Corrective Action Plans

Finding 380605 (2023-001)

None 2023

Town of Stow

MA

Questioned Costs Subrecipient Monitoring Reporting § 200.1

Condition: Obligations were overstated by $965,175 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: The overstated obligation error will be corrected in the next federal reporting period. Anticipated Completion Date: April 30, 2024 Contact: Denise M. Dembkoski,...

Condition: Obligations were overstated by $965,175 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: The overstated obligation error will be corrected in the next federal reporting period. Anticipated Completion Date: April 30, 2024 Contact: Denise M. Dembkoski, Town Administrator

View Audit 295369

Finding 380589 (2023-007)

Material Weakness 2023

Madison-Grant United School Corporation

IN

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

FINDING 2023-007 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronav...

FINDING 2023-007 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

View Audit 295346 Questioned Costs: $1

Finding 380575 (2023-005)

Material Weakness 2023

Madison-Grant United School Corporation

IN

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

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educational Agencies (i.e. the School Corporation), to assist them in providing special education and related services to eligible children with disabilities ages 3-21. IDEA’s Special Education – Preschool Grants program provides grants to states, and through them to LEAs to assist them in providing special education and related services to children with disabilities ages three to five and, at the state’s discretion, to twoyear- old children with disabilities who will turn three during the school year. The School Corporation did not have internal controls in place over payroll disbursements made from the special education funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-661-8807 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

View Audit 295346 Questioned Costs: $1

Finding 380557 (2023-002)

Material Weakness 2023

Madison-Grant United School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403 § 200.430

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Sum...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children. The cash reimbursement is to be used for the benefit of the food service program. The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024.

View Audit 295346 Questioned Costs: $1

Finding 380556 (2023-002)

Significant Deficiency 2023

School Town of Highland

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

FINDING 2023-002 Subject: COVID-19 Education Stabilization Fund – Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Number: S425U210013 Compliance Requirement: Allowable Costs Audit Findings...

FINDING 2023-002 Subject: COVID-19 Education Stabilization Fund – Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Number: S425U210013 Compliance Requirement: Allowable Costs Audit Findings: Significant Deficiency Condition: The School Corporation did not have internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. The School Corporation did not have adequate procedures in place to ensure that the expenditures charged to the grant were accurate and pertained to the Education Stabilization Fund. Context: The School Corporation requested a transfer of $54,886 from the School Lunch Fund to the Education Stabilization Fund to cover costs incurred for Grab & Go meals as a result of the COVID-19 Pandemic. Upon review of the supporting detail, the actual amount of expenditures for the Grab & Go meals was $30,293, resulting in over reporting of receipts in the amount of $24,593. This was due to a clerical error made by management that was not caught in the review process. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will transfer the over expenditure of $24,593 from the School Lunch Fund to the Education Stabilization Fund to correct the error. To make sure this type of error does not occur in the future; the district will change our internal control procedures to have a second person review and sign the transfer prior to entering the transfer into the financial software to ensure accuracy. Responsible Party and Timeline for Completion: The CFO will enter the corrective transfer and have it reviewed and signed off on by the Deputy Treasurer prior to February 29, 2024.

View Audit 295343 Questioned Costs: $1

Finding 380553 (2023-003)

None 2023

Kimball County

NE

Questioned Costs Allowable Costs / Cost Principles § 200.403 § 200.425

Program: AL 20.509 – Formula Grants for Rural Areas and Tribal Transit Program – Allowability Corrective Action Planned: The transit will work with NDOT and FTA to ensure cost allocations have proper documentation. Any items that may not seem clear cut will be reviewed by NDOT or mobility managemen...

Program: AL 20.509 – Formula Grants for Rural Areas and Tribal Transit Program – Allowability Corrective Action Planned: The transit will work with NDOT and FTA to ensure cost allocations have proper documentation. Any items that may not seem clear cut will be reviewed by NDOT or mobility management for feedback on the appropriateness of the expense reimbursement. Anticipated Completion Date: June 30, 2024 Responsible Party: Christy Warner, Transit Administrator

View Audit 295337 Questioned Costs: $1

Finding 380549 (2023-003)

Significant Deficiency 2023

River Kourt Apartments

OR

Questioned Costs Procurement, Suspension & Debarment HUD Housing Programs § 200.318 § 200.320

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all ...

