Corrective Action Plans

Finding 539675 (2024-002)

Material Weakness 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Questioned Costs Special Tests & Provisions

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless...

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless the student requests otherwise. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has examined the error and has implemented targeted training on the Return of Title IV (R2T4) process. This training focuses on accurately determining break days and performing the required calculations to ensure precision and compliance. To reinforce these efforts, the university will continue to provide quarterly training and cross-training opportunities for staff, ensuring a comprehensive understanding of R2T4 policies and procedures. To further strengthen accuracy, an additional internal review process has been established within the financial aid office. This review will be conducted by the Executive Director of Financial Aid, who will oversee calculations until the responsibility is designated to another team member with demonstrated expertise in R2T4 processing. These corrective measures will enhance the accuracy of R2T4 calculations, ensure compliance with federal regulations, and improve overall financial aid operations at Jackson State University. Estimated Completion Date: May 2, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MSU) Responsible Official: Lori Ball Executive Director for Financial Aid and Scholarship Corrective Action Planned: Our interpretation of the regulation was that if classes were held on weekends before or after the 5-day break, the weekend days were not counted, only the week itself (Monday- Friday) and the weekend afterwards. Classes started back the next Monday so we used 7 days. If we do not have classes on Saturday before spring break, we are now counting 9 days. Estimated Completion Date: March 15, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures have been updated to incorporate a nine-day break. The refund of funds to the Department of Education will be processed upon completion of the necessary calculations. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UM) Responsible Official: Mr. Eduardo Prieto, Vice Chancellor for Enrollment Management Corrective Action Planned: The University of Mississippi’s Office of Financial Aid has an existing process for next-level supervisor review of all Return of Title IV (R2T4) calculations. To further strengthen compliance, future R2T4 reviews will also include any documentation used to determine the date of withdrawal. While it is believed that communication with instructors was accurate, messaging will be refined to clarify which activities cannot be used to document academic engagement (e.g., simply logging into the online system). Additional scrutiny will be applied when determining the last date of attendance for online courses, and instructors will be contacted for clarification as needed. The Office of Financial Aid has also established a unit to enhance compliance through internal reviews of various processes, including R2T4. Although not all R2T4 calculations will be selected for examination, sample evaluations will provide an additional level of oversight. Additionally, a transition to Ellucian’s Banner system is planned for the 2026-2027 academic year, requiring instructors to report the last date of attendance for all F grades at the time of grade entry. This change will help minimize ambiguity regarding unofficial withdrawals. Estimated Completion Date: April 1, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UMMC) Responsible Official: Coralisa Williams, Senior Financial Aid Advisor Corrective Action Planned: Processing procedure has been updated to state the use of the “last date in class” from the academic calendar published in the UMMC Bulletin to ensure consistent and correct processing of R2T4. Estimated Completion Date: Effective immediately (has reviewed current R2T4 for accuracy) Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: The university included the Friday commencement day as last day of the term. Our reasoning is that some students are still completing assignments, tests, and class projects through the day of commencement. The financial aid office will verify the number of class days with the registrar office before each semester to ensure all class days are included in the award period. The student with the possible post-withdrawal disbursement withdrew prior to our census and all institutional charges were reversed and we could not verify that the student actually attended any of their classes. Effective February 3, 2025, institutions are exempt from performing an R2T4 calculation in this situation. Amend § 668.22(a)(2)(ii)(A)(6) to exempt institutions from performing an R2T4 calculation if: (1) a student is treated as never having begun attendance; (2) the institution returns all title IV, HEA assistance disbursed to the student for that payment period or period of enrollment; (3) the institution refunds all institutional charges to the student for that payment period or period of enrollment; and (4) the institution writes off or cancels any payment period or period of enrollment balance owed by the student to the institution due to the institution's returning of title IV, HEA funds to the Department. Going forward, USM intends to not perform R2T4 calculations for students that meet one of the above exemptions. Other possible post withdrawal disbursement will be tracked, and communication will be sent to students eligible once they are identified and calculated upon withdrawal. Estimated Completion Date: March 17, 2025

View Audit 350191 Questioned Costs: $1

Finding 539670 (2024-010)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Eligibility Significant Deficiency

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements...

