Corrective Action Plans

Finding 390508 (2023-018)

Material Weakness 2023

NH

Questioned Costs Material Weakness Period of Performance § 200.303

Corrective Action Planned: The identified payments relate to postage expenditures recorded in the Child Support Enforcement Grant. Postage expenditures are controlled in the State's mailing system through mail codes. Agencies send approved postage budgets to the Department of Administrative Service...

Corrective Action Planned: The identified payments relate to postage expenditures recorded in the Child Support Enforcement Grant. Postage expenditures are controlled in the State's mailing system through mail codes. Agencies send approved postage budgets to the Department of Administrative Services (DAS), who then creates a new mail code or adds additional funding to existing codes in the system. All mail processed through the mailing system is charged to these individual mail codes. A monthly expenditure report from the mailing system is interfaced with NH First, and the DAS uploads a journal entry to the general ledger to record these expenditures. The review and approvals for these postage transactions occur upfront at the agency level, not through a NH First approval workflow. DHHS and DAS will work together to document adequate evidence of this upfront review and approval.

View Audit 301259 Questioned Costs: $1

Finding 390492 (2023-010)

Material Weakness 2023

State of New Hampshire

NH

Reporting Subrecipient Monitoring Material Weakness § 200.303

This function (FFATA reporting) has now been designated to our Federal Reporting Group, which will allow for redundancy in personnel. A new policy and procedure, which will include internal controls, will be developed and implemented.

View Audit 301259

Finding 390488 (2023-009)

Material Weakness 2023

State of New Hampshire

NH

Questioned Costs Material Weakness Period of Performance § 200.303

NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were i...

NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were in fact some items that were charged outside the period of performance. This happened prior to us receiving the FY22 audit finding and putting in place new controls to prevent. We have since put into place DOE-OBM-33 to ensure payments are being reviewed closely to the period of performance at multiple times. We have also corrected any items charged to the wrong CAN. The NHED concurs with the findings identified with expenditures of $816. We will look into the district returning these funds or other enforcement actions. In addition to the DOE-OBM-033 process, the Division of Learner Support has created and implemented a transfer of funds procedure.

View Audit 301259 Questioned Costs: $1

Finding 390480 (2023-008)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring Reporting Material Weakness § 200.303

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission a...

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission and a secondary certification for accuracy verification, and a division wide process for FFATA filing and verification. Division wide training occurred on October 26, 2023. Due to grant award notification (GAN) changes and development within our grants management system (GMS), the FFATA process has also been developing and shifting; therefore the FFATA process will be revisited annually and updated as needed. A revised procedure for FFATA reporting will be completed prior to additional training being offered. To ensure that processes are being followed, newly hired staff is trained appropriately, and updates to the GAN process are considered within the FFATA process we will hold another training this spring, March 14th, 2024, prior to new subawards being issued.

View Audit 301259

Finding 390478 (2023-006)

Material Weakness 2023

State of New Hampshire

NH

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

BEA will evaluate existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the expenditures reported in comparison to the expenditures incurred within the general ledger, account for precision level control when changing guidance ...

BEA will evaluate existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the expenditures reported in comparison to the expenditures incurred within the general ledger, account for precision level control when changing guidance exists, and that all documentation used to support the amounts reported on the federal report are properly maintained. Condition A has been completed. In January 2024, BEA evaluated internal controls related to the review and approval of expenditures. The following additional reconciliation step was added to the processes of preparation of expenditure draws and reporting preparation: • Broadband program Accountant II performs a data extract from NHFirst and reconciles the drawdown calculation totals as well as “dashboard” reporting totals to the NHFirst data extract to confirm accuracy of all data points. This second data validation step has been added to ensure all expenditures recorded in NHFirst are evaluated against program guidelines, submitted for reimbursement and included on required reports. Condition B & C to be completed no later than 12/31/2024.

View Audit 301259

Finding 390475 (2023-003)

Material Weakness 2023

State of New Hampshire

NH

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

In order to meet the segregation of duties, the Department will explore the need to create a position to ensure requisite segregation of duties requirements. With regard to the segregation of duties, the SF-270 is required form that DMAVS submits to the National Guard Appendix Program Manager for re...

