Corrective Action Plans

Finding 382835 (2023-005)

Material Weakness 2023

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

Finding 382751 (2023-002)

Material Weakness 2023

Phoenix Houses of Texas, Inc.

TX

Questioned Costs Eligibility Material Weakness

Finding #2023-002 – Material Weakness and Other Noncompliance. Recommendation: Provide additional staff training to ensure internal control procedures over client eligibility and required documentation are followed. Planned corrective action: Client eligibility and documentation requirements do ...

Finding #2023-002 – Material Weakness and Other Noncompliance. Recommendation: Provide additional staff training to ensure internal control procedures over client eligibility and required documentation are followed. Planned corrective action: Client eligibility and documentation requirements do not pertain to cost reimbursement grants; these regulations exclusively apply to fee-for-service grants. The fee-for-service grant programs concluded on September 30, 2023. Consequently, starting from October 1, 2023, the business model shifted to cost reimbursement only. As a result, no corrective actions are needed for fee-for-service grants. Responsible officer: Drew Dutton, President and CEO. Estimated completion date: Completed October 1, 2023

View Audit 296356 Questioned Costs: $1

Finding 382710 (2023-001)

Material Weakness 2023

Weatherford Independent School District No. 26

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

A copy of the Davis-Bacon Act requirement has been placed in the office of the federal program director. The director will be responsible for filling out the appropriate paperwrok before approving any federal funds to be used on projects that are classified as construction. The requirements of the...

A copy of the Davis-Bacon Act requirement has been placed in the office of the federal program director. The director will be responsible for filling out the appropriate paperwrok before approving any federal funds to be used on projects that are classified as construction. The requirements of the Davis-Bacon Act have also been shared with the Encumbrance Clerk and Treasurer for the purpose of checks and balances.

View Audit 296312

Finding 382694 (2023-007)

Material Weakness 2023

Muncie Community Schools

IN

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-007 – Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirement Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We wil...

Finding 2023-007 – Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirement Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all construction projects using federal funding will meet the wage rate requirements. Anticipated Completion Date: March 2024

View Audit 296252

Finding 382689 (2023-006)

Material Weakness 2023

Muncie Community Schools

IN

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

Finding 2023-006 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate...

Finding 2023-006 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next ESSER reports due in FY24

View Audit 296252

Finding 382628 (2023-001)

Material Weakness 2023

Tipton Independent School District #8

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The Tipton School District will immediately implement the following controls to assure that the district has adequate internal controls in place should any future expenditures of federal funds for Capital Projects be made. The district will review the Federal Procurement and contractor requirements...

The Tipton School District will immediately implement the following controls to assure that the district has adequate internal controls in place should any future expenditures of federal funds for Capital Projects be made. The district will review the Federal Procurement and contractor requirements prior to submitting documents to use Federal Funds for Capital Projects. The district will provide training to staff to ensure compliance with all Federal Program Procurement including compliance with the Davis-Bacon Act (prevailing wage rate) requirements, and reviewing weekly certified payroll reports from the contractor or subcontractor. The district will ensure that all items are posted at the work site to confirm compliance. This corrective action plan will go into effect by March 11, 2024.

View Audit 296205

Finding 382592 (2023-005)

Material Weakness 2023

Portage Township Schools

IN

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

Finding 2023-005 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Linda Williams Contact Phone Number: 219-764-6209 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The PTS Office of Grants and Assessmen...

Finding 2023-005 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Linda Williams Contact Phone Number: 219-764-6209 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The PTS Office of Grants and Assessments will collaborate with the PTS Finance Office to establish a system of internal controls and separation of duties to ensure a thorough review prior to the submission of the Annual ESSER Data Report. Anticipated Completion Date: April 2024

View Audit 296149

Finding 382583 (2023-006)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.404

DOC will institute internal controls to review and monitor, on a quarterly basis, medical costs billed from the pharmaceutical vendor to ensure the billing is consistent with contract language. The review will be done by a Fiscal Management Specialist (FMS). The internal control will consist of the...