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements. In addition, there is a second layer of review of all approved applicants’ eligibility prior to requesting disbursement of funds. An outside CPA firm was contracted in May 2024 to perform the second layer of review of each approved applicant before disbursement, to review all disbursement prior to that date in the current grant cycle, and to provide guidance on internal controls. An additional staff person to assist with grant awarding and programmatic operations was hired in August 2024. Estimated Completion Date: August 2024

View Audit 350191 Questioned Costs: $1

Finding 539652 (2024-001)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring Reporting Questioned Costs § 200.502

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department...

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539649 (2024-004)

Significant Deficiency 2024

Municipality of Florida

PR

Questioned Costs Subrecipient Monitoring Reporting

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539647 (2024-003)

Significant Deficiency 2024

Municipality of Florida

PR

Questioned Costs Subrecipient Monitoring Reporting § 200.328

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539638 (2024-003)

Significant Deficiency 2024

Nbcc

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of ...

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of CoC and ESG grant funds. We perceived the historical general approval to be in alignment with the contract requirement of obtaining written approval for the reimbursement of costs incurred for travel outside the county. All costs submitted for reimbursement were eligible and reasonable expenses. We now understand this historical approval by HUD was not transferrable to this grant and therefore, moving forward, we will secure email approval of travel eligibility for specific grant reimbursement prior to travel. To that end, we have already been in contact with Housing and Community Development (HCD) fiscal staff at Santa Barbara County about a reliable method to secure said approvals in advance moving forward. If travel is not approved for a specific grant, or not obtained prior to travel, other unrestricted income will be utilized for that portion of the travel expenses. viii. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administrator, vgarfield@sbnbcc.org ix. Anticipated Completion Date: Staff anticipate attending the annual NAEH conference this year, therefore we will request approval once registration is confirmed and expect to receive approval or rejection from County CD staff by no later than the date of travel, or approximately July 15, 2025.

View Audit 350179 Questioned Costs: $1

Finding 539634 (2024-003)

None 2024

Argus Manor Association

WA

HUD Housing Programs Questioned Costs Reporting

S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that we...

S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that went into effect on December 1, 2019. That deposit was increased by HUD each year thereafter effective each December 1; however, management believes that they were not notified of the increases in deposit requirements, and maintain that they did not receive copies of the revised HUD 9250 forms establishing the effective dates and amounts of deposit requirements changes for the years ended December 31, 2020 through December 31, 2022. The total amount of the replacement reserve deposit shortage was calculated to be $13,302. S3800-080: Auditor Recommendation: Management should review policies and procedures to ensure all required deposits to the reserve account are properly billed and deposited into the escrow account with the lender. Management should also deposit the shortage of $13,302 in the replacement reserve escrow account held by the lender. S3800-045: Actions Taken or to be Taken: Management will follow up with the lender about the new deposit requirement and deposit the funding shortage of $13,302 in the replacement reserve escrow account held by the lender. They will also request all missing copies of the HUD 9250 forms for the effective dates of December 1, 2020 through December 1, 2022.

View Audit 350177

Finding 539606 (2024-001)

Significant Deficiency 2024

Horatio School District

AR

Questioned Costs Procurement, Suspension & Debarment Cash Management

Horatio School District will contact the Federal Communications Commission for guidance regarding this matter and reimbursement. Anticipated completion date: April 15, 2025.

View Audit 350148 Questioned Costs: $1

Finding 539602 (2024-002)

Significant Deficiency 2024

Bay County District School Board

FL

Matching / Level of Effort / Earmarking Questioned Costs § 200.303

Finding Number: 2024-002 Planned Corrective Action: The District had an unusually high volume of federal grants related to the CARES Act. There were expenditures planned for these funds; however, due to supply issues with both vendors and materials, other projects had to be substituted for the p...

