Corrective Action Plans

Finding 48757 (2022-001)

Significant Deficiency 2022

Impact Washington

WA

Questioned Costs Allowable Costs / Cost Principles

August 7, 2023 IMPACT WASHINGTON Schedule of Findings and Questioned Costs For the Year Ended December 31, 2022 Finding Number 2022-001 Corrective Action Plan: Contact Person(s): Eddie Roldan Impact Washington?s will follow the next steps: Task: Anticipated completion date: Configure a report t...

August 7, 2023 IMPACT WASHINGTON Schedule of Findings and Questioned Costs For the Year Ended December 31, 2022 Finding Number 2022-001 Corrective Action Plan: Contact Person(s): Eddie Roldan Impact Washington?s will follow the next steps: Task: Anticipated completion date: Configure a report that includes parallel detail that allows to match GL and Project coding. Add the report scrutiny to Month End Close check list. Done Revamp Finance Force (FF) Expense Report entry screens ? make it more user friendly. August 30, 2023 Sponsor staff annual best practice refresher trainings centered on IW?s accounting policies & procedures December 31, 2023 Reconfigure FF system, add and populate missing filtering fields to allow group reporting, eliminate manual filtering. December 31, 2023 Impact Washington considers the above steps sufficient and adequate to close the gaps in the coding of transactions that may have permitted unallowable costs to post to grants for YE2022. These steps will remedy the lapse in effectiveness experienced by Impact Washington?s internal controls over allowable costs.

View Audit 51340 Questioned Costs: $1

Finding 48714 (2022-004)

None 2022

Lorien Homes, Inc.

MD

Questioned Costs HUD Housing Programs Cash Management

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all residual receipts compliance requirements. Action Taken: The Organization will request approval from HUD to pay back the excess residual receipt balance.

View Audit 49550 Questioned Costs: $1

Finding 48713 (2022-003)

None 2022

Lorien Homes, Inc.

MD

Questioned Costs Reporting

Recommendation: Staff training should be performed to bring the staff up to date with the implementation of all replacement reserve compliance requirements. Action Taken: The Organization will insure that all missed and future monthly deposits to the reserve for replacement account are made in accor...

Recommendation: Staff training should be performed to bring the staff up to date with the implementation of all replacement reserve compliance requirements. Action Taken: The Organization will insure that all missed and future monthly deposits to the reserve for replacement account are made in accordance with their required monthly amount.

View Audit 49550 Questioned Costs: $1

Finding 48711 (2022-001)

Material Weakness 2022

Lorien Homes, Inc.

MD

Questioned Costs HUD Housing Programs Reporting

Recommendation: In conjunction with Lorien Homes, Inc. and their local HUD field office, it was determined that the related party should invoice the Organization for project expenses on a monthly basis. In turn, Lorien Homes, Inc. should pay the invoice amount on a monthly basis. Action Taken: The a...

Recommendation: In conjunction with Lorien Homes, Inc. and their local HUD field office, it was determined that the related party should invoice the Organization for project expenses on a monthly basis. In turn, Lorien Homes, Inc. should pay the invoice amount on a monthly basis. Action Taken: The auditors have worked with the auditee in conjunction with their local HUD field office to determine a course of action. All parties agreed with the recommendation to avoid unauthorized distributions.

View Audit 49550 Questioned Costs: $1

Finding 48649 (2022-002)

Material Weakness 2022

County of Rockingham, Virginia

VA

Questioned Costs Subrecipient Monitoring Material Weakness § 200.326

Identifying Number: 2022-002: Special Test ? Wage Rate Requirement Finding: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontract comply with those ...

Identifying Number: 2022-002: Special Test ? Wage Rate Requirement Finding: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontract comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). The School Board did not have adequate internal controls in place to verify this compliance requirement for this particular award prior to funds being spent. School Board employees were unaware the Wage Rate Requirement was applicable for this program. Corrective Action Taken or Planned: The policy on the Uniform Grant Guidance for federal grants will be updated to be more clear on the requirements. Also, the CFO will communicate the requirements to ensure all employees responsible for federally sourced funds are adequately trained. Anticipated Implementation Date: March 1, 2023 Responsible person: Cheryl Mast

View Audit 47051 Questioned Costs: $1

Finding 48646 (2022-004)

Material Weakness 2022

Madison District Public Schools

MI

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Of the 21 payroll transactions selected for testing, the District was unable to provide documentation for eight of those charges. O...

