Corrective Action Plans

Finding 540859 (2024-001)

Significant Deficiency 2024

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

At the time of the purchase for this particular building, the district had several prior approval applications for HVAC replacment submitted to DESE for approval. We believe this one had been submitted as well but was unable to confirm that with DESE. We will develop a better checklist for items s...

At the time of the purchase for this particular building, the district had several prior approval applications for HVAC replacment submitted to DESE for approval. We believe this one had been submitted as well but was unable to confirm that with DESE. We will develop a better checklist for items submitted to DESE for prior approvals so nothing is overlooked.

View Audit 350512 Questioned Costs: $1

Finding 540854 (2024-002)

Material Weakness 2024

Ashtabula County Educational Service Center

OH

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.430

The Treasurer will ensure that the appropriate documentation supporting the time spent on a federal grant, in accordance with the Service Center’s Policy 6116 for Time and Effort, for all employees having wages and/or benefits charged to federal grants.

View Audit 350470 Questioned Costs: $1

Finding 540840 (2024-003)

Material Weakness 2024

Kankakee Valley School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: During the fiscal year 2023-2024, the School Corporation was part of Cooperative School Services, which managed special education programs and finan...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: During the fiscal year 2023-2024, the School Corporation was part of Cooperative School Services, which managed special education programs and finances for its schools. There were recognized issues where non-public schools received direct reimbursements. It is recommended that the School Corporation implement internal controls to prevent direct reimbursements, ensuring compliance with grant requirements and financial regulations. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with Cooperative School Services to ensure allowable cost requirements are met. Reports tracking expenditures will be reviewed semiannually for compliance. Anticipated Completion Date: June 1, 2025

View Audit 350469 Questioned Costs: $1

Finding 540829 (2024-001)

Significant Deficiency 2024

Newbern Housing Authority

TN

Questioned Costs Cash Management HUD Housing Programs

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, ...

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, 2025 Planned Corrective Action: The Authority will work on ensuring requests for reimbursement of capital funds will have supporting documentation and management will take measures to ensure duplicate requests aren't made for a single invoice.

View Audit 350466 Questioned Costs: $1

Finding 540823 (2024-003)

Significant Deficiency 2024

Muncie Community Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.430

Finding 2024-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employee’s time charged to the grant...

Finding 2024-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employee’s time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all payroll amounts recorded to food service are reviewed to ensure they represent food service payroll activity only. Anticipated Completion Date: March 2025

View Audit 350456 Questioned Costs: $1

Finding 540795 (2024-008)

Material Weakness 2024

Rochester Community School Corporation

IN

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

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirements. Context: During testing of the Allowable Costs/Cost Principles compliance requirements, there were two vendor vouchers in a sample of 60, where the School Corporation was unable to locate any supporting documentation. These two selections totaled $1,530 charged to the grant. It was further noted that during our testing of payroll costs charged to the COVID-19 – Education Stabilization Fund, for 2 selections in a sample of 40, the School Corporation was unable to provide any support to validate the amount of payroll charged to the grant. These two selections totaled $414 charged to the COVID-19 – Education Stabilization Fund. Corrective Action Plan: The School Corporation will establish a system of internal controls to ensure that documentation is maintained and that expenditures charged to the grant comply with the grant agreement and are allowable. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

View Audit 350448 Questioned Costs: $1

Finding 540756 (2024-006)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.324

CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a ...

CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District will conduct a cost or price analysis for all contracts over the Simplified Acquisition Threshold of $250,000 before receiving bids and proposals. The timeframe for implementation of this procedure is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540755 (2024-005)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.300

CONDITION: During my review of the District’s compliance with the requirements of the Public-School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods be...

CONDITION: During my review of the District’s compliance with the requirements of the Public-School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, were obtained for the following vendors: Pittsburgh Area Community Schools Deborah Coppula Allegheny Intermediate Unit CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will document at least three price or rate quotations for procurements over $10,000. All procurements over $10,000 will be reviewed by the Superintendent to see evidence that three (3) verifiable price quotes were received before authorizing the requested procurement and will be placed in a file for audit purposes. The timeframe for implementation is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540754 (2024-004)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.320

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the...