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 2. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance, ShelterCare 3. The anticipated completion date: a. The written policies will be updated by 05/01/2024.

View Audit 295334

Finding 380548 (2023-002)

Significant Deficiency 2023

River Kourt Apartments

OR

Questioned Costs HUD Housing Programs Reporting

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. ShelterCare, as managing agent, has hired a new property accountant which should help with keeping the books current and ShelterCare prepared to start audit work mid-July and be ready to submit the audit to HU...

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. ShelterCare, as managing agent, has hired a new property accountant which should help with keeping the books current and ShelterCare prepared to start audit work mid-July and be ready to submit the audit to HUD within 90 days of the fiscal year end. 2. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance, ShelterCare 3. The anticipated completion date: a. New property accountant was hired in August of 2023.

View Audit 295334

Finding 380546 (2023-001)

Material Weakness 2023

Corry Memorial Hospital Association D/b/a Lecom Health Corry Memorial

PA

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.303

Condition The Organization did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Organization erroneously excluded certain transactions from the lost revenue calculation, resulting in lost revenues being overstated $95,765...

Condition The Organization did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Organization erroneously excluded certain transactions from the lost revenue calculation, resulting in lost revenues being overstated $95,765. The Organization reported lost revenues amounting to $471,219 on distributions totaling $925,113. The Organization had excess lost revenues from previous periods available to be used through June 30, 2023 amounting to $1,218,904. Corrective Action Plan Corrective Action Planned: The Organization will update its policies and procedures to ensure the submission undergoes a detailed review and that all points are cleared prior to submission. Name(s) of Contact Person(s) Responsible for Corrective Action: Tim McGahen, Chief Financial Officer Anticipated Completion Date: We anticipate that this will be completed by June 30, 2024.

View Audit 295333

Finding 380528 (2023-001)

Significant Deficiency 2023

Claremont Unified School District

CA

Eligibility HUD Housing Programs School Nutrition Programs

II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 50000 - ELIGIBILITY Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. M...

II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 50000 - ELIGIBILITY Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023

View Audit 295319

Finding 380526 (2023-001)

Significant Deficiency 2023

Continuum of Care, Inc. and Affiliates

CT

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon performing testing over payroll disbursements, we noted that there was no approval of the timesheet for the payroll disbursements tested. Questioned costs: None Context: The timesheet for 4 out of 4 payroll disbursements tested was not properly approved by the property manager. Cause: Turnover of property manager at the property management company and weaknesses in internal controls over payroll disbursements. Effect: There is no evidence of proper approval of payroll disbursement. Repeat Finding: Yes Recommendation: We recommend that management strengthen controls over review of payroll. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding: Although other controls and reviews around compensation help safeguard and mitigate compensation errors, the property manager will ensure that all time sheets are properly approved prior to payment as a first line of internal controls. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: May 30, 2024.

View Audit 295318

Finding 380524 (2023-001)

Significant Deficiency 2023

Margaret B. MacK Supportive Housing Corporation Hud Proj. #017-Hd038

CT

Internal Control / Segregation of Duties Questioned Costs Significant Deficiency

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management establish the residual receipt account and make the required deposit as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the ...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management establish the residual receipt account and make the required deposit as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A residual receipt account has been established. Required deposit will be made by May 30, 2024. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: Required deposit will be made by May 30, 2024.

View Audit 295316

Finding 380517 (2023-004)

Material Weakness 2023

City of Ottawa

IL

Questioned Costs Subrecipient Monitoring Cash Management § 200.502

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. City will also review with prior City Auditors to ensure proper overall proce...

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. City will also review with prior City Auditors to ensure proper overall procedures are in place to ensure all grants in the aggregate are monitored. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

View Audit 295284

Finding 380516 (2023-003)

Significant Deficiency 2023

City of Ottawa

IL

Internal Control / Segregation of Duties Questioned Costs Procurement, Suspension & Debarment

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly...