Finding Number: 2024-002 Planned Corrective Action: The District had an unusually high volume of federal grants related to the CARES Act. There were expenditures planned for these funds; however, due to supply issues with both vendors and materials, other projects had to be substituted for the planned expenditures to meet timing requirements of the grant. It was during this process that the requirements related to the Davis Bacon Act were not followed. Moving forward, staff has gained experience and are more aware of the effects of moving expenditures for grant-related funds. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Jacqueline Webb

View Audit 350140 Questioned Costs: $1

Finding 539584 (2024-004)

Material Weakness 2024

West Mifflin Area School District

PA

Questioned Costs Special Tests & Provisions Matching / Level of Effort / Earmarking

FINDING 2024-004: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Special Tests and Provisions - Wage Rate Requirements Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section N, "Special Tests and Pro...

FINDING 2024-004: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Special Tests and Provisions - Wage Rate Requirements Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section N, "Special Tests and Provisions" of the Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than the prevailing wages rates established by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and DOL regulations. 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. Condition: The School District did not have adequate internal control procedures in place to ensure that all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds were paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor. As a result, the School District did not properly notify 1 of the 3 contractors tested of the requirements to comply with the wage rate requirements via the including of a prevailing wage rate clause in the contract between the contractor and the School District, and therefore, the use prevailing wage rates were not determined. Cause: The School District did not have formal procedures in place to ensure that prevailing wage rate requirements were met on all construction projects over $2,000. Effect: The School District was not in compliance with the Special Tests and Provisions - Wage Rate Requirements of the Uniform Guidance. Repeat Finding: No Questioned Costs: Unknown Recommendation: We recommend that the School District revise its purchasing policy to formally reflect the requirements of Special Tests and Provisions - Wage Rate Requirements. Additionally, we recommend that the School District establish procedures to ensure that prevailing wage rate requirements are met for federally funded construction projects over $2,000. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. The Business Office will require that projects over $2,000 involving federal must use prevailing wage rates.

View Audit 350127 Questioned Costs: $1

Finding 539579 (2024-003)

Material Weakness 2024

West Mifflin Area School District

PA

Equipment & Real Property Management Questioned Costs Procurement, Suspension & Debarment

FINDING 2024-003: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Equipment and Real Property Management Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section F, "Equipment/Real Property Management" ...

FINDING 2024-003: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Equipment and Real Property Management Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section F, "Equipment/Real Property Management" of the Compliance Supplement, the School District is required to receive prior approval from the Pennsylvania Department of Education (PDE) for capital expenditures for equipment acquisition or improvements to land, buildings, and equipment. Condition: The School District did not adequately obtain approval from PDE prior to purchasing equipment and building improvements with ESF funds. Cause: The School District did not have a formal procedure in place to obtain prior approval of applicable expenditures. Effect: The School District was not in compliance with the Equipment and Real Property Management requirements of the Uniform Guidance. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the School District revise its purchasing policy to formally reflect the requirements of Equipment/Real Property Management. We recommend that the School District establish procedures to ensure that Equipment/Real Property Management requirements are met for applicable purchases. Views of Responsible Officials and Planned Corrective Action: The School District has expended all ESSER II grant monies, but the School District still has ARP ESSER funds that need to be spent, and some of the upcoming purchases will include capital expenditures. In order to receive prior approval from PDE for those expenditures, the School District will submit a revised ARP ESSER budget request to PDE. Approval of the budget requested by PDE includes the required prior approval for capital expenditures.

View Audit 350127 Questioned Costs: $1

Finding 539575 (2024-001)

Significant Deficiency 2024

Primary Connection Health Care, Inc.

WI

Questioned Costs Eligibility Internal Control / Segregation of Duties

We have determined that the sliding fee set up in our EHR will miscalculate a patient’s sliding fee discount when a combination of particular conditions are met. A representative of the EHR company has confirmed that the system “does not behave as it should” when these circumstances occur. While it...

We have determined that the sliding fee set up in our EHR will miscalculate a patient’s sliding fee discount when a combination of particular conditions are met. A representative of the EHR company has confirmed that the system “does not behave as it should” when these circumstances occur. While it is rare that a slide patient would meet all of these conditions, it does happen from time to time. Because of this, we have begun verifying the discounts applied to every slide patient’s account to ensure accuracy. Additionally, we are restructuring the sliding fee discount program and will rebuild it within the EHR to remove the possibility of one of the conditions occurring, which should prevent the system from ever miscalculating the discount to be applied. Person(s) Responsible: Kim Wieloch, Finance Director Timing for Implementation: Verifying all SFS discounts: Currently in process and ongoing; Rebuilding SFS calculation structure in EHR: By 7/1/2025

View Audit 350122

Finding 539570 (2024-002)

Significant Deficiency 2024

Connetquot Central School District

NY

Questioned Costs Allowable Costs / Cost Principles

2024-002. Allowable Costs/Cost Principles: Allowable Program Costs United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP All...