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the School District adhere to Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement, as well as the District’s Procurement Policy for Federal Programs (#626.5). MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will maintain procurement records, including why the noncompetitive procurement contract was necessary with appropriate documentation vetted by the District Solicitor. Additionally, the District will conduct an analysis to support that the price paid was reasonable. This analysis is needed to justify procurements that are not competitively bid. The timeframe for implementation is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540724 (2024-003)

Material Weakness 2024

Belcourt Public School District #7

ND

Questioned Costs Allowable Costs / Cost Principles

2024-003 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify ...

2024-003 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify that vendor quotes reflect competitive market rates. Purchasing agents and approving administrators will also ensure staff travel requests are electronically filed; all related documentation for all related expenses will be collected. Additional training will be provided to relevant staff on federal expenditure guidelines to prevent future issues. These corrective actions will mitigate the risk of non-compliance and ensure that expenditures are reasonable and necessary for the federal award. Anticipated Completion Date: Fiscal Year 2024-2025

View Audit 350425 Questioned Costs: $1

Finding 540722 (2024-001)

None 2024

Town of Hardwick

MA

Questioned Costs Procurement, Suspension & Debarment § 200.319

Condition: The Town was unable to provide documentation to support a competitive procurement process for one vendor. Corrective Action Planned: A change in Town leadership (Town Administrator) caused the requested documents to be misplaced. In the future the Town will keep all procurement docu...

Condition: The Town was unable to provide documentation to support a competitive procurement process for one vendor. Corrective Action Planned: A change in Town leadership (Town Administrator) caused the requested documents to be misplaced. In the future the Town will keep all procurement documents together in one central location at Town Hall. Anticipated Completion Date: Completed Contact: Laurie Dell’Olio, Town Accountant

View Audit 350423 Questioned Costs: $1

Finding 540717 (2024-002)

None 2024

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Student Financial Aid Eligibility

Finding 2024-002: Incomplete Verification Tested sixty-three files and an application selected for verification did not match supporting documentation for one student. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Plan...

Finding 2024-002: Incomplete Verification Tested sixty-three files and an application selected for verification did not match supporting documentation for one student. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has implemented an internal check and balance to ensure that all files have the documentation required. The school has also partnered with a third-party servicer that will also be auditing the documentation needed to complete verification of student files.

View Audit 350416 Questioned Costs: $1

Finding 540716 (2024-001)

None 2024

Ohio Institute of Allied Health, Inc.

IL

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001: Incorrect Pell Grants Tested sixty-three files, fifty-four of which were Pell Grant recipients, and four students received Pell grants in excess of their allowed amounts and two students did not receive the full amount of their allowed Pell grants. Comments on Finding and Recommend...

Finding 2024-001: Incorrect Pell Grants Tested sixty-three files, fifty-four of which were Pell Grant recipients, and four students received Pell grants in excess of their allowed amounts and two students did not receive the full amount of their allowed Pell grants. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting Pell. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be refunding $2,910 to the Department of Education and crediting $1,053 to the affected student accounts.

View Audit 350416 Questioned Costs: $1

Finding 540712 (2024-002)

Significant Deficiency 2024

Jobpath, Inc.

AZ

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

The organization identified the issues and made staffing changes as of January 1, 2025 that include eliminating the Director of Finance position and instead created an accounting coordinator position and hired an outside accounting firm to provide expertise and an additional level of oversight. This...

The organization identified the issues and made staffing changes as of January 1, 2025 that include eliminating the Director of Finance position and instead created an accounting coordinator position and hired an outside accounting firm to provide expertise and an additional level of oversight. This change expands the finance and accounting team, increasing capacity to ensure the time needed for review of invoices and efficient communication with funders and avoid misunderstandings in the future.

View Audit 350398 Questioned Costs: $1

Finding 540622 (2024-008)

Material Weakness 2024

State of New Hampshire

NH

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.306 § 200.414 § 200.434

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildli...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-008 - Matching Anticipated Completion Date: June 30, 2025 Corrective Action Planned: To have revised procedures in place to include additional documentation to ensure accuracy from the subrecipient. We concur with the finding; A. In-kind match documentation earned requires additional documentation to support subrecipient match contribution. Revised procedures will be implemented to include additional documentation from the subrecipient to ensure accuracy. B. Internal review of volunteer in-kind match calculations are in place, however, in one instance, prior year rates were used resulting in under reported in-kind match earned. The Department does review and track match received from the subrecipient. We do not agree there are questioned costs of $201,250.