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Of the 21 payroll transactions selected for testing, the District was unable to provide documentation for eight of those charges. Of the 21 payroll transactions selected for testing, the District identified that one individual had been charged to the grant in excess of their actual payroll for the year. As a result of this condition, the District does not have appropriate payroll support for nine of the transactions charged to the grant. Auditor Recommendation: We recommend the District limit payroll charged to federal programs to costs that are supported by documentation that is allowable under federal cost principles and its own policies and procedures. Corrective Action: The District will work with its auditors to ensure that future charges to grants are for allowable costs and supported by documentation as prescribed under Uniform Guidance. Responsible Person: Lawrence Miller (Director of Finance and Business Operations) Anticipated Completion Date: June 30, 2023

View Audit 46061 Questioned Costs: $1

Finding 48645 (2022-003)

Material Weakness 2022

Madison District Public Schools

MI

Questioned Costs Allowable Costs / Cost Principles

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Evidence of an independent review was not documented for 16 out of 40 disbursements selected for testing. The District could not pr...

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Evidence of an independent review was not documented for 16 out of 40 disbursements selected for testing. The District could not provide any supporting documentation for costs charged on 3 out of 40 disbursements selected for testing. The District is at increased risk of unallowable costs being charged to federal programs without being detected by its internal controls. Auditor Recommendation: We recommend the District follow its internal control policies and procedures that require independent review of all disbursement transactions. Corrective Action: The District will work with its auditors to ensure that future charges to grants are for allowable costs and supported by documentation as prescribed under Uniform Guidance. Responsible Person: Lawrence Miller (Director of Finance and Business Operations) Anticipated Completion Date: June 30, 2023

View Audit 46061 Questioned Costs: $1

Finding 48608 (2022-010)

Material Weakness 2022

State of Ohio

OH

Questioned Costs Allowable Costs / Cost Principles Eligibility

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments ma...

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

View Audit 52604 Questioned Costs: $1

Finding 48605 (2022-009)

Significant Deficiency 2022

State of Ohio

OH

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.1

Corrective Action Plan: The following actions will be taken: ? Work with the Ohio Department of Rehabilitation and Correction to obtain more accurate incarceration dates. Currently we are not receiving the dates the claimant is incarcerated in a facility. We are currently receiving their expected ...

Corrective Action Plan: The following actions will be taken: ? Work with the Ohio Department of Rehabilitation and Correction to obtain more accurate incarceration dates. Currently we are not receiving the dates the claimant is incarcerated in a facility. We are currently receiving their expected release date which does not meet the needs of the office. ? We do not believe there is a need to work with the Department of Health as there has been no discrepancy with the accuracy of the data provided. ? We will create a process to create a weekly review file and save those results for review and evaluation purposes for both death and incarceration records. ? We will create a procedure to investigate the results of the death and incarceration files consistent with our existing procedures to investigate similar situations. Anticipated Completion Date for Corrective Action: January 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

View Audit 52604 Questioned Costs: $1

Finding 48558 (2022-011)

None 2022

State of Ohio

OH

Questioned Costs Eligibility Subrecipient Monitoring

Corrective Action Plan: ? The program office will reach out to the county to advise of the error and ensure it has been corrected. ? The county will be reminded of the proper income entry and explain their plan to ensure it doesn?t happen again. ? The county will need to confirm they have started th...

