Corrective Action Plans

Finding 384216 (2023-003)

Material Weakness 2023

ND

Reporting Material Weakness Matching / Level of Effort / Earmarking

Finding 2023-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: Eide Bailly assisted in the preparation of our draft schedule of expenditures and federal awards and accompanying notes to the consolidated schedule of ...

Finding 2023-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: Eide Bailly assisted in the preparation of our draft schedule of expenditures and federal awards and accompanying notes to the consolidated schedule of expenditures and federal awards. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for a complete and accurate schedule of expenditures and federal awards. We requested that our auditors, Eide Bailly LLP, assist in the preparation of the schedule of expenditures. We have designated a member of management to review the drafted schedule of expenditures. Anticipated Completion Date: Ongoing

View Audit 297302

Finding 384112 (2023-001)

Material Weakness 2023

Concordia University, St. Paul

MN

Questioned Costs Student Financial Aid Material Weakness

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the 2022 Corrective Action Plan submitted in March 2023, a report was built to pull all withdrawals for the semester and broken down by module enrollment. This is reviewed and processed weekly after the initial aid disbursement for the semester. Financial Aid Counselors also review an Enrollment Change report daily and notify the Assistant Director and Director of Financial Aid of possible R2T4 calculations. Additionally, the Financial Aid Office is copied on all General Petition and University Withdrawal notifications to review for possible R2T4 requirements. The Loan Specialist, Assistant Director, and Director of Financial Aid have all passed the NASFAA U R2T4 course and hold the R2T4 Credential. The Director of Financial Aid also received the R2T4 Specialist designation from NASFAA. The 14 students found to be processed past the 45 days and the 5 students to have additional funds sent back, all R2T4s were processed prior to the 2022 Audit and Corrective Action Plan was put into place. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: Now in place and ongoing process

View Audit 297264 Questioned Costs: $1

Finding 384081 (2023-002)

Material Weakness 2023

Allen University

NC

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

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiencies): (Continued) (d) The University did not timely submit their Title IV reconciliations for testing. The University did not routinely reconcile Title IV funds throughout the year b...

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiencies): (Continued) (d) The University did not timely submit their Title IV reconciliations for testing. The University did not routinely reconcile Title IV funds throughout the year between the business and SFA offices. SFA Handbook Chapter 5 CFR 668.161 through 668.176. (e) The Fiscal Operations Report and Application to Participate (FISAP) was not tested because of corrections required by the U.S. Department of Education that are still under review. 34 CFR 674.19, 675.19, 676.19. Auditor’s Recommendation – The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – (a) The Business Office will generate credit balance invoices from Jenzabar weekly to review all credit balances and ensure refunds are issued within the required 14 days per HEA regulations. (b) Financial staff will update the COA worksheet that will be available once the Board has decided on the costs for each fiscal year. This will allow information to be readily available upon the auditor's request. (c) Management has hired a new Director of Financial Aid and has employed additional assistance to help facilitate the monthly reconciliation process. Monthly recon-ciliations will be completed and the Office of Financial Aid and the Business Office will meet monthly to review reconciliations and any possible variances. (d) The institution submitted a change request on February 14, 2024. Upon approval of the change request, the FISAP was resubmitted on February 20, 2024. Per the conversation with COD, the submission is waiting for approval and is currently being processed. Once the changes are approved, the final document will be submitted.

View Audit 297208

Finding 384020 (2023-001)

Material Weakness 2023

The Children's Institute of Pittsburgh

PA

Questioned Costs Material Weakness Reporting § 200.516

Finding Reference Number 2023-001 Description of Finding: The Children's Institute (CI) was non-compliant in maintaining contractual obligations established by the Fiscal Year 2022-23 Agreement with an awarding agency concerning financial responsibility and maintaining accurate and complete recor...

