Corrective Action Plans

Finding 11521 (2023-001)

Material Weakness 2023

CA

HUD Housing Programs Material Weakness Special Tests & Provisions

The Organization is in the process of opening a new residual receipts account. The Organization has recently established a procedure whereby on the 25th of every month a transfer occurs. Controls to ensure such transfers are appropriate have also been established.

View Audit 15365

Finding 11178 (2023-003)

Material Weakness 2023

Cumberland Memorial Hospital, Inc.

WI

Material Weakness Reporting Internal Control / Segregation of Duties

Recommendation – We recommend that all accounts be reconciled and adjustments be posted to the accounting records on a quarterly basis, at a minimum. Management’s Response – The Hospital will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the ...

Recommendation – We recommend that all accounts be reconciled and adjustments be posted to the accounting records on a quarterly basis, at a minimum. Management’s Response – The Hospital will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditors.

View Audit 14986

Finding 11176 (2023-001)

Material Weakness 2023

Cumberland Memorial Hospital, Inc.

WI

Internal Control / Segregation of Duties Material Weakness Reporting

Recommendation – We recommend management and those charged with governance continue to evaluate whether to accept the degree of risk associated with this condition because of cost or other considerations. Management’s Response – The Hospital does not have the resources and staff to prepare the finan...

Recommendation – We recommend management and those charged with governance continue to evaluate whether to accept the degree of risk associated with this condition because of cost or other considerations. Management’s Response – The Hospital does not have the resources and staff to prepare the financial statements and notes but will continue to oversee the auditor’s services and review and approve the financial statements and notes.

View Audit 14986

Finding 10980 (2023-002)

Material Weakness 2023

Western Oregon University

OR

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

Finding 2023-002 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Gramm-Leach-Bliley Act (GLBA) – Student ...

Finding 2023-002 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Gramm-Leach-Bliley Act (GLBA) – Student Information Security Type of Finding: Material Weakness in Internal Controls Finding Summary: During testing over GLBA compliance, it was noted that the University had not updated the information security program and was missing aspects of the required nine elements. Responsible Individuals: Kella Helyer, Director of Financial Aid (DFA) and Michael Ellis, Assistant Director of University Computing Solutions (AD UCS) Corrective Action Plan: Management agrees with this finding. See the GLBA Draft Corrective Action Plan table below. Anticipated Completion Date: See the attached GLBA Draft Corrective Action Plan table below: GLBA documentation 314.4 Reference What WOU will do Complete by Date Who will do it Completion Date Document full status of 314.4 4/1/24 AD UCS a Complete b Update our CIS18 controls - aka InfoSec Program 7/1/24 AD UCS b.2 Risk assessment for on-prem servers with FinAid* data 4/1/24 AD UCS, Lead Windows Admin, Warehouse Programmer c.1 Document current processes and access controls 4/1/24 AD UCS, DFA c.2 Document current information, including Business Office 12/20/23 Financial Aid Accountant 12/13/23 c.3 Encrypte NetApp volumes, and ensure encryption on DB links 8/1/24 AD UCS, Lead Windows Admin, Warehouse Programmer c.4 Assess warehouse & BannerRPT 7/1/24 AD UCS, Warehouse Programmer, Operating Systems/Security Analyst c.5 Complete c.6 Review PowerFAIDS electronic files for purging Review paper files for purging Have Business Office review files for purging 8/1/24 DFA c.7 Audit FinAid data access upon addition to Warehouse 8/1/24 Warehouse Programmer and/or Operating Systems/Security Analyst c.8 Add access logs to WOU central logging system 8/1/24 AD UCS, Web & Banner Programmer d.2.i Annual pentest by Campus Guard 2/29/24 AD UCS e Complete f Document all 3rd party providers who interact with FinAid data. Audit yearly 8/1/24 DFA, AD UCS g Complete h Complete i Verbal report given in 2023. Anticipated written report to Board on 7/1/24 7/1/24 AD UCS

View Audit 14816

Finding 10974 (2023-001)

Material Weakness 2023

Western Oregon University

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: M...

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: Material Weakness in Internal Controls Finding Summary: During the testing of compliance for Enrollment Reporting, there were instances where the National Student Loan Data System (NLSDS) did not reflect accurate or timely reporting of a student’s change in enrollment status. While records were submitted accurately and timely to the National Student Clearinghouse, those records were not reflected in NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: Management agrees with this finding. The initial response to this request for data did not include the active and inactive enrollment levels for the requested sample students. Initially it appeared that there was a systems issue between the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS); however, upon further investigation and in conversation with NSLDS, the required information was found and subsequently provided to Eide Bailly on December 1, 2023. The resolution of this request for data was resolved but after the final audit report was submitted. Anticipated Completion Date: Completed December 1, 2023

View Audit 14816

Finding 10967 (2023-001)

Material Weakness 2023

Center for Advocacy for the Rights and Interests of the Elderly

PA

Reporting Material Weakness

Center for Advocacy for the Rights and Interests of the Elderly (CARIE) respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: Year ending June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding...

