Corrective Action Plans

Finding 507844 (2023-002)

Material Weakness 2023

WA

Questioned Costs Allowable Costs / Cost Principles

Identify, solve, and prevent future payroll liability and payroll expenses over allocation charged to grantors. Identify and solve errors. Follow financial policy to verify the solution and prevent future noncompliance. Responsible person: Finance Dept. Identify over-allocation amounts for each...

Identify, solve, and prevent future payroll liability and payroll expenses over allocation charged to grantors. Identify and solve errors. Follow financial policy to verify the solution and prevent future noncompliance. Responsible person: Finance Dept. Identify over-allocation amounts for each grant in 2023. Responsible person: Finance Dept. Inform all funders affected. Responsible person: Executive Director. Determine whether policy/procedure need to be updated or established. Responsible Persons: Executive Director and Finance Dept. Monthly check-ins to assess progress on action steps. Reveiw the effectiveness of implemented changes at the end of the fiscal year.

View Audit 328359 Questioned Costs: $1

Finding 507799 (2023-003)

Significant Deficiency 2023

Wilsona School District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.439

The District will ensure that all proposed capital expenditures originating from any Federal sources that are in excess of $5,000 are pre-approved by CDE prior to executing the proposed transaction.

View Audit 328293 Questioned Costs: $1

Finding 507793 (2023-002)

Significant Deficiency 2023

Wilsona School District

CA

Subrecipient Monitoring Reporting Significant Deficiency

Moving forward, the District will ensure that all items reported to various agencies, including the California Department of Education, are supported and are retained to external review.

View Audit 328293

Finding 507058 (2023-014)

Significant Deficiency 2023

The Howard University

DC

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.302

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR ...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025 Anticipated Completion Date: December 31, 2024

View Audit 328267 Questioned Costs: $1

Finding 506325 (2023-011)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from f...

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings. 5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent. Anticipated Completion Date: June 30, 2025

View Audit 328267

Finding 505602 (2023-008)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

Name of Responsible Individual: Nate R. McGill, Associate Director, Center for Career & Professional Success, Ben Carmichael, Associate Director for Compliance, John Hooth, Senior Director of Payroll Corrective Action: Federal Work Study supervisors are required to have training on the appropriate...

Name of Responsible Individual: Nate R. McGill, Associate Director, Center for Career & Professional Success, Ben Carmichael, Associate Director for Compliance, John Hooth, Senior Director of Payroll Corrective Action: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this. The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester. The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services is anticipating hiring a full-time Federal Work Study Coordinator by the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any Federal Work Study students and the first review of timesheets to ensure accuracy/timeliness in payment, as well as no supervisor approves time prior to the student working.

View Audit 328267

Finding 505595 (2023-007)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Questioned Costs Reporting

Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Ai...

Name of Responsible Individual: Edward Harper, Senior Associate Director of Financial Aid Corrective Action: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024. Anticipated Completion Date: The policy and procedure for V4 verification intake was updated in February 2024 and the training of Financial Aid Counselors occurred in February and March 2024. There will be annual training of Financial Aid Counselors on following appropriate verification procedures as needed. The Associate Director for Compliance performed a review of V4 verification documents processed by Financial Aid Counselors in March 2024 and June 2024. All V4 verification documents received after the training followed the updated policy and procedure. Another review of V4 verification will be completed in September 2024 and any additional training required will be scheduled.

View Audit 328267

Finding 505572 (2023-002)

Material Weakness 2023

The Howard University

DC

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Reporting § 200.516

Name of Responsible Individual: Bruce Jones, Senior Vice President of Research, Marchon Jackson, Associate Vice President of Research and Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The process to review Payment Request Forms (“PRFs”), used for paymen...

Name of Responsible Individual: Bruce Jones, Senior Vice President of Research, Marchon Jackson, Associate Vice President of Research and Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (“SPO”) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025. As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions. Anticipated Completion Date: March 31, 2025

View Audit 328267 Questioned Costs: $1

Finding 505564 (2023-007)

Material Weakness 2023

Michigan City Area Schools

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-007 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance for the rep...

FINDING 2023-007 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance for the reporting requirement. Not all EESER reports submitted by the School Corporation during the audit period were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are implementing a proper system of internal controls and developing policies and procedures to ensure all reports are submitted accurately. Description of Corrective Action Plan: We are implementing a proper system of internal controls and developing policies and procedures to ensure all reports are submitted accurately. Moving forward we will ensure all ledgers are attached to the reports that have been submitted. Anticipated Completion Date: The anticipated date of correction for this finding is January 1, 2025.