Finding Reference Number 2023-001 Description of Finding: The Children's Institute (CI) was non-compliant in maintaining contractual obligations established by the Fiscal Year 2022-23 Agreement with an awarding agency concerning financial responsibility and maintaining accurate and complete records for one of CI's Family Support Services (FSS) programs. Statement of Concurrence or Nonconcurrence CI leadership has reviewed the 2023-001 findings and concur with the recommendations stated. Corrective Action: Training: 1. FSS managers and supervisors were trained on billing reconciliation process, June-July 2023. 2. The Chief Program Officer, in collaboration with the Director of Compliance, will oversee the development of a training program for all current and new hire FSS employees for billing and documentation requirements by December 31, 2023. Process Improvement: 1. Monthly office billing reconciliation process was developed by FSS leadership and CI Finance team and implemented, July 2023. 2. The Chief Program Officer, in collaboration with the Director of Compliance, will develop a policy around billing reconciliation by November 15, 2023. Monitoring: 1. The COO, in collaboration with the Director of Compliance, will create a task force by November 15, 2023, to oversee development of documentation and billing policy and procedure, training and auditing standards. 2. CI executive leadership will contract with an external auditing firm to perform a baseline billing and documentation audit and prepare recommendations for process improvements on all remaining FFS programs. 3. A 20% random sample of case files, for the FSS program referenced in these findings, will be internally audited quarterly for accuracy and completeness of billing and documentation, to begin by November 30, 2023. CI will extend these internal auditing practices to all FSS programs after baseline external audits are complete.

View Audit 297071 Questioned Costs: $1

Finding 384019 (2023-001)

Material Weakness 2023

Wayne Independent School District No. 10

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and frin...

Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The District will also ensure that all items are posted at the work site to ensure compliance.

View Audit 297069

Finding 384006 (2023-001)

Material Weakness 2023

Navajo Independent School District No. 01

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The District will develop internal controls to meet the requirements of the Davis-Bacon Act to ensure that any time federal awards are used on construction, compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effec...

The District will develop internal controls to meet the requirements of the Davis-Bacon Act to ensure that any time federal awards are used on construction, compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The district will also ensure that all items are posted at the work site to ensure compliance. The District will make these internal controls effective immediately, as of today, November 7, 2023.

View Audit 297032

Finding 383989 (2023-008)

Material Weakness 2023

School City of East Chicago

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-008 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email ...

FINDING 2023-008 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID – 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

View Audit 296995

Finding 383979 (2023-006)

Material Weakness 2023

School City of East Chicago

IN

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

FINDING 2023-006 Finding Subject:􀀃Title􀀃I􀀃Grants􀀃to􀀃Local􀀃Educational􀀃Agencies􀀃􀍲􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃Annual􀀃Report􀀃Card,􀀃 High􀀃School􀀃Graduation􀀃Rate􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirement...

FINDING 2023-006 Finding Subject:􀀃Title􀀃I􀀃Grants􀀃to􀀃Local􀀃Educational􀀃Agencies􀀃􀍲􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃Annual􀀃Report􀀃Card,􀀃 High􀀃School􀀃Graduation􀀃Rate􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃Annual􀀃Report􀀃Card,􀀃High􀀃School􀀃 Graduation􀀃Rate􀀃compliance􀀃requirement.􀀃The􀀃School􀀃Corporation􀀃did􀀃not􀀃have􀀃effective􀀃internal􀀃controls􀀃to􀀃ensure􀀃 that􀀃documentation􀀃regarding􀀃the􀀃reason􀀃for􀀃a􀀃student􀀃being􀀃removed􀀃from􀀃the􀀃high􀀃school􀀃graduation􀀃cohort􀀃for􀀃 mobility􀀃reasons􀀃was􀀃prepared,􀀃reviewed,􀀃and􀀃retained.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: School City of East Chicago will implement new internal controls to ensure of that exit conferences for each student withdrawal will be held and all documentation will be filed. All documents will be scanned to student software. All students will be properly document to the state and local entities. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

View Audit 296995

Finding 383977 (2023-005)

Material Weakness 2023

School City of East Chicago

IN

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-005 Finding Subject:􀀃Title􀀃I􀀃Grants􀀃to􀀃Local􀀃Educational􀀃Agencies􀀃–􀀃Reporting􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Reporting􀀃requirement.􀀃The􀀃Sc...

