Corrective Action Plans

Finding 383646 (2023-002)

Material Weakness 2023

MD

Student Financial Aid Subrecipient Monitoring Material Weakness § 200.303

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement wi...

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A CIO who has extensive experience in regulatory compliance as well as cyber security has been hired. The CIO has set forth a plan to get us in full regulatory compliance. A new information security plan has been crafted and is being published on the website. That plan will be put into practice over the next few months. Name(s) of the contact person(s) responsible for corrective action: Irving Bruckstein Planned completion date for corrective action plan: June 30, 2024

View Audit 296682

Finding 383645 (2023-001)

Material Weakness 2023

Washington College

MD

Student Financial Aid Eligibility Material Weakness § 200.303

Student Financial Aid Cluster – NSLDS Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with...

Student Financial Aid Cluster – NSLDS Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure continuity of operations, Jennifer Gallagher will be temporarily assuming responsibility for Enrollment Reporting until a new Registrar is hired and trained. She is committed to addressing any outstanding issues and improving the efficiency of our processes during this transitional period. Name(s) of the contact person(s) responsible for corrective action: Jennifer Gallagher Planned completion date for corrective action plan: June 30, 2024

View Audit 296682

Finding 383638 (2023-006)

Material Weakness 2023

Southwest School Corporation

IN

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

Finding 2023-006 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: 84.425U Federal Award Numb...

Finding 2023-006 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: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, 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. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $556,865 during the audit period on a construction project to expand the cafeteria which was charged to the ESSER III grant award (84.425U) and approved through the grant application with the Indiana Department of Education. The construction contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts. The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from the construction company and its subcontractors, as applicable, for the construction project to verify prevailing wages were being paid during the project period. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The construction payments represented approximately 22.5% of the Education Stabilization Fund disbursements for the period under audit. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 - The Southwest School Corporation will ensure that Davis Bacon rules are included in any RFP using federal funds. The Development Team will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 2024

View Audit 296662

Finding 383627 (2023-005)

Material Weakness 2023

Southwest School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X...

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

View Audit 296662

Finding 383601 (2023-002)

Material Weakness 2023

Southwest School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Educ...

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. The lack of internal controls was a systemic issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – All invoices, as well as receipts, will be documented upon receipt by the Director of Special Education at Greene Sullivan Special Education Cooperative. After this takes place, The Director of Finance at Greene Sullivan Special Education Cooperative will then create vouchers and receipts accordingly. Prior to submission, the Director of Special Education of Greene Sullivan Special Education Cooperative will verify all documents for accuracy. The Superintendent and Treasurer of Southwest School Corporation will review the documentation for the Cooperative at lease semi-annually. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

View Audit 296662

Finding 383591 (2023-001)

Material Weakness 2023

Unified School District No. 307

KS

Reporting Subrecipient Monitoring Material Weakness § 200.502

March 18, 2024 U.S. Department of Education and U.S. Department of Homeland Security Washington, D.C. Unified School District No. 307 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Au...

March 18, 2024 U.S. Department of Education and U.S. Department of Homeland Security Washington, D.C. Unified School District No. 307 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT None. FINDINGS-FEDERAL AWARD PROGRAMS AUDIT 2023-001 Preparation of and Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agencies: U.S. Department of Education and U.S. Department of Homeland Security Program Names: Education Stabilization Fund and Disaster Grant – Public Assistance Assistance Listing Numbers: 84.425 and 97.036 Award Period: June 30, 2023 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. Contact Name – Cher Richards Expected Completion Date -06/30/2024 If the U.S. Department of Education or U.S. Department of Homeland Security has questions regarding this plan, please call Cher Richards at 785-914-5602. Sincerely yours, Cher Richards District Treasurer Unified School District No. 307

View Audit 296639

Finding 383545 (2023-005)

Material Weakness 2023

Community Schools of Frankfort

IN

School Nutrition Programs Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact P...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

View Audit 296610

Finding 383533 (2023-003)

Material Weakness 2023

Community Schools of Frankfort

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-003 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to reporting. Contact Person Responsible for Corrective Action: Scott Weltz, Michelle Wolfe Contact Phone Numbe...