2024-002. Allowable Costs/Cost Principles: Allowable Program Costs United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Condition: Testing of the expenditures charged to the special education cluster, determined that a certain cost charged to the program grant would not be allowable. Planned Corrective Action: The District will monitor procedures that perform a detailed review of expenditures being charged to grants to ensure that they are allowable costs under the guidance provided by federal agencies. Responsible Contact Person: Laurie O’Hara Director of Special Education Connetquot Central School District 700 Ocean Avenue Bohemia, New York 11716 Anticipated Completion Date: June 30, 2025.

View Audit 350117 Questioned Costs: $1

Finding 539561 (2024-004)

Significant Deficiency 2024

St John Public School District No. 3

ND

Questioned Costs Allowable Costs / Cost Principles

Contact Person Mary Vandal, Business Manager Planned Corrective Action To ensure that all payroll expenditures are allowable for hourly employees, timesheets will be approved by each supervisor and/or the Superintendent. Any additional pay issued to certified staff will have Superintendent approval ...

Contact Person Mary Vandal, Business Manager Planned Corrective Action To ensure that all payroll expenditures are allowable for hourly employees, timesheets will be approved by each supervisor and/or the Superintendent. Any additional pay issued to certified staff will have Superintendent approval documented on a pay request sheet. All certified employees will continue to have a signed contract on file each year. All non-certified employees will have a letter of assignment signed and on file each year. Planned Completion Date June 30, 2025

View Audit 350113

Finding 539560 (2024-005)

Significant Deficiency 2024

St John Public School District No. 3

ND

Questioned Costs Reporting Internal Control / Segregation of Duties

Contact Person Mary Vandal, Business Manager Planned Corrective Action This finding was noted by the auditors on the Impact Aid application submitted in January 2023. Both applications submitted in January of 2024 and 2025 had the proper support showing student enrollment information with review or ...

Contact Person Mary Vandal, Business Manager Planned Corrective Action This finding was noted by the auditors on the Impact Aid application submitted in January 2023. Both applications submitted in January of 2024 and 2025 had the proper support showing student enrollment information with review or approval by tribal authority prior to submitting the application. Applications made in the future will continue to have the required documentation to support the application. Planned Completion Date June 30, 2025

View Audit 350113

Finding 539559 (2024-002)

Material Weakness 2024

Food for Greater Elgin, Inc.

IL

Equipment & Real Property Management Questioned Costs School Nutrition Programs

The food pantry acknowledges the finding and agrees with the recommendations. The responsible officials have committed to implementing the following corrective actions: develop and implement a comprehensive inventory management policy that includes the requirement for an annual physical inventory of...

The food pantry acknowledges the finding and agrees with the recommendations. The responsible officials have committed to implementing the following corrective actions: develop and implement a comprehensive inventory management policy that includes the requirement for an annual physical inventory of donated foods, schedule and conduct the annual inventory observation for the current fiscal year and ensure it is completed by the end of the fiscal year, provide training to staff involved in the inventory process to ensure they understand and follow the new procedures and perform periodic internal audits to ensure ongoing compliance with the inventory management policy and address any issues identified.

View Audit 350112

Finding 539550 (2024-004)

Material Weakness 2024

City of Alexandria

VA

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303

DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.

View Audit 350101

Finding 539547 (2024-002)

Significant Deficiency 2024

University of Central Oklahoma

OK

Questioned Costs Reporting

COD Reporting Errors Audit Finding: Two students had incorrect disbursement information reported. Out of a population of 6,385 students with disbursements during the Spring and Fall semesters of the 2024 aid year, 25 were selected for testing. Of those students, two had the incorrect disbursement d...