Corrective Action Plan: ? The program office will reach out to the county to advise of the error and ensure it has been corrected. ? The county will be reminded of the proper income entry and explain their plan to ensure it doesn?t happen again. ? The county will need to confirm they have started the overpayment process for any benefit overissued. Anticipated Completion Date for Corrective Action: February 2023 Contact Person Responsible for Corrective Action: Betsy Suver, Bureau Chief, Ohio Department of Job and Family Services 30 East Broad Street, Columbus OH 43215 Phone Number: 614-387-8302, E-Mail Address: Betsy.Suver@jfs.ohio.gov

View Audit 52604 Questioned Costs: $1

Finding 48556 (2022-001)

Material Weakness 2022

Dean College

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Allowable Costs ? COVID 19 Federal Emergency Management Agency Disaster Grants ? Public Assistance, Assistance Listing Number 97.036, Department of Homeland Security Condition A cost item was submitted twice within the applications of FEMA funds and funded by FEMA. Views of Responsible Officials an...

Allowable Costs ? COVID 19 Federal Emergency Management Agency Disaster Grants ? Public Assistance, Assistance Listing Number 97.036, Department of Homeland Security Condition A cost item was submitted twice within the applications of FEMA funds and funded by FEMA. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. FEMA was notified about the cost item and provided the College with instruction related to the return of funds. In addition, all future applications will be reviewed by a second staff member to prevent submission of a duplicate item. Responsible Official: Kathleen McGuire, Vice President for Financial Services Expected Completion Date: December 1, 2022 Summary Schedule of Prior Audit Findings None noted.

View Audit 52542 Questioned Costs: $1

Finding 48553 (2022-001)

Material Weakness 2022

Shelton School District No. 309

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Shelton School District No. 309 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Shelton School District No. 309 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-01 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement and restricted purpose requirements. Name, address, and telephone of District contact person: Brenda Trogstad, Assistant Superintendent of Finance & Operations Shelton School District No. 309 700 South 1st Street Shelton, WA 98584 Corrective action the auditee plans to take in response to the finding: Shelton School District does not concur with the audit finding being issued by the State Auditor?s Office. The district does agree that internal controls and processes could be improved. It is the district?s understanding the almost every district in Washington State that received this grant has an audit finding. The district believes there was not clear guidance on processes and requirements. The school district did not receive any of the federal funds directly. The vendors that we purchased the laptops, hotspots, and bus wi-fi were responsible for applying for the funds from the federal government directly. The district is being held accountable for the actions of the vendor which we did not have control over. The district does not agree that these should be questionable costs since the district did not apply for or receive any funds directly. The ECF laptops were procured using the USAC site and procedures. The district filed a form 370 indicating the devices we wanted and we received quotes from two vendors. One vendor?s quote was related to a cooperative purchasing agreement contract. The district chose to purchase from that vendor as they included a white glove service to place asset tags on the devices, enroll them in our admin console and they also came with an extended warranty that includes accidental damage protection. The district?s IT Operations Manager was working with school principals to come up with the best method to determine high need students in a fair and equitable manner. The laptops will be distributed early in the 2023-24 school year once the plan is in place and all parties agree with the process. Anticipated date to complete the corrective action: Prior to January 1, 2024.

View Audit 50013 Questioned Costs: $1

Finding 48529 (2022-003)

Significant Deficiency 2022

Mountain View School District

AR

Questioned Costs Allowable Costs / Cost Principles Special Tests & Provisions

Finding Number: 2022-003 Finding. The district purchased and requested reimbursement totaling $7,415 for devices purchased for the sole purpose of anticipated loss or breakage which did not meet the definition of eligible equipment. Corrective Action Plan: The district will seek gui...

Finding Number: 2022-003 Finding. The district purchased and requested reimbursement totaling $7,415 for devices purchased for the sole purpose of anticipated loss or breakage which did not meet the definition of eligible equipment. Corrective Action Plan: The district will seek guidance from the Federal Communications Commission on how the remaining devices should be used and implement proper controls over the program. Anticipated Completion Date: June 30, 2023

View Audit 48527 Questioned Costs: $1

Finding 48528 (2022-002)

Significant Deficiency 2022

Mountain View School District

AR

Questioned Costs Allowable Costs / Cost Principles Special Tests & Provisions

Finding Number: 2022-002 Finding. Unallowable costs totaling $2,800 for seven devices that were provided to school board members, who do not provide educational services to students. Response Corrective Action Plan: The district will seek guidance from the Federal Communications Commission on ho...