DOC will institute internal controls to review and monitor, on a quarterly basis, medical costs billed from the pharmaceutical vendor to ensure the billing is consistent with contract language. The review will be done by a Fiscal Management Specialist (FMS). The internal control will consist of the following: - Beginning with the December 2023 invoice, DOC will request fully executed procurement documents from the pharmaceutical contractor to verify acquisition costs. - The current contract language states that pharmaceuticals are billed at actual acquisition costs plus a dispensing fee. Therefore, the FMS will match the acquisition cost for the vendor for a sample of transactions to the invoices received from the vendor. - DOC will conduct this review on the pharmaceutical invoices for March, June, September, and December in each year continually. - DOC will document the review using an excel spreadsheet that has the universe of pharmacy orders by patient – matching the records and recording the date the review was done. All documents will be saved in an internal medical invoice folder. - Reviews will be completed by the last day of the month after the invoice is submitted. - Training on the new process will be done by March 31, 2024. Findings (or lack thereof) will be reported to DDAP by April 30th, July 31st, October 31st, and January 31st of each year via email. - If there are discrepancies, the vendor will be contacted immediately and a true-up will be requested in the next month’s invoices (either a credit or a debit depending on the discrepancy). DOC will continue to utilize PACE to complete full audits on reasonability of drug prices. DOC acknowledges, due to purchasing and distribution practices for the pharmaceutical vendor, Sublocade was not on prior reports. However, in the third and fourth quarter of 2023, Sublocade was added to the quarterly PACE audits for reasonability of drug prices. DOC has spoken with PACE and will now receive all quarterly audits and will be invited to all meetings between PACE and the contracted pharmaceutical vendor to discuss any findings. Anticipated Completion Date: 03/31/2024 Contact Names: Erica Benning, Director, Healthcare Services; Jodilynn Jacob-Byrd, Fiscal Management Specialist

View Audit 296143 Questioned Costs: $1

Finding 382520 (2023-011)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Cash Management Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.305

DEP will ensure appropriate language as per 31 CFR Section 205.33 (a) of the Treasury-State Cash Management Improvement Act (CMIA) to be included in all Delegation Memorandum of Understandings (DMOU) and Letter of Commitments (LOC) for all future Capital Budget Projects to ensure the expenditure of ...

DEP will ensure appropriate language as per 31 CFR Section 205.33 (a) of the Treasury-State Cash Management Improvement Act (CMIA) to be included in all Delegation Memorandum of Understandings (DMOU) and Letter of Commitments (LOC) for all future Capital Budget Projects to ensure the expenditure of federal monies is consistent with the progress of the project. Anticipated Completion Date: Completed Contact Names: Patrick Webb, Director, Bur. of Abandoned Mine Reclamation; Tim Golding, Exec. Assist., Office of Admin. and Management

View Audit 296143

Finding 382482 (2023-012)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Office of Income Maintenance (OIM) Bureau of Operations (BOO) BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card T...