In order to meet the segregation of duties, the Department will explore the need to create a position to ensure requisite segregation of duties requirements. With regard to the segregation of duties, the SF-270 is required form that DMAVS submits to the National Guard Appendix Program Manager for reimbursement with all back up documentation. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense on behalf of DMAVS to request the cash draw. Prior to the submission of reimbursement of any funds, each billing and invoice is reviewed, entered into a ledger and reconciled by three members of the accounting team. Once reconciled, the SF-270 is prepared and signed by the Financial Administrator. The SF-270 is then submitted to the appendix program manager for concurrence and then to the federal fiscal agent (USPFO) for approval. No funds are drawn down until approved by the USPFO. If this is not a satisfactory level of review, the department will request a new position to ensure that there the business function has the proper level of staffing to meet the requirements for segregation of duties.

View Audit 301259

Finding 390474 (2023-002)

Material Weakness 2023

State of New Hampshire

NH

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

For clarity the Department will create a redundant manual ledger that duplicates the functions of the current ledger and Detailed Transaction Register (DTR). DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all tr...

For clarity the Department will create a redundant manual ledger that duplicates the functions of the current ledger and Detailed Transaction Register (DTR). DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all transactions that reconciles every month to NH First Detail Transaction Register (DTR), Federal Fund tracking sheet, and Federal reimbursement tracking sheet with backup documents. The tracking sheet for the federal register is not intended to account for the state share of billing. The state share is accurately accounted for in the DTR, the cumulative accounting in the SF-270 and associated back up documentation. Supporting documentation to substantiate the accuracy of lines a, c, e, and f is in the DTR, the cumulative accounting of each SF-270, the supporting documentation sent with the billing to the Federal Government, and Year-end Agency Report for Federal Awards. This includes reconciliation and analysis of SADB expenditures and revenues to the Statement of Appropriations by each Program Accounting Unit. The SF-270 form is continuous cumulative data that starts Oct 1st and runs through the end of that Federal Fiscal Year. The SF-270 is the required federal form DMAVS submits to the Federal National Guard Appendix Program Manager for reimbursement. Back up documentation is submitted with the SF-270. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense to affect the cash draw. DMAVS does not unilaterally make cash draws to the federal government. The USPFO, who is substantially involved provides an independent review and reconciles any discrepancies prior to approving any requests for reimbursement. One possible explanation for the finding is that the selected test works were not continuous.

View Audit 301259

Finding 390473 (2023-002)

Material Weakness 2023

Guthrie County Hospital

IA

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

Department of Health and Human Services: Federal Financial Assistance Listing #93.498 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN #426037759 Activities Allowed or Unallowed and Allowable Costs/Cost Principles ...

Department of Health and Human Services: Federal Financial Assistance Listing #93.498 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year - Period 4 TIN #426037759 Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: Guthrie County Hospital (the Hospital) reported expenses in the Department of Health and Human Services (HHS) special report for Period 4 that were not reduced by reimbursement from other sources or that other sources were obligated to reimburse. Additionally, the Hospital did not report its excess expenses as unreimbursed expenses attributable to Coronavirus in the HHS special report, did not report total interest earned on the ARP Rural Payments and Period 4 General Distribution Payments, and reported gross revenues/net charges from patient care by quarter for 2021 when net revenues should have been reported. In addition, there was no evidence retained that the HHS special report was reviewed by an individual separate from the preparer prior to submission. Planned Corrective Action: Management will implement an internal control policy for federal awards compliance to more diligently review the reporting of expenses and revenues to ensure all reporting requirements are met. However, had the errors in reporting of expenses and lost revenues been identified and corrected prior to reporting, the Hospital would have demonstrated that they had incurred eligible expenses and lost revenue in excess of the Period 4 funds received, including interest on such funds. Contact Person, Title and Phone Number: Christopher Stipe, Chief Executive Officer, (641)332-2201 Anticipated Date of Completion: June 30, 2024

View Audit 301254

Finding 390471 (2023-004)

Material Weakness 2023

The Be Kind People Project Foundation

AZ

Reporting Material Weakness Matching / Level of Effort / Earmarking

2023‐004 Material Weakness in Internal Control over Compliance – Other for Preparation of Schedule of Expenditures of Federal Awards Condition: The Organization does not have an internal control system designed to provide for the preparation of the schedule. There was no documentation of review of t...