Finding Number: 2022-002 Finding. Unallowable costs totaling $2,800 for seven devices that were provided to school board members, who do not provide educational services to students. Response Corrective Action Plan: The district will seek guidance from the Federal Communications Commission on how the devices should be used and will implement proper controls over the program. Anticipated Completion Date: June 30, 2023

View Audit 48527 Questioned Costs: $1

Finding 48499 (2022-002)

Material Weakness 2022

Powder River Conservation District

WY

Questioned Costs Matching / Level of Effort / Earmarking

2022-002 Cost Sharing Requirements - Material Weakness i. Contact Person Responsible for Action: District Manager Anita Bartlett ii. Correction Action Planned: The PRCD will insure that district employees receive updated training for OMB requirements of federal grants. 1. Anticipated Completion Date...

2022-002 Cost Sharing Requirements - Material Weakness i. Contact Person Responsible for Action: District Manager Anita Bartlett ii. Correction Action Planned: The PRCD will insure that district employees receive updated training for OMB requirements of federal grants. 1. Anticipated Completion Date: December 31, 2023. iii. Correction Action Planned: The PRCD will insure to confirm the original source of all grant funding, so confusion does not occur when receiving federal grant funding from non-federal sources. 1. Anticipated Completion Date: December 31, 2023. iv. Correction Action Planned: The PRCD will also contact the US Fish and Wildlife Service/WY Game and Fish Department and the USDA-NRCS to discuss the federal-to-federal funding match that occurred within the Emergency Watershed Protection Program during the District's FY 2021-2022 to see what correction actions they agencies would like the District to take. The District will follow the recommendations of the federal agencies. 1. Anticipated Completion Date: June 30, 2023.

View Audit 47009 Questioned Costs: $1

Finding 48491 (2022-002)

Material Weakness 2022

State of Alabama

AL

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

Finding Ref. No. 2022-002 Finding: The Uniform Guidance, 2 CFR 200.303, requires non-Federal entities receiving Federal Awards (i.e., auditee management) to establish and maintain effective internal controls over the Federal Award that provide reasonable assurance that the non-Federal entity is man...

Finding Ref. No. 2022-002 Finding: The Uniform Guidance, 2 CFR 200.303, requires non-Federal entities receiving Federal Awards (i.e., auditee management) to establish and maintain effective internal controls over the Federal Award that provide reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and terms and conditions of the Federal Award. 20 CFR 604.3(a) requires a State to only pay an individual who is able to work and available for work for the week which Unemployment Compensation (UC) is claimed. Based on work performed on unemployment compensation payments at the Alabama Department of Labor, for the period of October 1, 2021, through September 30, 2022, we identified 243 payments, totaling $58,809.00, which were made to 22 deceased claimants. We also identified an additional 186 payments, totaling $42,276.00, which were made to 27 incarcerated claimants. The combined improper payments to deceased or incarcerated claimants total $101,085.00 for the Unemployment Insurance Program. The Alabama Department of Labor did not have internal controls in place which were adequately designed to identify deceased or incarcerated claimants in a timely manner, in order to help prevent and/or detect improper payments. The lack of a well-designed system of internal controls, to identify deceased or incarcerated claimants, could cause the Alabama Department of Labor to continue to pay benefits to claimants who are deceased or incarcerated. Recommendation: The Alabama Department of Labor should establish and maintain effective internal controls to help ensure payments are not made to deceased or incarcerated claimants. Response/Views: We agree with the finding. Corrective Action Planned: ADOL now utilizes IDV through the Integrity Data Hub (IDH) for death crossmatch, giving ADOL the capability to crossmatch all claimants through the IDV. However, the review process is manual at this time. ADOL continues to pursue a fully automated process with the system vendor. ADOL is also working with the Interstate Connection Network (ICON) through the National Association of State Workforce Agencies (NASWA) to implement a match of SSN?s with the Social Security Administration?s Prisoner Update Processing System (PUPS). This will allow records to be checked in a nationwide database not just the State of Alabama. Reason for the Recurrence: The cause of this was due to the workload of pandemic claims and the lack of requirements to provide proof of income and employment. Prior to the pandemic a person had to have wages in order to qualify for benefits, eliminating a deceased person of more than 2 years from being monetarily eligible for benefits. Any remaining claimants that had died would be reported by the employer or through returned mail or a surviving of family member. Any notice of deceased person would be reviewed. With no way to verify whether a person was deceased or not, some did pay benefits. Anticipated Completion Date: ADOL implemented checking claims through IDH June 2022. Netacent, the vendor who maintains ADOL?s unemployment system, anticipates the PUPs project to be fully functioning by December 31,2023. Contact Person(s): Brent Langley, Assistant Unemployment Administrator