View Audit 350389 Questioned Costs: $1

Finding 540621 (2024-007)

Material Weakness 2024

State of New Hampshire

NH

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.502

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildli...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-007 – Activities Allowed or Unallowed/Allowable Costs/Costs Principles Anticipated Completion Date: Unknown Corrective Action Planned: To have the ability to use NHFIRST for grant accounting in the future. Hopefully, the migration to CloudSuite will offer this option. We concur in part with the finding; A. The Department does recognize the NHFIRST system is the official financial system of the state of NH, however, at this time NHFIRST does not allow for us to be able to charge grants individually for staff working on grant funded projects through the NHFIRST system. Therefore, we use QuickBooks as a ‘calculator’ for these grant costs. The Department uses a calculated rate based on the employee’s pay rate, benefits and years of service. While it is an arduous and complicated task, there is currently no other option for capturing all costs of the employee to the programs. B. We do not concur with part B as we did supply the support to substantiate the payroll costs but it was not used for testing. C. We did provide a specific sample for testing but again not in the timeliness requested. The Department does perform reconciliations and pre-audits of information entered into QuickBooks to verify data is complete and accurate. Payment vouchers are entered into QuickBooks by the Federal Aid Accountant and verified by the Supervisor. The Supervisor also verifies payroll and Indirect. We do not agree there are questioned costs of $11,409.

View Audit 350389 Questioned Costs: $1

Finding 540600 (2024-001)

Significant Deficiency 2024

University of Pittsburgh of the Commonwealth Sys. of Higher Education

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Signi...

Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Significant Deficiency The School of Dental Medicine did not have a report to identify students with a federal loan aggregate related issue. The Office of Admissions and Financial Aid had a report for students in the undergraduate and graduate careers (excluding the Dental Medicine professional Primary Academic Program). The Office of Admissions and Financial Aid added the School of Dental Medicine staff as a recipient on this report to assist them in identifying students with an ISIR code indicating students that are approaching or have already exceeded the Federal Direct Loan aggregate limits for review. Since September 2024, the School of Dental Medicine has been receiving and reviewing the Aggregate Overpay Checklist report. Name of the contact person: Michelle Jackson Completion date: Already completed, September 2024

View Audit 350369 Questioned Costs: $1

Finding 540595 (2024-002)

Significant Deficiency 2024

Southern Oregon University

OR

Questioned Costs Student Financial Aid Eligibility

Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit f...

Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU will review its policies and procedures for Direct Loan entrance counseling to ensure all students, including GRAD PLUS loan recipients, have completed their entrance counseling or previously completed counseling is retained within the student information system. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: April 2025

View Audit 350358 Questioned Costs: $1

Finding 540563 (2024-001)

Material Weakness 2024

Tougaloo College

MS

Questioned Costs Student Financial Aid Subrecipient Monitoring

I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1) 11 out of 60 st...

I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this finding is $180,794. 2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or incomplete timesheets. 34 CFR Part 675. 3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. 4) Entrance and exit counseling documentation was not provided for first time borrowers, withdrawn students or graduated students. 34 CFR 685.304. 5) Cost of Attendance Budgets to determine students unmet need were not provided by the College. 34 CFR 685.102(b). 6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and Federal Work-Study. 7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and Federal Direct Loans. CFR 685.300(b)(5). Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The collective knowledge of others within the Division of Finance and Administration reinforces the expertise of the four financial aid staff members. The Vice President of Finance and Administration, in collaboration with the Vice President for Enrollment and Student Services, who has direct oversight of the financial aid department, has implemented professional development targeted training on the continuous changes in Title IV program management. In addition to addressing/paying the questioned costs found with improper documentation of Satisfactory Academic Progress with USDE, the following allows for corrective actions while continuing to engage with the Title IV student financial aid programs: 1. Financial Aid team members become certified in the enterprise resource program module, specific to financial aid. 2. Annually, one or more staff members attend the national conference for student aid administrators, which focuses on deepening understanding of federal regulations, exploring new legislation enacted by Congress, gaining practical experience with student loan data systems, and networking with industry peers who offer support identifying and effectively addressing challenges associated with financial aid operations. 3. Attend monthly and quarterly training via knowledge base webinars on: Satisfactory Academic Progress (SAP), Work-study process for students and staff, student loan process, the return of Title IV funds, and reconciling expenditures with the Business Office. 4. Utilize additional resources from the U.S. Department of Education’s Minority-Serving and Under-Resourced Schools Division for administering Title VI Aid.