2023‐004 Material Weakness in Internal Control over Compliance – Other for Preparation of Schedule of Expenditures of Federal Awards Condition: The Organization does not have an internal control system designed to provide for the preparation of the schedule. There was no documentation of review of the Schedule retained and the Schedule required adjustments. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: The weekly tracking of expenses as indicated in #3 will keep the issue top of mind throughout the year. The CEO will review all Schedules and reports prior to their submission for audit review. Responsible Individuals: - Accountability for understanding and management of the entire process – Marcia Meyer, CEO - Preparation of regular schedules during year – Jennie Myers - Preparation of quarterly schedule updates – Jennie Myers - Approval of quarterly schedules and presentation to Finance Committee – Marcia Meyer (approval) and Jennie Myers -Preparation of annual schedule in advance of the audit – Jennie Myers - Approval of annual schedule before submiting for audit – Marcia Meyer Anticipated Completion Date: This will be implemented immediately and will be up to date by June 2024

View Audit 301253

Finding 390470 (2023-003)

Material Weakness 2023

The Be Kind People Project Foundation

AZ

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking § 200.303

2023‐003 Material Weakness in Internal Control over Compliance with Actvities Allowed Unallowed and Allowable Costs/Cost Principles Condition: The Organiza􀆟on did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing av...

2023‐003 Material Weakness in Internal Control over Compliance with Actvities Allowed Unallowed and Allowable Costs/Cost Principles Condition: The Organiza􀆟on did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: The CEO will add a regular discussion point to the weekly finance meetings in which the finance department reports on both the status of federal funds and the expenditures using those funds. Responsible Individuals: -Maintain separate tracking account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024

View Audit 301253

Finding 390428 (2023-004)

Material Weakness 2023

Delaware State University

DE

Reporting Subrecipient Monitoring Material Weakness § 200.303 § 200.502 § 200.510

2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: ...

2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director will reevaluate the controls and set in place policies and procedures for SEFA completion. Name(s) of the contact person(s) responsible for corrective action: Director of Restricted Funds Accounting, Symone Merritt Planned completion date for corrective action plan: October 2024

View Audit 301226

Finding 390420 (2023-005)

Material Weakness 2023

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will strengthen procedures and reporting practices to ensure timely submission to the National Student Clearinghouse (NSCL) & the National Student Load Data System (NSLDS). The Registrar’s Office will confirm and ensure the submissions to the National Student Clearinghouse (NSCL) corresponds with the timeframe the enrollment is rolled over to the National Student Loan Data System (NSLDS). Name(s) of the contact person(s) responsible for corrective action: Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: July 2024

View Audit 301226

Finding 390416 (2023-009)

Material Weakness 2023

Delaware State University

DE

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation o...

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Information Technology is reviewing the written policies and procedures needed to safeguard the University’s applications and data. This includes all 3rd party developed/ implemented applications as well. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russel Weaver & VP/ Chief Information Officer, Darrell McMillion. Planned completion date for corrective action plan: June 2024

View Audit 301226

Finding 390408 (2023-004)

Material Weakness 2023

Hunters Point Boarding School, Inc.

AZ

Material Weakness Reporting Internal Control / Segregation of Duties

Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned Corrective Action: The Business Manager will imme...

Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned Corrective Action: The Business Manager will immediately ensure that all payroll withholdings/ deductions will be processed properly along with all stipends. This will correct the quarterly Form 941 that will be filed by the Business Manager. All time sheets will be reviewed by Business Manager to make sure all employees hours are correctly paid.

View Audit 301207

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390270 (2023-005)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management § 200.303

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samar...

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science has processes in place for determining the amount of student financial aid to be drawn down and disbursed; however, management did not perform internal controls over cash management throughout the year. CHI Health School of Radiologic Technology has processes in place for determining the amount of Direct Loans and Pell grants to be drawn down and disbursed; however, there is no review control in place over the disbursement amounts before funds are drawn down from the G5 system. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May of 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management and FAS management. This review is presented monthly to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will implement a review control for accounting staff to review the draw down amount provided by the School prior to completing the drawn down. Documentation of the review will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science and Andrea Heffelfinger, Market Director of Accounting (CHI Health) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390235 (2023-002)

Material Weakness 2023

National University

CA

Student Financial Aid Material Weakness Reporting

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National Univer...

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National University has implemented regular reviews of its enrollment reporting. During this process, errors in reporting are identified and corrected. However, the timing of the review has not allowed enough time to process corrections within compliance. To allow for appropriate adjustments and corrections to be implemented after testing but before the enrollment reporting deadline, National University will shift the timing of its enrollment reporting review from 60 to 30 days. Though NU is currently testing enrollment reporting and adjusting queries in an ongoing effort to improve accuracy, some of those adjustments inadvertently caused students to not appear in our queries. This impact on reporting occurred in edge cases not taken into account in the queries. To ensure this does not happen in the future, NU will implement a testing regime for these queries. This testing will be conducted at regular intervals to verify the effectiveness and accuracy of the queries in identifying students who have ceased attendance as required. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance and Sarah Massey, AVP Operations, Student Support and Registrar Anticipated Completion Date: June 2024