View Audit 41985 Questioned Costs: $1

Finding 48488 (2022-001)

Significant Deficiency 2022

Santa Fe Recovery Center, Inc.

NM

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.403 § 200.430

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This...

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

View Audit 53214 Questioned Costs: $1

Finding 48457 (2022-004)

Material Weakness 2022

Rochester Community School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to sta...

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, employee contract, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

View Audit 52598 Questioned Costs: $1

Finding 48435 (2022-001)

Significant Deficiency 2022

Lake Central School Corporation

IN

Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.320

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: ...

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Context: During testing of procurement over the Special Education Cluster, it was noted that the School Corporation did obtain an appropriate number of bids relating to Special Education consultants as required under small purchase procurement guidelines. There were two consultants charged to the Special Education Cluster during the audit period with expenses totaling $147,319. One of these consultants was selected during testing for procurement. The issue impacted both ALN 84.027 and 84.173. No issues were identified when testing suspension and debarment requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Due to the number of students we service with special needs, we often need to contract out for some of our Speech Language Pathology services. We currently have three contractors that provide outstanding services for us and we haven?t annually bid this out since the pool of providers is very small. In the future, we will document the process that we take to try to fill these spots with full time employees, how we request various pathologists from a multitude of vendors, and the decision making process to choose the contractor. We will review the rates provided by other potential contractors and seek School Board approval for whomever is the contracted vendor. Responsible party and timeline for completion: Our Director of Student Services, Rebecca Gromala, will oversee this corrective action plan. It is too late to make this correction for the current 2022-2023 school year. We anticipate this being corrected by September 1, 2023 for the 2023-2024 school year.

View Audit 48256 Questioned Costs: $1

Finding 48419 (2022-001)

Material Weakness 2022

Alive, Inc.

MO

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

Corrective Action Plan Contact Name: Maggie Menefee Corrective Action: ALIVE is seeking an individual with appropriate nonprofit and federal award experience to provide additional oversight Expected Completion Date: December 31, 2022.

View Audit 53779 Questioned Costs: $1

Finding 48384 (2022-015)

Material Weakness 2022

State of New York

NY

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

State Agency: Office of Children and Family Services Single Audit Contact: Bonnie Hahn Title: External Audit Liaison Telephone: 518-486-1034 E-mail Address: Bonnie.Hahn@ocfs.ny.gov Federal Program(s) (ALN # [s]): Social Services Block Grant (93.667) Audit Report Reference: 2022-015 Anticipated Compl...

State Agency: Office of Children and Family Services Single Audit Contact: Bonnie Hahn Title: External Audit Liaison Telephone: 518-486-1034 E-mail Address: Bonnie.Hahn@ocfs.ny.gov Federal Program(s) (ALN # [s]): Social Services Block Grant (93.667) Audit Report Reference: 2022-015 Anticipated Completion Date: 3/31/24 Corrective Action Planned: OCFS Bureau of Financial Operations has set up monitoring activities to review the adequacy of supporting documentation and appropriateness of Title XX claims. Going forward, the annual subrecipient risk assessment will be used to determine a schedule for reviewing the districts. OCFS will review the current monitoring activities performed by various program offices to determine, when considered as a whole, if they are sufficient to address the portion of the finding regarding eligibility and the accuracy of the Post-Expenditure Report.