FINDING 2023-003 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to reporting. Contact Person Responsible for Corrective Action: Scott Weltz, Michelle Wolfe Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, wolfem@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

View Audit 296610

Finding 383525 (2023-001)

Material Weakness 2023

Rush Springs School District I-68

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Rush Springs Public Schools will develop internal controls to meet the requirements of the Davis-Bacon Act. The District will make sure that any federal awards used on construction projects are in compliance with the Act by not only including the prevailing wage clauses in the construction contract...

Rush Springs Public Schools will develop internal controls to meet the requirements of the Davis-Bacon Act. The District will make sure that any federal awards used on construction projects are in compliance with the Act by not only including the prevailing wage clauses in the construction contract , but also ensuring that federal wage rates and fringes are met. The District will ensure these wages are met by collecting and reviewing weekly certified payroll reports supplied by either the contractor or subcontractor. To ensure complance with the Davis-Bacon Act, Rush Springs Public Schools will post all required items at the work site. This Corrective Action Plan will be implemented immediately beginning on January 10, 2024.

View Audit 296600

Finding 383498 (2023-002)

Material Weakness 2023

Cornish College of the Arts and Cornish Foundation

WA

Material Weakness Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College immediately start the search process for a replacement controller and potentially look into outsourcing that position if necessary.. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College immediately start the search process for a replacement controller and potentially look into outsourcing that position if necessary.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has hired an interim controller and is in the process of finding a permanent replacement. Name(s) of the contact person(s) responsible for corrective action: Debbie Treen, VP Finance and CFO, pending hiring of open Controller position Planned completion date for corrective action plan: July 31, 2024

View Audit 296558

Finding 383340 (2023-001)

Material Weakness 2023

Mangum Independent School District #1

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Mangum Public Schools will comply with all requirements of the Davis-Bacon Act. The district will develop internal controls to ensure contracts used for construction with federal awards will require certified payroll reports from the contractor or subcontractor. These actions will be taken immedia...

Mangum Public Schools will comply with all requirements of the Davis-Bacon Act. The district will develop internal controls to ensure contracts used for construction with federal awards will require certified payroll reports from the contractor or subcontractor. These actions will be taken immediately and will be utilized for any future construction that meets the criteria of the Davis-Bacon Act to ensure we are compliant.

View Audit 296538

Finding 383309 (2023-001)

Material Weakness 2023

Elk City Independent School District No. 06

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, will include requirements of the Davis-Bacon Act. Prevailing wages will be inserted into the language of the contract to be signed by contractors and subcontractors. All contracts will also...

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, will include requirements of the Davis-Bacon Act. Prevailing wages will be inserted into the language of the contract to be signed by contractors and subcontractors. All contracts will also spell out weekly reporting requirements of certified wages paid by contractors and subcontractors. In addition, ECPS will ensure that Davis-Bacon information is posted at all job sites.

View Audit 296509

Finding 383284 (2023-018)

Material Weakness 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Eligibility Special Tests & Provisions § 200.303 § 200.334

Corrective action plan: In December 2021, HHSC implemented the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment Management System (PEMS), an automated system that is the single tool for provider enrollment, re-enrollment, revalidation, and maintenance requests (maintaining and upda...

Corrective action plan: In December 2021, HHSC implemented the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment Management System (PEMS), an automated system that is the single tool for provider enrollment, re-enrollment, revalidation, and maintenance requests (maintaining and updating provider enrollment record information). Medicaid provider enrollment, revalidation, and re-enrollment documentation, including risk-based screenings, are tracked in PEMS. Additionally, the relevant federal databases are checked at least monthly for all providers currently enrolled in Medicaid. Of the Medicaid providers requested during the fiscal year 2023 Statewide Single Audit, 47 of 60 samples had been enrolled or revalidated through PEMS and the auditor received all requested documentation. The listed exceptions only apply to Medicaid long-term care (LTC) providers whose enrollment and/or revalidation have not yet been processed through PEMS. The LTC enrollment and revalidation process mirrors the sampled acute care providers which were found to be 100 percent compliant during this review, further supporting that the process is working. HHSC operated under the public health emergency (PHE) between March 30, 2020, and May 11, 2023. In response to the PHE, the Centers for Medicare and Medicaid Services waived exclusion check requirements for provider reenrollments and revalidations. HHSC is in the process of revalidating providers through PEMS; however, as a result of the PHE end date and provider revalidation requirements, the projected completion date for the required revalidation of all LTC providers is January 2027. HHSC continues efforts to enroll LTC providers through PEMS and expects to eliminate errors related to these documents once all LTC providers have revalidated. Implementation dates: December 2021, PEMS implementation January 2027, LTC provider enrollment and revalidation completed Responsible persons: Jordan Nichols, Deputy Associate Commissioner, Medicaid and CHIP Services Operations Management

View Audit 296491

Finding 382968 (2023-010)

Material Weakness 2023

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problemat...