View Audit 350319 Questioned Costs: $1

Finding 540527 (2024-001)

Material Weakness 2024

Mental Health Center of Denver

CO

Questioned Costs Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.327

March 26, 2025 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-001 AREA: Procurement and Suspension & Debarment Compliance It was noted that (1) the Organization's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200....

March 26, 2025 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-001 AREA: Procurement and Suspension & Debarment Compliance It was noted that (1) the Organization's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327; and (2) in accordance with 2 CFR Part 180, contracts cannot be entered with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. It is recommended for the Organization to comply with the Organization’s internal procurement policies and the Uniform Guidance with respect to obtaining vendor quotes and retain support for a check of suspension and debarment. CLIENT PLANNED ACTION: 1. WellPower will review and align its procurement policy with Uniform Guidance compliance requirements for procurement, suspension & debarment. 2. WellPower will provide the necessary training on Uniform Guidance procurement compliance requirements to its procurement department and other authorized purchasers within the organization 3. WellPower will update its suspension & debarment check procedures and record keeping thereof, to ensure that SAM.gov checks of vendors are obtained prior to contract / purchase order issuance / purchase, and at a minimum annually. All records will be maintained with Procurement. CLIENT RESPONSIBLE PARTIES: Angela Oakley, VP & Chief Financial Officer Wes Williams, VP & Chief Information Officer COMPLETION DATE: May 31, 2025

View Audit 350276 Questioned Costs: $1

Finding 540446 (2024-005)

Material Weakness 2024

Hawaii Pacific University

HI

Questioned Costs Cash Management § 200.303 § 200.305

The University has policies and procedures to ensure the review of expenditures charged to federal grants prior to draw downs. However, the University failed to identify a mistake in a journal entry which resulted in a duplicate expense posting to the grant until after the draw down request had been...

The University has policies and procedures to ensure the review of expenditures charged to federal grants prior to draw downs. However, the University failed to identify a mistake in a journal entry which resulted in a duplicate expense posting to the grant until after the draw down request had been made. Specifically, the University charged prepaid amortization to a grant fund, although the expenditure had already been fully recorded to the grant fund. This resulted in a duplicated expense posting, one for the actual payment of the expenditure, and a second for the expense amortization. The University discovered the mistake after the duplicated expense had been drawn down. To correct this error, the University initiated the process to reduce a subsequent draw for the grant to ensure that overall, the grant is not overdrawn. Management reviewed the conditions which contributed to this error and is establishing the following controls to address this error: 1. The University will incorporate an additional review step for any journal entries posted to federal grants. The Office of Sponsored Projects and Business Office management will sign off on any journal entries which are posted to federal grants prior to the posting taking place. 2. The Business Office will reinforce existing procedures to all accounting staff responsible for prepaid expense accounting to ensure that prepaid expense is not recorded to federal grant funds. 3. The Office of Sponsored Projects will adjust its review process and train staff to ensure thorough review of all activities impacting grants, including journal entries made by the Business Office, before authorizing drawdowns. Person(s) Responsible: Assistant Vice President of the Office of Sponsored Projects. Controller & Associate Vice President. Targeted Correction Date: June 30, 2025.