Center for Advocacy for the Rights and Interests of the Elderly (CARIE) respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: Year ending June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—SINGLE AUDIT MATERIAL WEAKNESS 2023‐001 Internal Control over Compliance and Compliance (Reporting) Recommendation: We recommend management evaluate their internal controls surrounding the major federal programs to ensure compliance with the reporting requirements of their grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will create a reporting calendar with due dates to be reviewed monthly. The Finance Manager will prepare the reports and the Executive Director will review the reports prior to submission. Names of contact responsible for corrective action: Whitney Lingle, Executive Director. Planned completion date for corrective action plan: June 30, 2024. If the Department of Health and Human Services has questions regarding this plan, please call Whitney Lingle at (267) 546‐3434.

View Audit 14811

Finding 10949 (2023-001)

Material Weakness 2023

Lake County Community College District

OH

Cash Management Subrecipient Monitoring Material Weakness § 200.305

Condition: The College drew down an estimated amount of cash prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: There is not anymore HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future, the C...

Condition: The College drew down an estimated amount of cash prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: There is not anymore HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future, the College will follow the three-day drawdown rules for cash disbursements. Contact person responsible for corrective action: Tom Reynolds College Treasurer Anticipated Completion Date: 12/14/2023 as soon as possible moving forward

View Audit 14778

Finding 10948 (2023-001)

Material Weakness 2023

South Redford School District

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Special Tests & Provisions

Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovatio...

Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovation, or construction contracts that are over $2,000 and use laborers and mechanics, must meet Davis-Bacon prevailing wage requirements. The School District expended ESSER funds that related to repairs and renovations; however, the prevailing wage requirement was not included in any of the related contracts' language, nor did the School District receive or review the certified payroll reports from any of the contractors. Planned Corrective Action: As it pertains to the use of ANY Federal funds for construction projects in the South Redford School District (SRSD), when said funds will be used to compensate for labor for any construction project: We must stipulate in all RFP’s, Davis-Bacon requirements for prevailing wages as it relates to the use of laborers and mechanics, for all projects over $2,000. All responses to RFP’s must: 1. Acknowledge the Davis Bacon prevailing wage requirement; 2. All bid pricing must reflect prevailing wage requirements; 3. Bid recipients must have a process in place for reporting their compliance to the prevailing wage requirement and submit documentation along with all invoices, be it directly to SRSD or to the construction management firm, who will then include said documentation with their backup and invoices to SRSD. Contact person responsible for corrective action: Linda Earl, Finance Director Anticipated Completion Date: November 1, 2023

View Audit 14775

Finding 10938 (2023-009)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Material Weakness Reporting

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and is committed to establishing and enforcing internal control procedures for compliance with performance reporting requirements. We will work to improve our oversight and compliance in this regard. o A compliance team wil...

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and is committed to establishing and enforcing internal control procedures for compliance with performance reporting requirements. We will work to improve our oversight and compliance in this regard. o A compliance team will be appointed to ensure that the agency adheres to all compliance requirements. o The compliance team will work closely with the PM to coordinate and delegate tasks to collect the data needed to complete the report. o The compliance team will assist in creating a process for maintaining documentation to support what is reported. o The compliance team will document the level of compliance in which internal controls are followed and report results to program and agency leadership along with recommendations for improvement. Internal audits will be conducted in preparation for external audits. • Anticipated Completion Date: The process will be implemented on January 3, 2024, and will continuously be reviewed and updated to align with best practices.

View Audit 14751

Finding 10934 (2023-005)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification appli...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification application and gather the necessary documentation. o The recertification application and documentation will be forwarded to the PM for review and approval. o The PM will review the form, sign, and date it after confirming that all information is accurate and complete. o If there are inaccuracies and/or missing information, the form will be returned to the ES who will follow up with the host site to obtain the missing information or correct the inaccuracy. o Steps 1 and 2 will be repeated. o The QI department will conduct quarterly file reviews to determine if processes are being followed. Re-certification was modified during the pandemic out of an abundance of caution for the participants in the program. Those who had access to the internet were asked to email their documentation, and those who didn’t were asked to mail theirs. A drive through recertification process was implemented when COVID restrictions eased, and participants were asked to remain in their vehicles while SCSEP employment specialists obtained their recertification documentation. Many participants do not have transportation and were not able to participate in the drive through. The most recent, pre-pandemic certification information for participants was used for those who were not able to attend the drive through or virtual recertification processes. CWI did not end COVID protocols until Q4 of PY2022 (April 1, 2023). Alternative recertification methods were used to comply with the protocols. With the end of the COVID protocols and restrictions, we have reinstituted the in-person/face-to-face recertification process required by the funder. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded.