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problematic for HHSC to commit to the specific designation of CAPPS-Financials as the improvement solution, actions will be taken to improve compliance. HHSC will implement a quality review of selected programs to assess FFATA compliance on an annual basis. Implementation date: September 1, 2025 Responsible person: Racheal Kane, Director, Federal Funds

View Audit 296491

Finding 382888 (2023-002)

Material Weakness 2023

School Town of Speedway

IN

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

The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner....

The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner. Responsible party and timeline for completion: Superintendent and Director of Facilities; Information that was requested has been provided to the best of our ability. Future contracts will have required information provided during the project, and at the completion of the project.

View Audit 296461

Finding 382881 (2023-001)

Material Weakness 2023

Morgan Metropolitan Housing Authority

OH

HUD Housing Programs Material Weakness Reporting

Finding Number: 2023-001 Planned Corrective Action: Being a small PHA, only 19 of our files were tested. One of those files had an error in it making the error rate 5.263%. In that file, when the tenant’s utility allowance was figured, the system default of the McConnelsville water/sewer rate ($167)...

Finding Number: 2023-001 Planned Corrective Action: Being a small PHA, only 19 of our files were tested. One of those files had an error in it making the error rate 5.263%. In that file, when the tenant’s utility allowance was figured, the system default of the McConnelsville water/sewer rate ($167) was not overridden to the Malta water/sewer rate ($160). This created an error of $7 per month that the tenant was underpaid for his utility allowance, which resulted in the HAP payment to the homeowner being overpaid by $7 per month ($362 instead of $355). Because of this, the tenant’s rental amount due reflected $7 less than it should have been ($238 instead of $245). When the Auditor of State’s representative was on site at MMHA for testing on February 7, 2024, he brought this to our attention. The correction was made in our software system and a notice was sent to the tenant that same day. A copy of the amended HAP contract and a copy of the notice that was sent to the tenant was provided to the Auditor of State’s audit team. Both show a computer-generated date stamp of February 7, 2024. The tenant’s annual re-examination took place on June 1, 2023 and the corrected HAP amount was effective April 1, 2024. For the current year (7/1/22-6/30/23), there was a total payment of $7 from Section 8 funding which was for the month of June 2023. Anticipated Completion Date: February 7, 2024 Responsible Contact Person: Angie Finley, Executive Director

View Audit 296460

Finding 382872 (2023-003)

Material Weakness 2023

Northeast School Corporation

IN

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

Finding 2023-003 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: 84.425U Federal Award Numbers...

Finding 2023-003 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: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, 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. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $540,000 during the audit period on a construction project for the North Central High School Kitchen/Cafeteria remodel, which was charged to the ESSER III grant award (84.425U). The construction contract did include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts. The School Corporation did not have an internal control designed to ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing ($254,377), we noted that labor costs totaled $55,299. The School Corporation did not receive the weekly payroll reports as required to ensure that pay rates complied with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. Treasurer will track future projects' labor cost. 1 - The Northeast School Corporation will ensure Davis Bacon rules are included in any RFP using federal funds. The treasurer will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

View Audit 296449

Finding 382869 (2023-004)

Material Weakness 2023

Northeast School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.328

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II),...

FINDING 2023-004 Information on the federal program: Subject: COVID-19 Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER) Fund, Elementary and Secondary School Emergency Relief (ESSER II), and Elementary and Secondary School Emergency Relief (ESSER III) Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Number: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have a review control in place to ensure the annual data report was reviewed by someone other than the preparer and that the report was submitted timely. Context: The Annual Data Report for the period of July 1, 2021 to June 30, 2022 was due to the Indiana Department of Education (IDOE) by April 7, 2023. The School Corporation did not submit the report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will submit future reports in a timely manner. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer Effective for the 2023-2024 school year

View Audit 296449

Finding 382857 (2023-007)

Material Weakness 2023

Northeast School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Fe...