COD Reporting Errors Audit Finding: Two students had incorrect disbursement information reported. Out of a population of 6,385 students with disbursements during the Spring and Fall semesters of the 2024 aid year, 25 were selected for testing. Of those students, two had the incorrect disbursement date reported. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure accurate reporting. Effect of the Finding: The University reported inaccurate information and, as such, ED was not provided accurate information. Acknowledgement of the Finding: We acknowledge the audit finding regarding the discrepancies between the disbursement dates reported to the Common Origination and Disbursement (COD) system and the actual disbursement dates. We understand the importance of aligning these dates to ensure accurate federal reporting and compliance with Title IV regulations. Risk Acceptance: After careful consideration, we have determined that we are willing to accept the risk associated with the mismatches in COD disbursement dates. We believe that the discrepancies identified have not resulted in significant adverse impacts on our federal aid programs or student aid disbursement processing. Furthermore, we assess that the likelihood of material financial or operational consequences arising from these discrepancies is low. Rationale for Accepting the Risk: o The mismatched disbursement dates were not caused by fraudulent activity or intentional misreporting. o There is no evidence of overpayments or underpayments of Pell Grant funds to students as a result of the discrepancies. o The institution has a long history of successfully managing federal aid programs, and the current system's checks and balances are deemed adequate to ensure that aid is disbursed correctly, even if the dates reported to COD do not exactly match the dates the funds were disbursed. o The impact on reconciliation and compliance has been minimal, and we have not encountered significant issues in our annual reviews with the Department of Education. o The mismatches are not expected to have any significant impact on our ability to meet Title IV reconciliation deadlines or other reporting requirements. Mitigating Actions: While we are willing to accept the risk associated with these mismatches, we will continue to take steps to mitigate any potential negative impacts and improve our internal processes, including: o Monitoring and Review: We will conduct periodic reviews to identify any significant discrepancies and address them promptly. Any material issues that arise in the future will be corrected as needed. o Reconciliation Process: We will continue to ensure that our reconciliation process between our internal system and COD is robust, even if mismatched dates are accepted. Any discrepancies will be reviewed at regular intervals to verify accuracy. o Training: We will provide ongoing training to staff responsible for Pell Grant disbursements and reporting to COD to ensure they are aware of the risks and potential consequences of incorrect disbursement date reporting. o Documentation of Decisions: We will maintain documentation of the decision to accept the risk and will revisit this decision as part of our annual risk assessment to ensure that it continues to align with institutional goals and compliance objectives. Conclusion: We are confident that the risk of COD disbursement date mismatches will not significantly impact our overall compliance or federal aid management. However, we remain committed to continuous monitoring and improvements in our processes to ensure accurate reporting and minimize any potential future issues. Responsible Parties: The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Senior Director Student Financial Services and Operations. Responsible party contact information is located at uco.edu.

View Audit 350087

Finding 539545 (2024-001)

Material Weakness 2024

University of Central Oklahoma

OK

Questioned Costs Reporting Special Tests & Provisions

NSLDS Reporting Errors Audit Finding: Eight students had incorrect enrollment information reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Out of a population of 4,479 students with status changes...

NSLDS Reporting Errors Audit Finding: Eight students had incorrect enrollment information reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Out of a population of 4,479 students with status changes during the Spring and Fall semesters of the 2024 aid year, 40 were selected for testing. Of those students, four had the incorrect program begin date reported, one had the incorrect program enrollment effective date reported, one had the incorrect program length reported, two had the incorrect CIP code reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely and accurate reporting. Effect of the Finding: The University reported inaccurate information or failed to report changes within the required time frame and, as such, ED was not provided accurate and timely information. Corrective Action Plan: To address the errors identified in the NSLDS reporting, the following corrective actions will be taken: 1. Immediate Review and Correction of Existing Data o Conduct a review of federal student aid records for the past nine months to identify and correct any discrepancies in loan amounts, disbursement dates, and borrower statuses reported to NSLDS. o Work with the SIS vendor and ED to ensure that all data submissions to NSLDS are accurate and complete. 2. System Integration and Process Improvement o Implement a data validation process that cross-checks loan disbursements and borrower statuses against internal records before submitting to NSLDS. o Enhance the SIS to NSLDS data mapping interface to ensure consistency and accuracy of loan-related information between the two systems. 3. Training for Staff o Provide targeted training for financial aid office staff responsible for NSLDS reporting, emphasizing proper data entry practices, system integration, and error-checking protocols. o Review periodic refresher courses to ensure staff remains up to date on any changes to NSLDS reporting requirements. 4. Ongoing Monitoring and Reconciliation o Establish a routine process to reconcile NSLDS data with internal student aid records monthly, ensuring discrepancies are caught and corrected promptly. o Implement a monthly review of the NSLDS submission to confirm all data is up to date, including loan disbursements, borrower status updates, and any adjustments. 5. Timeline for Implementation o Review and correction of existing NSLDS errors, as needed: Completed by June 30, 2025. o System and integration review: Completed by June 30, 2025. o Staff training sessions: First session scheduled by June 30, 2025, with periodic refreshers as available. o Ongoing monitoring process implementation: Ongoing starting immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Registrar will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