View Audit 301132

Finding 390234 (2023-001)

Material Weakness 2023

National University

CA

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

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we c...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we continue to refine our R2T4 processes, we’ve had two key challenges we are addressing: Timeliness of R2T4 calculations: In FY22, NU identified an issue with how it was identifying unofficial withdrawals at the institution. To assist in rectifying the issue, we implemented a 35-day attendance policy that resulted in a significant amount of students being attritted from the University. We were working with a third-party firm to help us complete all the R2T4 calculations, which proved challenging; between our internal staffing and external support, we did not have the ability to do all of the calculations timely. As we’ve analyzed the needed manpower, we’ve expanded our Processing and Quality Assurance teams. The establishment of two additional teams within the Processing team in 2024 underscores our commitment to ensuring the timely completion of necessary calculations. Simultaneously, the increased Quality Assurance team is poised to support the enhanced internal controls, conducting weekly reviews of R2T4 calculations to verify their accuracy and timeliness. Missing students for R2T4 calculations who were withdrawn: We have established precise and accurate criteria for the development and execution of report queries. This initiative aims to ensure the comprehensive identification of students who discontinue attendance before the end of a payment period, thereby mitigating the risk of oversight. To bolster the reliability of these refined processes, NU is committed to implementing regular testing of the attendance queries. By conducting these tests at established intervals, the institution seeks to verify that the queries consistently identify the correct cohort of students. This approach serves as a crucial mechanism to maintain the accuracy of our withdrawal determination processes and underscores our dedication to continuous improvement. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390225 (2023-001)

Material Weakness 2023

Do Good Multnomah

OR

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that there is support to be able to be able to adequately review and approve invoices, as well as train and hold accountability with supervisors for payroll approv...

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that there is support to be able to be able to adequately review and approve invoices, as well as train and hold accountability with supervisors for payroll approval.

View Audit 301123

Finding 390219 (2023-004)

Material Weakness 2023

Enlace Chicago

IL

Procurement, Suspension & Debarment Eligibility Material Weakness

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions to maintain documentation supporting the procurement for 5 years following the end of the contract. Views of Responsible Officials: There is no disagreement with this ...

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions to maintain documentation supporting the procurement for 5 years following the end of the contract. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago is committed to following the procurement process and requirements outlined within the policies and procedures. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Finance Planned completion date for corrective action plan: June 30, 2024.

View Audit 301111

Finding 390194 (2023-001)

Material Weakness 2023

College Dreams, INC

OR

Allowable Costs / Cost Principles Cash Management Material Weakness

Finding # 2023-001 Material weakness over allowable costs U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Only allowable costs may be charged to the contract for reimbursement. One out of six invoices charged to the contract was an unallowable expense (sc...

Finding # 2023-001 Material weakness over allowable costs U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Only allowable costs may be charged to the contract for reimbursement. One out of six invoices charged to the contract was an unallowable expense (scholarships). Recommendation: Expenses charged to contract should be reviewed thoroughly and be in compliance with contract agreement. Management should have understanding of what costs are considered allowable and unallowable. Corrective Action: We will have the Executive Director, Business Manager and College+ Program Manager thoroughly review the monthly Talent Search billing before completing a drawdown to ensure that all expenses billed are allowable costs. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390168 (2023-002)

Material Weakness 2023

Altus Independent School District #18

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390167 (2023-001)

Material Weakness 2023

Altus Independent School District #18

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390165 (2023-006)

Material Weakness 2023

Yukon Flats School District

AK

Allowable Costs / Cost Principles Material Weakness

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is mad...

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is made. The Business manager and the Superintendent will conduct a review of claims to determine whether they are proper and valid charges. Once reviewed, all transactions will be authorized. DocuSign will be used for electronic signature approval. Accounts payable clerk will ensure that all transactions include copies of receipts for the goods or services purchased. Finally, the Finance department will work with the program directors to ensure that expenses are coded accurately and within reasonable timeframe to allow for timely submission of grant reports. Proposed Completion Date: March 31, 2024

View Audit 301080

Finding 390163 (2023-005)

Material Weakness 2023

Yukon Flats School District

AK

Cash Management Material Weakness Reporting

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calenda...

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calendar developed by ALASBO which addresses all reporting requirements for the school districts in Alaska. Proposed Completion Date: March 31, 2024

View Audit 301080

Corrective Action Plans

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