View Audit 328262

Finding 505560 (2023-005)

Material Weakness 2023

Michigan City Area Schools

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403

FINDING 2023-005 Finding Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles. Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the gran...

FINDING 2023-005 Finding Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles. Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Across-the-board stipends were paid without documentation or justification for additional duties or work performed on which to base the stipends. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We disagree with this finding. We did not offer an across the board stipend with ESSER II. We paid it to employees who had met certain length of employment requirements and effectiveness requirements. The IDOE guidance states that staff may be paid extra for added COVID-related work. However, this list is not exhaustive and we believe there are other reasons that allowed us to proceed. a. Incentives paid with federal funds must comply with 200.430(f). The federal regulations explicitly state that the bonus is allowed for efficient performance, which was our criteria. Explanation and Reasons for Disagreement: The USDOE gave what we did as a recommended best practice and example for others, of addressing staffing shortages and offering premium pay. In regards to Cafeteria workers please see this research brief released by USDOE regarding pandemic funds (ARP but also other federal pandemic funds, which would include ESSER II) State and Local Practices for Cafeteria and Custodial Staff • Waco Independent School District in Texas will give custodians and cafeteria workers up to $1,000 in bonuses, based on years served with the district. Those who have worked for 10 or more years will receive $1,000, divided in three payments beginning in December 2022. Those who have worked for five to nine years will get $750, and those with the district fewer than five years will get $500. The district expects $500 in bonuses to go to custodians and cafeteria workers. INDIANA STATE BOARD OF ACCOUNTS 46 • North Carolina is using ESSER funds to help local school nutrition operations across􀀃North􀀃Carolina􀀃 recruit􀀃and􀀃retain􀀃needed􀀃staff.􀀃 ESSER states, any activity authorized by the ESEA of 1965 (Titles I, II, III, IV IC Migrant, ID Neglected and Delinquent, 21st Century Community Learning Centers, and Rural and Low-Income Schools Grant) is allowable. Title II has explicit language about paying teachers and admin (but not cafeteria) more as a recruitment or retention bonus

View Audit 328262 Questioned Costs: $1

Finding 505554 (2023-002)

Material Weakness 2023

Diocesan Housing Services Corporation of the Diocese of Camden, Inc.

NJ

Reporting Subrecipient Monitoring Questioned Costs

The Organization has strengthened its policies and procedures for the identification of Federal awards to ensure that the preparation of a complete and accurate SEFA is performed in a timely manner and in accordance with the requirements of Office of Management and Budget. Management has implemented...

The Organization has strengthened its policies and procedures for the identification of Federal awards to ensure that the preparation of a complete and accurate SEFA is performed in a timely manner and in accordance with the requirements of Office of Management and Budget. Management has implemented compliance procedures for obtaining confirmation from the federal agencies. Any entities developed in the future will be assess accordingly and their funding will be included in the preparation of a complete and accurate SEFA for the Diocesan Housing Services Corporation of the Diocese of Camden, Inc.

View Audit 328245 Questioned Costs: $1

Finding 505441 (2023-003)

Significant Deficiency 2023

Calhoun Liberty Hospital Association INC

FL

Questioned Costs Material Weakness Reporting

Calhoun-Liberty Hospital Association, Inc., D/B/A Calhoun-Liberty Hopsital, (Hospital), respectfully submits the following corrective action plan for the year ended December 31, 2023. The finding from the December 31, 2023, Schedule of Findings and Questioned Costs is discussed below. The finding is...

Calhoun-Liberty Hospital Association, Inc., D/B/A Calhoun-Liberty Hopsital, (Hospital), respectfully submits the following corrective action plan for the year ended December 31, 2023. The finding from the December 31, 2023, Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD PROGRAMS AUDIT FINDING Significant Deficiency - Noncompliance (2023-003) Recommendation: The Hospital should continue to improve its understanding of the reporting requirements as specified in the applicable loan document and create a process to ensure all USDA requirements are met. Planned Corrective Action: As of September 30, 2024, the Hospital will open a bank account with the Hospital's current banking relationship. This account will be a restricted account dedicated to holding the required reserve as described in the existing USDA loan documents. The required reserve balance will be recorded on the Hospital's trial balance. The reconciliation for such balance will be provided upon request. Emily Brown Chief Executive Officer

View Audit 328121 Questioned Costs: $1

Finding 505381 (2023-007)

Material Weakness 2023

Chippewa County

MN

Internal Control / Segregation of Duties Questioned Costs Cash Management § 200.303

Finding Number: 2023-007 Finding Title: Social Service Fund Reporting (DHS-2556) Program: 93.778 Medicaid Cluster Name of Contact Person Responsible for Corrective Action: Jennifer Bakkelund, Fiscal Supervisor Corrective Action Planned: After speaking with State Auditors and DHS, expenses that had b...