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

View Audit 296449

Finding 382835 (2023-005)

Material Weakness 2023

Northeast School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Pre...

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. The lack of internal controls was a systemic issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: The Superintendent and Treasurer of Northeast School Corporation will review the documentation for the Cooperative at least semi-annually. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

View Audit 296449

Finding 382828 (2023-004)

Material Weakness 2023

North White School Corporation

IN

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

Finding 2023-004 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 A...

Finding 2023-004 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): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, 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. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $2,354,885 during the audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building which included labor installation costs subject to federal Davis Bacon wage rate requirements. Each project had a separate vendor for a total of two vendor contracts during the audit period subject to testing for Davis Bacon wage rate requirements. The vendor contracts did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects to verify prevailing wages were being paid during the project period. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. For the period July 1, 2021 through June 30, 2023, $925,844 was disbursed related to these building projects and charged to the ESSER II grant award (84.425D). For the period July 1, 2021 through June 30, 2023, $1,429,041 was disbursed related to these building projects and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 80.1% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Corporation will make sure all contracts using federal dollars will have the Davis-Bacon clause written in the contract. The project manager will request weekly time sheets for all labor installation and verify the work has been completed. Responsible Party and Timeline for Completion: The Superintendent, Nicholas Eccles, will oversee the corrective action plan regarding the Davis-Bacon clause in future contracts which will be implemented by June 30, 2024. The Building/Maintenance Director, Dean Cook, will oversee the corrective action plan regarding the verification of time sheets for labor installation which will be implemented by June 30, 2024.

View Audit 296431

Finding 382799 (2023-003)

Material Weakness 2023

Nettle Creek School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement an...

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for ESSER II, Year 1, annual report tested the School Corporation could provide supporting documentation that did not agree with the ESSER II, Year 1, annual report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated from ESSER 1I, Year 1 report. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will prepare annual reports for grants and the Director of Learning and/or Superintendent will review and sign-off reports before submission. Anticipated Completion Date: June 30, 2024

View Audit 296407

Finding 382780 (2023-004)

Material Weakness 2023

San Diego Christian College

CA

Subrecipient Monitoring Material Weakness

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: • 16 CFR § 314.4(b)(1): To be completed by June 30, 2024. • 16 CFR § 314.4(c)(1-8): To be completed for SDCC-utilized systems that contain this feature by June 30, 2024. • 16 CFR § 314.4(d)(2): The College currently monitors in...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: • 16 CFR § 314.4(b)(1): To be completed by June 30, 2024. • 16 CFR § 314.4(c)(1-8): To be completed for SDCC-utilized systems that contain this feature by June 30, 2024. • 16 CFR § 314.4(d)(2): The College currently monitors information systems internally through log review. External penetration testing will be conducted pending funds availability for this purpose. • 16 CFR § 314.4(e): To be completed by September 30, 2024. • 16 CFR § 314.4(h): To be completed by September 30, 2024. • 16 CFR § 314.4(i): To be completed by December 31, 2024. Person Responsible for Corrective Action Plan: Lisa Kopecky, Chief Financial Officer and Matt Owen, designated Information Security Officer Anticipated Date of Completion: Completion as noted above.

View Audit 296385

Finding 382767 (2023-005)

Material Weakness 2023

Lakeland School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had a lack of internal controls over the ESSER reporting to the IDOE. There was no review process in place to prevent, or detect and correct, errors. Contact Person Responsi...

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had a lack of internal controls over the ESSER reporting to the IDOE. There was no review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The Director of Business Operations and Director of Staff and Student Success will meet to review the annual data reports for accuracy before they are submitted to the IDOE. The meeting will be logged and reports signed off by both individuals. Anticipated Completion Date: Immediately

View Audit 296373

Finding 382761 (2023-003)

Material Weakness 2023

Lakeland School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee t...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee to ensure compliance. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Claims for Reimbursement will be prepared by the Food Service Director and the Director of Business Operations will review the claims for compliance. The claims will then be initialed signaling they have been reviewed. Anticipated Completion Date: Immediately

View Audit 296373

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