View Audit 14751

Finding 10933 (2023-004)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing whi...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded. o A SCSEP Employment Specialist will meet with participants to complete the recertification application and gather the necessary documentation. o The recertification application and documentation will be forwarded to the PM for review and approval. o The PM will review the form, sign, and date it after confirming that all information is accurate and complete. o If there are inaccuracies and/or missing information, the form will be returned to the ES who will follow up with the host site to obtain the missing information or correct the inaccuracy. o Steps 1 and 2 will be repeated. o The QI department verify eligibility and recertification documents are within the file during their quarterly reviews to determine if processes are being followed.

View Audit 14751

Finding 10931 (2023-002)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

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

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o After the PM has verified that timesheets are accurate and complete, they will be scanned and s...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o After the PM has verified that timesheets are accurate and complete, they will be scanned and sent to Payroll for processing. o Payroll will maintain a copy of the email providing the documents and will comply with federal guidelines of storing records for a period after the close of the grant. o The PM will file a hard copy of the timesheets in the SCSEP office. o The files will be kept in the office until completion of quarterly reviews for the fiscal year by the QI department, and then they will be transferred to the agency’s long-term storage facility for files. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded

View Audit 14751

Finding 10850 (2023-001)

Material Weakness 2023

Rogue Community College

OR

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

Finding: 2023-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.238, 84.033 Initial Fiscal Year Finding Occurred: 2023 Finding Summary: During the testing over student information security, it was determined the College...

Finding: 2023-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.238, 84.033 Initial Fiscal Year Finding Occurred: 2023 Finding Summary: During the testing over student information security, it was determined the College did not have all nine elements of the new GLBA requirements in place with written policies and documented follow through protocols. Responsible Individuals: Jeremy Taylor, Chief Information Officer and Josh Ogle, former Chief Information Officer. Corrective Action Plan: : Subsequent to the June 30, 2023 finding the College has already implemented or updated process to ensure student information security safeguards are in place. This includes a Security Information and Event Management (SIEM) solution fully equipped to log all user access within our network and capture detailed information about user activities on the network and their individual PCs. Additionally, it comprehensively monitors and collects data on all network switch and firewall activity. This data is stored and analyzed on-premises and reported to Sophos for enhanced monitoring through their Managed Detection and Response (MDR) service. Rogue Community College has extended its security measures by integrating our Microsoft 365 tenant and Okta with Sophos, enabling 24/7 user activity monitoring across these platforms. These integrations and vigilant monitoring practices demonstrate our unwavering commitment to robust security and adherence to regulatory compliance standards, ensuring meticulous surveillance of authorized user actions and safeguarding against unauthorized access. We have contracted with Eide Bailly’s Technology Consulting group. The Statement of Work focuses on creating an Incident Response Plan which is leading to updated policies and procedure documentation. We are working on a GLBA specific policy as well. Anticipated Completion Date: As of December 2023, we believe we have the minimum safeguards in place. By early 2024, a written GLBA specific policy including how we document follow through on monitoring efforts will be in place.

View Audit 14543

Finding 10826 (2023-007)

Material Weakness 2023

Washoe County

NV

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Date: 12/26/2023 Division: Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-007 Finding: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Corrective Act...

Date: 12/26/2023 Division: Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-007 Finding: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Corrective Action Taken or To Be Taken: The County will continue to work with the departments on costs associated with grant events. This will include reviewing project costs associated with grants on a quarterly basis and making the necessary revenue adjustments. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Cathy Hill, Comptroller Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: 775-328-2552 Email: chill@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.26

View Audit 14489

Finding 10825 (2023-006)

Material Weakness 2023

Washoe County

NV

Reporting Material Weakness

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-006 Finding: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirem...

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-006 Finding: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Corrective Action Taken or To Be Taken: Internal controls will be created for reporting to the Department of Treasury for capital expenditures to include written justification. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Gabrielle Enfield, Community Reinvestment Manager Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: (775) 328-2552 Email: genfield@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10821 (2023-009)

Material Weakness 2023

Washoe County

NV

Internal Control / Segregation of Duties Eligibility Material Weakness

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-009 Finding: The Office of the County Manager did not have internal controls established over the determination of eligibility of the participants in the ...