Finding Number: 2023-007 Finding Title: Social Service Fund Reporting (DHS-2556) Program: 93.778 Medicaid Cluster Name of Contact Person Responsible for Corrective Action: Jennifer Bakkelund, Fiscal Supervisor Corrective Action Planned: After speaking with State Auditors and DHS, expenses that had been listed as “other” are now part of services rendered. A change in process of backup reports will be done to make this move of costs in the future. Fiscal Year 2023 reports are being corrected to match this new requirement. Any reports that are past the year cut off I am working directly with DHS to correct. Anticipated Completion Date: December 31, 2024

View Audit 328062 Questioned Costs: $1

Finding 505380 (2023-006)

Material Weakness 2023

Chippewa County

MN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Finding Number: 2023-006 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 93.778 Medicaid Cluster Name of Contact Person Responsible for Corrective Action: Jennifer Bakkelund, Fiscal Supervisor Corrective Action Planned: 2556 reports are being corrected to ...

Finding Number: 2023-006 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 93.778 Medicaid Cluster Name of Contact Person Responsible for Corrective Action: Jennifer Bakkelund, Fiscal Supervisor Corrective Action Planned: 2556 reports are being corrected to reflect the required corrections. Worked with DHS to correct the expenditure not eligible for federal reimbursement. (corrected 9/26/2024). Auditors’ office has been making corrections of payroll to move the 3 supervisors out of SSTS RMS to non SSTS RMS codes. I will then go back and correct the 2023 2556 reports. Any that are past the year cut off, I will work with DHS directly to make the corrections. Salary splits for Passport time and Director salary for supervision of Circle program will be adjusted and corrected on the 2556 as well. In the future these activities may be removed from the Family Services area. Anticipated Completion Date: December 31, 2024

View Audit 328062 Questioned Costs: $1

Finding 505354 (2023-102)

Significant Deficiency 2023

Booker T. Washington Child Development Center, Inc.

AZ

Questioned Costs Reporting

Person Responsible: Josie Ayon Estimated Completion Date 6/30/2024 Planned Corrective Action: The organization converted from the Cash Basis of Accounting to the Accrual Basis of Accounting (GAAP) for fiscal year 2023. Additionally, the organization converted to a new accounting system and hired ou...

Person Responsible: Josie Ayon Estimated Completion Date 6/30/2024 Planned Corrective Action: The organization converted from the Cash Basis of Accounting to the Accrual Basis of Accounting (GAAP) for fiscal year 2023. Additionally, the organization converted to a new accounting system and hired outside consultants to assist with data entry and financial reporting. The audit for June 30, 2024 is planned to start in October 2024, which will provide adequate time to comply with this requirement.

View Audit 328011

Finding 505353 (2023-101)

Material Weakness 2023

Booker T. Washington Child Development Center, Inc.

AZ

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Questioned Costs

Person Responsible: Josie Ayon Estimated Completion Date: 12/31/2024 Planned Corrective Action: Due to the COVID relief money received, there was no time to acquire additional in-kind donations. The Organization will continue to emphasis the importance of in-kind volunteer hours by parents and has ...

Person Responsible: Josie Ayon Estimated Completion Date: 12/31/2024 Planned Corrective Action: Due to the COVID relief money received, there was no time to acquire additional in-kind donations. The Organization will continue to emphasis the importance of in-kind volunteer hours by parents and has implemented a new program to track parent volunteer hours which will facilitate the gathering of accurate records.

View Audit 328011

Finding 505247 (2023-002)

Significant Deficiency 2023

Scott County School District

MS

Questioned Costs

Corrective Action Plan

View Audit 327862 Questioned Costs: $1

Finding 505247 (2023-002)

Significant Deficiency 2023

Scott County School District

MS