FINDING 2023-005 Finding Subject:􀀃Title􀀃I􀀃Grants􀀃to􀀃Local􀀃Educational􀀃Agencies􀀃–􀀃Reporting􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Reporting􀀃requirement.􀀃The􀀃School􀀃Corporation􀀃did􀀃not􀀃have􀀃 effective􀀃internal􀀃controls􀀃to􀀃ensure􀀃that􀀃reimbursement􀀃requests􀀃or􀀃final􀀃expenditure􀀃reports􀀃were􀀃properly􀀃 supported􀀃with􀀃documentation.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls and policies will be put in place to ensure all Title cash request will have three approvals before submitting the request to the State. The Federal clerk will prepare the request, the federal director we do second approval. The CFO will do final approval after review all documentation associated with the cash request. All will sign document. All title state reporting and back up documentation will be reviewed by the CFO and signed. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

View Audit 296995 Questioned Costs: $1

Finding 383960 (2023-001)

Material Weakness 2023

Corn Belt Power Cooperative

IA

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

Federal Agency Name: Department of Homeland Security & Emergency Management passed through State of Iowa department of Homeland Security and Emergency Management Assistance Listing Number: 97.3036, 4642DRIAP00000501 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative ...

Federal Agency Name: Department of Homeland Security & Emergency Management passed through State of Iowa department of Homeland Security and Emergency Management Assistance Listing Number: 97.3036, 4642DRIAP00000501 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative did not have any formally documented review and approval over the material and transportation costs claimed for reimbursement under the program. Corrective Action Plan: The Cooperative will document the review and approval of expenses for transportation and material that we are already doing. This will include initials and e-mails documenting the review process that was completed. For transportation the person reviewing the transportation logs with the payroll logs will initial the transportation logs. The person tying the transportation logs to the computer system and the vehicle’s actual ending mileage will also initial the transportation logs. For material transactions, a summary of transactions for the month will go to the appropriate department supervisor to sign off on those transactions. The person approving the transaction will depend on the department. Responsible Individuals: Department Supervisors who have inventory, Jaylen Heinz - Accountant, Kari Rubel - Accountant and other accountants. Anticipation Completion date: March 2024

View Audit 296983

Finding 383909 (2023-001)

Material Weakness 2023

Sayre Independent School District #31

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The superintendent and encumbrance clerk will review all Davis-Bacon requirements before using federal funds on construction projects beginning immediately (10-20-23) and continuing with all construction projects in the future. The following will be monitored as part of the review/action plan: com...

The superintendent and encumbrance clerk will review all Davis-Bacon requirements before using federal funds on construction projects beginning immediately (10-20-23) and continuing with all construction projects in the future. The following will be monitored as part of the review/action plan: compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met, including collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance.

View Audit 296918

Finding 383845 (2023-001)

Material Weakness 2023

Indigenous Peoples Task Force

MN

Questioned Costs Cash Management Material Weakness § 200.302

2023-001: Overspent Grant Federal Departments: Department of Health and Human Services Assistance Listing #: 93.243 Compliance and Internal Controls Material Weakness Category of Finding – Cash Management Name of contact person – Sharon Day, Executive Director Corrective action – IPTF h...

2023-001: Overspent Grant Federal Departments: Department of Health and Human Services Assistance Listing #: 93.243 Compliance and Internal Controls Material Weakness Category of Finding – Cash Management Name of contact person – Sharon Day, Executive Director Corrective action – IPTF hired a new contract accountant in October 2022 and have since implemented processes to ensure accurate internal financial statements are prepared and reviewed by program managers on a monthly basis as required by their written financial policies. Completion date – Management and the Board of Directors implemented the above as of January 2024.

View Audit 296866 Questioned Costs: $1

Finding 383823 (2023-002)

Material Weakness 2023

Metropolitan School District of Washington Township

IN

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.208 § 200.302 § 200.303 § 200.328

FINDING 2023-002 Finding Subject: Special Education Cluster (IDEA) - Reporting Summary of Finding: Expenditures not agreeing with ledgers Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Respons...

FINDING 2023-002 Finding Subject: Special Education Cluster (IDEA) - Reporting Summary of Finding: Expenditures not agreeing with ledgers Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The finding was due to amounts that could not be claimed timely for reimbursement because of funds needing to be moved within grant buckets. Per a discussion with the auditors we need to tie the expenses not claimed back to a specific employee/employees or a specific purchase. beginning with our March reimbursements all adjustments to the funds ledger will have backup documents showing what items were omitted from reimbursement because of need for a budget amendment. Anticipated Completion Date: March 2024

View Audit 296858

Finding 383797 (2022-001)

Material Weakness 2023

City of Dillingham

AK

Reporting Material Weakness § 200.512

Finding 2022-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Anita Fuller, Finance Director Corrective Action Plan: FY23 Audit onsite work has been completed and is still pending review. FY24 Audit has been scheduled in two part. Testwork is scheduled for t...