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-009 Finding: The Office of the County Manager did not have internal controls established over the determination of eligibility of the participants in the Emergency Rental Assistance Program. Corrective Action Taken or To Be Taken: Internal controls will include determining the eligibility of the participants in the Emergency Rental Assistance Program. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Cathy Hill, Comptroller Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: (775) 328-2552 Email: chill@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10820 (2023-008)

Material Weakness 2023

Washoe County

NV

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

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-008 Finding: The Office of the County Manager did not have internal controls established over the direct payments made to participants of the Emergency Re...

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-008 Finding: The Office of the County Manager did not have internal controls established over the direct payments made to participants of the Emergency Rental Assistance Program. Corrective Action Taken or To Be Taken: Internal controls will be monitored/created for future awards. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Cathy Hill, Comptroller Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: (775) 328-2552 Email: chill@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10799 (2023-003)

Material Weakness 2023

City of Swartz Creek, Michigan

MI

Reporting Subrecipient Monitoring Material Weakness § 200.502 § 200.508 § 200.510

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared as it originally included expenditures that were improperly excluded from the SEFA for the year ended June 30, 2022. Planned Corrective Action: Additional Supervisory Review of Expenditures Contact person responsible fo...

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared as it originally included expenditures that were improperly excluded from the SEFA for the year ended June 30, 2022. Planned Corrective Action: Additional Supervisory Review of Expenditures Contact person responsible for corrective action: Deanna Korth Anticipated Completion Date: 09/30/2023

View Audit 14451

Finding 10669 (2023-003)

Material Weakness 2023

City of Port Huron, Michigan

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.319 § 200.320

Condition: We identified 4 expenditures, during testing, that the City did not verify were in accordance with their internal procurement policy, pursuant to 2 CFR 200.319 and 200.320 prior to entering into contracts with award funds. Planned Corrective Action: Procedures have already been put into p...

Condition: We identified 4 expenditures, during testing, that the City did not verify were in accordance with their internal procurement policy, pursuant to 2 CFR 200.319 and 200.320 prior to entering into contracts with award funds. Planned Corrective Action: Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City of Port Huron management and staff will continue to improve communication with and between departments to ensure all staff understands the purchasing policy. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

View Audit 14333

Finding 10668 (2023-002)

Material Weakness 2023

City of Port Huron, Michigan

MI

Subrecipient Monitoring Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.212 § 200.318

Condition: We noted during testing that the City had omitted a subrecipient from its search to ensure that the subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR section 180.300. Planned Corrective Action: Procedures have already been put into place to ensure that each...

Condition: We noted during testing that the City had omitted a subrecipient from its search to ensure that the subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR section 180.300. Planned Corrective Action: Procedures have already been put into place to ensure that each new contractor is not on the Federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the Federal list and none were suspended and/or debarred. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

View Audit 14333

Finding 10659 (2023-002)

Material Weakness 2023

Marshall Public Schools

MI

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three o...

Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three of the contracts selected for testing that were subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls. The District did not follow federal requirements to include the prevailing wage rate provision in its contract. Auditor Recommendation: We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained. Corrective Action: District officials will ensure that construction contracts contain these requirements during the bidding and/or proposal process. Responsible Person: Rebecca Jones, Superintendent and Tara Newman, Business Manager Anticipated Completion Date: June 30, 2024

View Audit 14327 Questioned Costs: $1

Finding 10441 (2023-005)

Material Weakness 2023

Solano Community College District

CA

Material Weakness Internal Control / Segregation of Duties § 200.303

2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Dir...

2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Director of Information Security and Special Projects position with an Interim placement effective February 1, 2024, to provide leadership in developing, implementing, and maintaining the District’s Information Security Policy including the seven elements required by the Gramm-Leach-Bliley Act. Names of the contact person responsible for corrective action: James “Kimo” Calilan, Director – Information Systems Planned completion date for corrective action plan: April 30, 2024

View Audit 14106

Finding 10437 (2023-004)

Material Weakness 2023

Solano Community College District

CA

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

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures use...

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.

View Audit 14106

Finding 10392 (2023-003)

Material Weakness 2023

Alpha One

ME

Questioned Costs HUD Housing Programs Material Weakness

Management will seek approval from the funding Agency for the questioned costs and return funds if costs are not approved.

View Audit 14054 Questioned Costs: $1

Finding 10348 (2023-005)

Material Weakness 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

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