 30, 2023. We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Additionally, the School Corporation was unable to provide the supporting reports containing the FTEs reported as of 9/30/22 and 9/30/23. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Federal reporting will be completed by the due date assigned and approved by the Superintendent prior to submission. After submission, the reports will be maintained. Anticipated Completion Date: Immediate

View Audit 348999

Finding 537971 (2024-001)

Material Weakness 2024

White River Valley School District

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Finding 2024-001 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: During testing we noted the following issues in a sample of forty ESSER payroll transactions: • 30 of 40 payroll transactions where a timecard was not completed by the employ...

Finding 2024-001 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: During testing we noted the following issues in a sample of forty ESSER payroll transactions: • 30 of 40 payroll transactions where a timecard was not completed by the employee to validate their hours worked and the time charged to the grant. • 26 of 40 payroll transactions where the School Corporation was unable to provide supporting documentation for approval of the hourly rate paid or the contracted salaried amount paid to employee. The noncompliance was due to turnover in the Corporation personnel and the inability to find supporting records from prior fiscal years. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A timecard checklist will be developed to keep track of timecards as they are received. Timecards will be collected by the Deputy Treasurer (Payroll) prior to completion of payroll and the timecards will be maintained with the payroll records. Salary schedules will be prepared and approved by the Board of School Trustees. The approved salary schedules will be maintained as part of the board documentation as well as part of the payroll records. Contracts will be maintained in a separate binder and a copy will be placed in the employee file. Anticipated Completion Date: Immediate

View Audit 348999 Questioned Costs: $1

Finding 537969 (2024-001)

Material Weakness 2024

Western Michigan University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Planned Corrective Action: To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Offi...

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Planned Corrective Action: To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22:  The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office.  The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date.  All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: July 2025

View Audit 348998

Finding 537960 (2024-006)

Material Weakness 2024

South Harrison Community School Corporation

IN

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

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with...

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Documentation of review for adjustments/corrections, including the period of performance, will be maintained for auditor review. Anticipated Completion Date: June 15, 2025

View Audit 348992

Finding 537955 (2024-005)

Material Weakness 2024

South Harrison Community School Corporation

IN

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

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) – Earmarking Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the findin...

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) – Earmarking Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The failure to expend all of the funding set aside for nonpublic schools was caused by several factors, including significant changes within the leadership of the nonpublic schools being served and parents’ refusal of services in lieu of vouchers being received to provide private services. The following corrective actions will be implemented with the intentions to fully expend the set-aside funding, account for the expenditures by location, and to document those efforts:  Attain documentation from the nonpublic schools being served to document the discussions about planned and allowable spending.  When it is projected that the nonpublic proportionate share will not be fully expended, documentation will be requested from the nonpublic school detailing the cause so that the waiver can be submitted.  Attend updates offered from the Indiana Department of Education for Special Education. Retain appropriate documentation from these meetings to support decisions made regarding the grants.  Account for all expenditures by nonpublic school location and prepare proportionate share reports utilizing the location-specific information. Anticipated Completion Date: April 1, 2025

View Audit 348992

Finding 537949 (2024-003)

Material Weakness 2024

South Harrison Community School Corporation

IN

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2024-003 Finding Subject: COVID-19 - Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the ...

FINDING 2024-003 Finding Subject: COVID-19 - Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The following internal controls will be implemented related to the required reporting of information:  Supporting details of reported information will be retained within the grant files for audit purposes.  Documentation of the collaboration between personnel submitting the report will be retained for audit purposes.  Documentation from the Indiana Department of Education to assure that the submitted data was correctly uploaded will be requested and retained for audit purposes. Anticipated Completion Date: June 30, 2025

View Audit 348992

Finding 537945 (2024-001)

Material Weakness 2024

South Harrison Community School Corporation

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur wi...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The following internal control procedures will be developed and implemented to assure that enrollment and poverty numbers of non-public schools is correctly entered into the grant application:  The Director for Elementary Curriculum, Instruction and Assessment/Title I Coordinator will utilize the “Guidelines for Title Services to Non-Public Schools” checklist (provided by the Indiana Department of Education during a recent Title I Directors meeting) to assure that all required non-public school related documentation is obtained and documented.  Someone other than the person preparing the Title I grant application will review the application prior to submission to assure that data is entered into the application correctly.  Documentation concerning the collaboration with and information obtained relating to the non-public school eligibility will be retained with the grant files to assure availability during audits. Anticipated Completion Date: April 1, 2025

View Audit 348992

Finding 537941 (2024-002)

Material Weakness 2024

Kokomo School Corporation

IN

Equipment & Real Property Management Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303 § 200.313

FINDING 2024-002 Finding Subject: Special Education (IDEA)-Equipment The school corporation did not maintain sufficient property records of equipment purchased with Special Education funds. All equipment was not properly added to records systems and information was entered incorrectly in the records...

FINDING 2024-002 Finding Subject: Special Education (IDEA)-Equipment The school corporation did not maintain sufficient property records of equipment purchased with Special Education funds. All equipment was not properly added to records systems and information was entered incorrectly in the records system. Contact Person Responsible for Corrective Action: Robert McIntire Contact Phone Number and Email Address: 765-455-8000 rmcintire@kokomo.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will retrain grant directors and review all requirements related to Equipment and Property Management. Anticipated Completion Date: Retraining of grant directors and all employees related to property management related to grant purchases will be completed by September 1, 2025.

View Audit 348989

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