Finding 2022-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Anita Fuller, Finance Director Corrective Action Plan: FY23 Audit onsite work has been completed and is still pending review. FY24 Audit has been scheduled in two part. Testwork is scheduled for the week of September 30, 2024. With the final review in November. Upper-level staffing positions have been filled which will allow for work to be fulfilled in-house. Proposed Completion Date: Immediately

View Audit 296807

Finding 383771 (2023-003)

Material Weakness 2023

Catholic Community Services of Western Washington

WA

Allowable Costs / Cost Principles Cash Management Subrecipient Monitoring § 200.303 § 200.329

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the ...

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the documentation of secondary review of financial reports, timely filing, and disclosed demographics contained within the reports, which can be attributed to a lack of documentation of review and controls in place for submission of a report when responsible employee is out of office during the due date. Authorized personnel review was not documented, and a performance report was not filed timely and was filed with incorrect demographics. More thorough training of staff, along with careful supervisory review and documentation of review of report submissions prior to filing would likely have prevented these errors. Corrective action: A process for secondary review of all financial and programmatic reports will be developed in each region.

View Audit 296797

Finding 383722 (2023-007)

Material Weakness 2023

Solen Public School District No. 3

ND

Material Weakness Reporting

Contact Person David Drapeaux Corrective Action Plan The district will implement measures to enhance the accuracy and verification of data reported on the Federal Impact Aid Application. The Superintendent and Business Manager will work together in the future to implement validation checks and verif...

Contact Person David Drapeaux Corrective Action Plan The district will implement measures to enhance the accuracy and verification of data reported on the Federal Impact Aid Application. The Superintendent and Business Manager will work together in the future to implement validation checks and verification processes to ensure there is accurate documentation to verify information on the application. Completion Date On-going

View Audit 296746

Finding 383699 (2023-002)

Material Weakness 2023

South Gibson School Corporation

IN

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

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not s...

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not support the amounts reported for expenditures in either ESSER II annual data report. It was recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are supported by the School Corporation’s underlying accounting records. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning with the annual data report submissions for these funds due in April 2024, the Assistant Superintendent will audit the reports as prepared by the Treasurer in order to ensure the spreadsheets are correct and reflect the financial statements’ of the school corporation. Anticipated Completion Date: 5 March 2024

View Audit 296724

Finding 383652 (2023-001)

Material Weakness 2023

Mount Mary University, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

For the Year Ended June 30, 2023 Finding 2023-001 Condition 1: Management's review of the enrollment reporting did not detect errors on certain student data elements that were not timely filed. Certain student records within the NSLDS were identified with inaccurate data elements and others that wer...

For the Year Ended June 30, 2023 Finding 2023-001 Condition 1: Management's review of the enrollment reporting did not detect errors on certain student data elements that were not timely filed. Certain student records within the NSLDS were identified with inaccurate data elements and others that were not timely reported. Corrective Action Planned: Registrars will work with our IT department to ensure data retrieved from Jenzabar for NSLDS reporting is pulling all the correct information including student’s status and all effective dates.  Prior to the report being uploaded to NSLDS, the Registrar will review a sample of students to ensure the accuracy of data.  Once the reports are updated to NSLDS Financial Aid and Veterans Services will review a sample of students and review data provided by NSLDS, again to confirm the accuracy of data at all stages. Name(s) of Contact Person(s) Responsible for Corrective Action: Angela Sarni, Director of Financial Aid & Veterans Services and Jonathan Hertig, Registrar Anticipated Completion Date: Registrar is currently working with IT to review report script and resolve any prior reporting’s. Student updates will continue to be monitored prior to NSLDS submissions and confirmed by Financial Aid and Veterans Services. We anticipate a revised report to be completed with accuracy to NSLDS no later than April 30, 2024.

View Audit 296692

Finding 383646 (2023-002)

Material Weakness 2023

Washington College

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

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