View Audit 49189 Questioned Costs: $1

Finding 48347 (2022-001)

Material Weakness 2022

Seattle School District No. 1

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Name, address, and te...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Name, address, and telephone of District contact person: Amy Fleming, Accounting Director 2445 3rd Avenue S. Seattle WA 98104 (206) 252-0274 Corrective action the auditee plans to take in response to the finding: The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy ?unmet? need in would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 51: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? Anticipated date to complete the corrective action: December 2023

View Audit 40833 Questioned Costs: $1

Finding 48322 (2022-001)

Material Weakness 2022

Westhaven of Englewood, Ltd.

IL

Questioned Costs HUD Housing Programs Reporting

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: Section 8 Housing Assistance Payments, CFDA 14.195 Recommendation: Management should arrange to transfer the amount due to the residual receipts account as soon as possible. Corrective Actions Taken: Management has acknowledged the findin...

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: Section 8 Housing Assistance Payments, CFDA 14.195 Recommendation: Management should arrange to transfer the amount due to the residual receipts account as soon as possible. Corrective Actions Taken: Management has acknowledged the finding and promised to transfer the amount due to the residual receipts account as soon as possible. Contact: Greg Miller, Management Agent Anticipated Completion Date: June 30, 2023

View Audit 47249 Questioned Costs: $1

Finding 48312 (2022-006)

Significant Deficiency 2022

City of Albuquerque

NM

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.320

2022 ? 006 (Previously 2021-012) Procurement (Significant Deficiency and Noncompliance) Management?s Progress for Repeat Findings: The City plans to review the controls in p...

2022 ? 006 (Previously 2021-012) Procurement (Significant Deficiency and Noncompliance) Management?s Progress for Repeat Findings: The City plans to review the controls in place to ensure that our federal procurement guidelines are clear on City process and the need for retention of proper supporting documentation. In addition, we will also plan to have the SEFA completed well before the deadline to allow sufficient management review and major programs can be identified earlier in the audit process. The additional time will allow City departments to provide requested audit documentation within the Auditor?s deadlines. Management Response: The City respectfully disagrees with the finding. The two exceptions noted above are, on the contrary, examples of good fiscal management by the City. The statewide price agreement and the cooperative education services contract were both competitive. The uniform grant guidance in to ? 200.318(e) below encourages state and local intergovernmental agreements. To foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. In addition, the City did compete the temporary employment services. The request for bids awarded contracts in October 2016. Three (3) years, three (3) months into the five (5) year term of the contract, the first COVID case was reported in the United States and the President declared a public health emergency on January 31. New Mexico and the City of Albuquerque soon followed with their declarations. The City made the decision to extend the existing contract with the existing rates. There is nothing in City policy that prevents extension of contracts for a specific length of time. Extending the contract most likely was a cost savings to the City because the rates would most likely would have increased. Auditor?s Response: We were not provided supporting documentation, as identified in management?s response, during our testwork over procurement to apply the necessary procedures to resolve this exception. Timeline and Responsible Position: June 2023 ? Chief Procurement Officer

View Audit 48606 Questioned Costs: $1

Finding 48306 (2022-001)

Material Weakness 2022

Chris Properties Graham Circle, Inc.

GA

Questioned Costs Allowable Costs / Cost Principles

Finding 2022-001 ? Allowable Costs/Cost Principles (Allocation of Payroll) Type of Finding: Compliance and material weakness in internal control over compliance Corrective Action Plan: The Organization is in the process of implementing procedures around time and effort reporting with federal grants....

Finding 2022-001 ? Allowable Costs/Cost Principles (Allocation of Payroll) Type of Finding: Compliance and material weakness in internal control over compliance Corrective Action Plan: The Organization is in the process of implementing procedures around time and effort reporting with federal grants. The new process will include a formal written policy for time and effort reporting across all federal grants that will provide the required documentation that federal funds were charged only for time actually worked. The Organization will be implementing a time and effort certification process that will be completed on a quarterly basis. It will be included in our documented policies and procedures and will be completed for all employees charging time to federal grants The certifications will be signed by the employee and the supervisor.

View Audit 47524 Questioned Costs: $1

Corrective Action Plans

Filters