Office of Income Maintenance (OIM) Bureau of Operations (BOO) BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties and will ensure there is coverage for card pinning until 5:00 pm each business day. Also, reminders to be sent to review the OIM EBT Procedural Manual periodically and when updates occur. This will occur by April 1, 2024. 2. All CAOs and district offices will be reminded to maintain adequate security of the EBT cards, card inventory, pinning devices, and ribbons. The EBT office will ensure all offices have two pinning devices and that they are in working order. This will occur by April 1, 2024. 3. OIM mandates annual training for EBT personnel to be completed at the beginning of each year. The training includes reviewing the procedures that safeguard access to the EBT systems. Area managers and staff assistants monitor completion of the training. Also included are the following: a. Review of roles and responsibilities and who may hold a role b. Card maker and pinner coverage for all business hours c. Proper security for EBT cards and associated items d. Timeframes for submitting changes e. Retention timeframes Anticipated Completion Dates: 1, 2 - 04/01/2024; 3 - Completed Contact Name: Jeanette Coulston, Staff Assistant to Director, Bureau of Operations OIM Bureau of Program Support (BPS)/EBT Project Office BPS will take the following actions to address the finding: 1. The EBT Project Office will make updates to the EBT Procedures Manual (Manual) and OIM EPPIC EBT Systems Application form (application) as needed. Notification of updates will be sent to CAO staff via email. This is expected to occur by April 1, 2024. 2. The EBT Program office will provide guidelines for the CAOs to follow when reviewing/updating their written internal procedures for EBT security of card mailings. This is expected to occur by April 1, 2024. 3. The EBT Project Officer will start retraining parties that are responsible for the completion of the EBT Headquarters Card Destruction log. This is expected to occur by April 1, 2024. Anticipated Completion Date: 04/01/2024 Contact Name: Tonya Holloway, Division Director OIM Bureau of Program Evaluation (BPE)/Division of Corrective Action (DCA) BPE will take the following actions to address the finding: The Bureau of Program Evaluation, Division of Corrective Action conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a 3-year rotation to ensure compliance in the execution of documented policies and procedures. BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the Electronic Benefit Transfer Procedures Manual. The current rotation schedule spans FFY 2022- FFY 2024. The new 3-year schedule will begin October 2024. Anticipated Completion Date: October 2024 Contact Name: Amira S. Milikin, Division Director

View Audit 296143 Questioned Costs: $1

Finding 382476 (2023-004)

Material Weakness 2023

North Harrison Community School Corporation

IN

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

Finding 2023-004 – Education Stabilization Fund Wage Rage Requirement Contact Person Responsible for Corrective Action: Administration and Head of Maintenance Contact Phone Number: 812-347-2407 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Superin...

Finding 2023-004 – Education Stabilization Fund Wage Rage Requirement Contact Person Responsible for Corrective Action: Administration and Head of Maintenance Contact Phone Number: 812-347-2407 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Superintendent will review with Grant Coordinator on any building projects where funds are allocated. Anticipated Completion Date: On going

View Audit 296134

Finding 382468 (2023-002)

Material Weakness 2023

North Harrison Community School Corporation

IN

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

Auditee Contact Person: Paula Powers Title of Contact Person: Food Service Coordinator Phone Number: 812 347-3905 Findings 2023-002-Child Nutrition Cluster-Eligibility Views or Responsible Official: We concur with the findings. Description of Corrective Action Plan: With future processi...

Auditee Contact Person: Paula Powers Title of Contact Person: Food Service Coordinator Phone Number: 812 347-3905 Findings 2023-002-Child Nutrition Cluster-Eligibility Views or Responsible Official: We concur with the findings. Description of Corrective Action Plan: With future processing of free and reduced applications, the Food Authority will process the application. A second person will review and sign the application in order to maintain proper checks and balances. Anticipated Completion Date: March 2024

View Audit 296134

Finding 382362 (2023-001)

None 2023

Seton Hill University

PA

Student Financial Aid Eligibility Material Weakness § 200.516

Finding 2023-001: Student Financial Assistance Cluster, Department of Education Programs Program Name: Federal Direct Student Loans CFDA Numbers: 84.268 Corrective Action Plan: The University will update written procedures to clearly identify a step to manually do enrollment testing following all c...

Finding 2023-001: Student Financial Assistance Cluster, Department of Education Programs Program Name: Federal Direct Student Loans CFDA Numbers: 84.268 Corrective Action Plan: The University will update written procedures to clearly identify a step to manually do enrollment testing following all conferral of degrees. For those regularly scheduled graduation periods and following the submission of both the degree and last of term enrollment files, we will randomly sample 10% of graduated students and manually verify their statuses. For degrees conferred outside of the regularly scheduled graduation periods, each record will be manually verified. This will ensure recorded graduation records will be verified within the National Student Clearinghouse to ensure alignment between degree history and enrollment history. The error was found to be a bug in the reporting software that happened in the current fiscal year. The University’s processes in previous years were correct as this error was not present. Completion Date: Estimated March 2024

View Audit 296043

Finding 382353 (2023-006)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Numbe...