View Audit 350087

Finding 539544 (2024-004)

None 2024

The Housing Authority of the City of Opelika

AL

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective action...

Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective actions. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.

View Audit 350086 Questioned Costs: $1

Finding 539540 (2024-001)

Significant Deficiency 2024

Kid Net Foundation Dba Jonathan's Place

TX

Questioned Costs Allowable Costs / Cost Principles Cash Management

RESET is a cost reimbursement grant. The agency maintains an Excel workbook that tracks costs over the course of the 12-month award year. The workbook is updated prior to each month's request for reimbursement. The grant accountant accrued a reimbursable expense for clothing for September, then inex...

RESET is a cost reimbursement grant. The agency maintains an Excel workbook that tracks costs over the course of the 12-month award year. The workbook is updated prior to each month's request for reimbursement. The grant accountant accrued a reimbursable expense for clothing for September, then inexplicably entered a slightly different amount into the workbook. This l ne item was selected for audit, and the agency is unable to provide support for the difference. In addition, in October the grant accountant improperly recorded a payroll cost in the General Ledger and the grant workbook. While the documentation clearly shows how the amount was calculated, it was nor a legitimate period cost. The agency charges expenses to a unique department number in the General Ledger. Costs are assigned in the workbook to one of three categories: reimbursable, ineligible, and pending. The control process calls for the grant accountant to assign each GL expense to a category, then to ensure the workbook ties to the GL for the month and award year-to-date. An initial review indicates the control worked because the cost column for the month consistently matches the GL. A closer review shows that for September, the accountant matched the GL by entering a rounding error. Rounding errors should be limited to a penny or so. The control failed. The lack of accuracy and attention to detail is regrettable. The grant accountant is no longer with the agency. The grant accountant is responsible for the integrity of the workbook. The CFO is responsible for the overall integrity of the financial statements. The CFO and grant accountant meet monthly to review the workbook. The CFO reviews the workbook for reasonableness and completeness. This review includes observing the grant accountant's assertion that the workbook matches the GL. To reduce the risk of future errors, the CFO has 1. Reviewed the monthly process with the new grant accountant, emphasizing the need to match the GL. Status: Complete. 2. Created an agenda template for monthly workbook reviews. This agenda includes confirmation that the workbook matches the GL and identification of any amount of rounding for the month and award year-to-date. Status: Complete. 3. Added a step to the workbook. In addition to the current process of entering GL information to the workbook, the grant accountant will enter date of confirmation and save a copy of the GL that matches the workbook. Status: complete, effective as of January 2025 activity. 4. Added a step to the department's close checklist. The grant accountant explicitly confirms that Step 3 is done. Status: complete, effective as of January 2025 activity.

View Audit 350082

Finding 539534 (2024-001)

None 2024

Economic and Community Development Institute, Inc.

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.516

Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of ho...

Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Planned Corrective Action: ECDI will put additional steps in place in Payroll Review process to ensure reconciliation of payroll charges to actual time records and rates. The organization will modify it's calculations to ensure that pay rates are reflective of the timeframe in question (not for periods before or after). ECDI will update its calculations to include thresholds for Executive pay so they are not entered in excess of approved rates. The company is also exploring technology enhancements so that information from ECDl's Payroll system flows directly into ECDl's Accounting system to limit the chance of errors during extraction from Payroll system and uploading into Accounting system. Contact Person Responsible for Corrective Action: Brian Barrett and Hudu Ahmed. Completion Date: In process

View Audit 350075 Questioned Costs: $1

Finding 539532 (2024-004)

Material Weakness 2024

Community Care

ME

Questioned Costs Eligibility Reporting

Corrective Action Plan for Finding 2024-004 Community Care agrees with this finding. There are four bullets in this finding. We will be making a formal request to have the HMIS 72 hour data entry removed from our contract. The HMIS system does not have the capability to measure data entry timefram...

Corrective Action Plan for Finding 2024-004 Community Care agrees with this finding. There are four bullets in this finding. We will be making a formal request to have the HMIS 72 hour data entry removed from our contract. The HMIS system does not have the capability to measure data entry timeframes because of this we would need to design a data entry tracking process to track the timeframes. If our request is denied, we will create an entry tracking process. Bullets 2-4 are results of providing services in from the perspective of a low barrier service. Our priority is to have youth come to a safe place that is warm and where they are provided with a place to sleep, food, healthcare, and services to aid them. Staying in the program is not contingent on completing assessments or engaging in a service planning process. Each time a youth is in a program they are provided with the opportunity to participate in an assessment and are offered an organized service plan. Most participate but some do not. We will continue to offer the same level of support and opportunity for assessments and service planning to each youth. • There was no auditable evidence to test whether the participants were entered into HMIS within 72 hours. • Four participants did not have a service plan developed within 30 days. • The client was unable to provide the NavSEA for three participants. • The service plan for one participant did not have documented review. Responsible Official: David McCluskey, Executive Director Date of Corrective Action: Systems are in place and efforts will continue to encourage youth to participate in assessments and service planning practices. Regarding the HMIS data entry request will be made Friday the 21st March, 2025. If denied we will build a tracking process within 30 days.

View Audit 350061

Finding 539531 (2024-003)

Material Weakness 2024

Community Care

ME

Questioned Costs HUD Housing Programs

Corrective Action Plan for Finding 2024-003 Community Care agrees with this finding. The homeless youth service sector of our organization has significant report requirements that could not be supported by existing resources. A recent effort to improve report timing was to hire an administrative...

Corrective Action Plan for Finding 2024-003 Community Care agrees with this finding. The homeless youth service sector of our organization has significant report requirements that could not be supported by existing resources. A recent effort to improve report timing was to hire an administrative person to specifically focus on these reports. This individual began employment in February 2025. The primary purpose of this position will be to organize data and complete reports on schedule. Responsible Official: David McCluskey, Executive Director Date of Corrective Action: New employee hired in February 2025

View Audit 350061

Finding 539530 (2024-002)

Material Weakness 2024

Community Care

ME

Questioned Costs

Corrective Action Plan for Finding 2024-002 Community Care agrees with this finding. There are three bullets in the finding. Although we agree with the findings, the first two are not fully related to a problem of service delivery from Community Care These timeframes are highly dependent on the De...

Corrective Action Plan for Finding 2024-002 Community Care agrees with this finding. There are three bullets in the finding. Although we agree with the findings, the first two are not fully related to a problem of service delivery from Community Care These timeframes are highly dependent on the Department of Health and Human Services to ensure parents and family members have reliable transportation. Approximately 6 months ago, Community Care discussed with DHHS that we would be willing to transport parents and were told by DHHS the funding cannot be used for that part of the service. Community Care will continue to hiring employees to fulfill the contract and arranging visits efficiently as soon as parents and families members who are visiting have transportation. We have seen improvements in the area. Because these two measurements are not fully in our control we will be advocating for this measurement to be removed in future contract language. The third bullet has been improved since 2024. In Feb of 2025 we made significant efforts and dedicated significant resources in employee to move closer to this goal. Currently we are within 7-10 days from date of service making entries into the Katahdin system rather than two months. Responsible Official: David McCluskey, Executive Director Date of Corrective Action: Hiring activities/efforts are on-going

View Audit 350061

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