View Audit 350256 Questioned Costs: $1

Finding 540401 (2024-014)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Eligibility Reporting

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Upon further review of the case, it was determined that the caseworker processed the case in “Manual Eligibility” mode which prevented the Kauhale On Line Eligibility Assistance System (“KOL...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Upon further review of the case, it was determined that the caseworker processed the case in “Manual Eligibility” mode which prevented the Kauhale On Line Eligibility Assistance System (“KOLEA”) from terminating benefits. Another worker removed “Manual Eligibility” mode in January enabling KOLEA to process the case and send a termination notice. The worker should have processed the case and taken the case out of “Manual Eligibility” mode when case processing was complete. Corrective Action Taken or Planned: The “Eligibility Determination” training module will be updated to include additional instructions for Manual Actions in the Kauhale On Line Eligibility Assistance System (“KOLEA”). Workers will be instructed to seek guidance from a supervisor for next steps, before running a case manually. This training will be provided on April 30, 2025, to all supervisors and caseworkers and will include a Participant Guide and a summary of the change. To ensure that the training was effective, a query will be run of all cases that are set to “manual,” including the date in which the case was placed in manual. Med-QUEST Division (“MQD”) will review all identified cases to determine if the case should remain in manual for any legitimate eligibility reason. Completion Date: April 30, 2025 Responding Official(s): Lori Lei Aponte, Med-QUEST Division, Eligibility Branch Administrator

View Audit 350226 Questioned Costs: $1

Finding 540398 (2024-013)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have al...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. Most providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. There are a few providers who did not re register by December 31, 2023, and these were primarily providers of exclusive or specific services who refused to enroll into HOKU. Not enrolling these providers will have a disruptive impact to the service delivery experience and greatly increase the costs to the program, by risking the Department having to send additional patients to the mainland to get the specialized medical care needed. The Department will be terminating these remaining providers by December 31, 2025. Additionally, the Department is planning to apply for an 1115 demonstration waiver amendment in 2025, to waive the 42 CFR 455.414 provider enrollment requirements for these few providers with exclusive services. Completion Date: December 31, 2025 Responding Official(s): Marvin Malohi, Med-QUEST Division, Supervising Contracts Specialist

View Audit 350226 Questioned Costs: $1

Finding 540397 (2024-012)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the Income Eligibility and Verification System (“IEVS”)…”. However, the policy does not specify the State agency must “properly us...

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the Income Eligibility and Verification System (“IEVS”)…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…” as notated in this finding under “Effect.” Unless IEVS provides the necessary information for the applicable benefit month(s) used to determine a TANF applicant’s or recipient’s (“client”) eligibility, information obtained through IEVS will only validate whether a household received an income source, after the fact, but will not verify the dollar amount. Hard-copy verification is obtained from the client to verify income source and dollar amount, for the applicable benefit months, to determine eligibility in accordance with §17 676-51, Hawaii Administrative Rules. For example, if a client applied for TANF on February 28, 2025, and the department processes the application on March 20, 2025 (current month), verification of the household’s income received in February 2025 and received thus far in March 2025, must be obtained to determine eligibility for the month of application (February 2025) and subsequent months (based on projected income). Data obtained from IEVS are not current; therefore, if the information obtained from IEVS is used to determine eligibility, then we would violate our own administrative policy (i.e., §17 676-51, Hawaii Administrative Rules). For example, wage information through SWICA becomes available on a quarterly basis. The most current SWICA information available would have been for quarter ending December 31, 2024, for an application received on February 28, 2025, that was processed on March 20, 2025. Eligibility determination would have been improperly made if SWICA information from IEVS was applied. Corrective Action Taken or Planned: The department will continue to conduct IEVS check. The information obtained will only be used to validate a source of income reported by the applicant/client IF the information is applicable. Completion Date: On going Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

View Audit 350226 Questioned Costs: $1

Finding 540396 (2024-011)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will collaborate with the division’s Staff Development Office to develop “refresher” ...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will collaborate with the division’s Staff Development Office to develop “refresher” training modules on the Benefit, Employment, and Support Services Division (“BESSD”) Learning Academy. Each training module will focus on a specific topic of concern. To monitor staff’s completion of the training modules and their progress, each module will include a quiz or test at the end that staff will be required to complete and pass (e.g., pass equates to a score of 80% and higher). The TANF Program Office and the Staff Development Office began discussions on February 26, 2025. Completion Date: December 31, 2025 Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

View Audit 350226 Questioned Costs: $1

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