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Bajmakovich, Principal Calumet HS Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cbajmakovich@lakeridgeschools.net Condition: 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 Annual Report Card, High School Graduation compliance requirement. Context: One individual was involved in collecting the High School student documentation for withdrawal, reviewing the documentation, and removing the student from the cohort. Other review of knowledgeable individual was not documented to ensure all students that were removed from the graduation cohort, had the appropriate documentation to do so. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The high school principal shall review and approve withdrawal documentation collected by the registrar prior to the removal of the student from the graduation cohort. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382351 (2023-005)

Material Weakness 2023

Lake Ridge Schools

IN

Internal Control / Segregation of Duties Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numb...

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numbers: S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Regin Johnson, Title I Director Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net Condition: This finding addresses two issues. First, 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 Eligibility compliance requirement. Second, The School Corporation has established a process of receiving and reviewing the listing of students from the Private Schools in order to be entered into the Title I application. However, the internal controls were determined not effective since the School Corporation only requested to receive eligible students listing and not enrolled students. Context: The School Corporation has not established a process of review of the Eligibility Summary in the Title I application for the student enrollment and poverty. Real time report October 1 count is used for the eligibility summary in the Title I application. Additionally, the examiner could not determine if the enrolled private school number was correct because the School Corporation did not request the information. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will review and sign off on the Real Time October 1 report to ensure that the student enrollment and poverty numbers reconcile with what is submitted in the Eligibility Summary. Additionally, the Title I Director will solicit both eligible and total enrollment figures from private schools that wish to participate in Title I. Anticipated Completion Date: The Corrective Action will be implemented immediately and completed upon the filing of the next Real Time report and Eligibility Summary.

View Audit 296034

Finding 382343 (2023-004)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistanc...

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Chris Akers, Treasurer Contact Phone Number and Email Address: (219) 838-1819 cakers@lakeridgeschools.net Condition: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the monthly sponsor claim for reimbursement. Context: School Food Authority’s (SFA) and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. The Food Service Management Company employed Food Service Director prepared the monthly claim for reimbursement on the Indiana Department of Education Child Nutrition Program website based on meal count reports from the point-of-sale system. The School Corporation did not implement a system of internal control to ensure what was claimed for reimbursement agreed to the point-of-sale system meal count reports. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Before the monthly claim for reimbursement is submitted by the FSMC, the Treasurer will reconcile the claim with the meal count report generated by the point-of-sale system. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382322 (2023-004)

Material Weakness 2023

Board of Education Baltimore County

MD

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

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – ...

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24) 211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22) 221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22) Compliance Requirement: Special Test Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation to support student withdrawals and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BCPS conducts regular training with the school-based staff that maintain this related student documentation. The training will include updates on collecting and maintaining written documentation to meet the requirements for removing a student form the cohort. Name(s) of the contact person(s) responsible for corrective action: Dr. Kim Ferguson, Executive Director of Student Support Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382273 (2023-004)

Material Weakness 2023

Rensselaer Central 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: 84.425U Pass-Through Entit...

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: 84.425U 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 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 which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the corrective action plan which will be implemented by June 30, 2024.

View Audit 295986

Finding 382253 (2023-004)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or de...

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports—a total of six reports. However, the School Corporation failed to submit all six required reports. We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: The transition in the Corporation’s Business Manager position resulted in a failure to properly identify and train the person responsible for submitting final expenditure reports for ESSER grants. The Business Manager will prepare the final expenditure reports, and the Grant Specialist will review and compare the report to the ledger to verify that it is correct. After the review, the Business Manager will submit the final expenditures reports. Additionally, the Business Manager and Grant Specialist have developed a shared calendar that includes all report due dates. Anticipated Completion Date: This corrective action plan was implemented beginning February 2024 and will be implemented moving forward.

View Audit 295985

Finding 382243 (2023-005)

Material Weakness 2023

The University of Chicago

IL

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s w...

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s website. Implementation Date: March 6, 2024 Contact Person: Amanda Fijal

View Audit 295975

Corrective Action Plans

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