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

View Audit 295284

Finding 380489 (2023-003)

Material Weakness 2023

Lanesville Community School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles School Nutrition Programs § 200.303

Finding 2023-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the find...

Finding 2023-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will review all food service payroll charges to ensure only payroll related to food service duties is charged to the child nutrition cluster program. Anticipated Completion Date: April 2024

View Audit 295238 Questioned Costs: $1

Finding 380462 (2023-002)

Material Weakness 2023

Northern Cambria School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.320

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as we...

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

View Audit 295236 Questioned Costs: $1

Finding 380455 (2023-006)

Material Weakness 2023

Northern Cambria School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.403

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will ensure that all future purchases will comply with Board policy 626 for procurement – federal programs, by processing a purchase order for all purchases regardless of the type of award or purchase. The timeframe for implementation will commence d...

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will ensure that all future purchases will comply with Board policy 626 for procurement – federal programs, by processing a purchase order for all purchases regardless of the type of award or purchase. The timeframe for implementation will commence during the remaining months of the 2023-2024 fiscal year and extend to all future fiscal years.

View Audit 295236 Questioned Costs: $1

Finding 380454 (2023-005)

Material Weakness 2023

Northern Cambria School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.214 § 200.237

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update, as necessary, its current procurement policies and procedures to ensure compliance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements. In specific, this procedure will ensure that the terms and cond...

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update, as necessary, its current procurement policies and procedures to ensure compliance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements. In specific, this procedure will ensure that the terms and conditions required by Subpart D are included as part of all future contracts involving the use of federal assistance. This procedure will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

View Audit 295236 Questioned Costs: $1

Finding 380451 (2023-001)

Material Weakness 2023

Northern Cambria School District

PA

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.439

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will complete the Prior Approval Form for the Pennsylvania Department of Education (PDE) and obtain approval from PDE in advance of incurring any future federally funded expenditures, that meet PDE’s criteria as a capital purchase, to ensure complianc...

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will complete the Prior Approval Form for the Pennsylvania Department of Education (PDE) and obtain approval from PDE in advance of incurring any future federally funded expenditures, that meet PDE’s criteria as a capital purchase, to ensure compliance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance. This procedure will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future applicable capital purchases.

View Audit 295236 Questioned Costs: $1

Finding 380439 (2023-003)

Material Weakness 2023

Michigan State University

MI

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

Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated proce...

Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: 01/01/2024

View Audit 295211

Finding 380432 (2023-002)

Material Weakness 2023

Michigan State University

MI

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

Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by t...

Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the university is revising its policies and procedures, specifically as they relate to “medical withdrawals” and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses, and students who rescind their intent to withdraw, or enroll in or attend subsequent modules. Contact person responsible for corrective action: Steve Shablin - University Registrar, Matthew Lyth - Financial Aid Officer Anticipated Completion Date: 05/10/2024

View Audit 295211 Questioned Costs: $1

Finding 380420 (2023-002)

Significant Deficiency 2023

Milwaukee Institute of Art and Design, Inc.

WI

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-002 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and significant de...

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-002 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and significant deficiency in control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for safeguarding sensitive data under the Gramm-Leach-Bliley Act, including performing an annual risk assessment that addresses three required areas noted in 16 Code of Federal Regulations (CFR) 314.4 (b). Statement of Condition: The Institute performed a risk assessment however the safeguards for the risks identified were not formally documented through a policy. A formal policy was not reviewed in fiscal year 2023 which would have addressed required areas noted in 16 CFR 314.4 (b). Questioned Costs: Questioned costs could not be determined. Context: A policy and documentation linking the safeguards to the risk assessment was not formally written. The internal controls over compliance at the Institute did not identify the noncompliance. However, the Institute performed risk assessments and has appropriate safeguards for each area identified within 16 CFR 314.4(b). Cause: The Institute did not have internal controls in place to identify the need for the policy documenting the safeguards required by the Gramm-Leach-Bliley Act. Effect: The Institute has no verifiable evidence of the policy and the related safeguards for each risk identified. Recommendation: We recommend management review 16 CFR 314.4 (b) to create a policy that addresses the three required areas, which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. This policy should be formalized and reviewed annually. We recommend that the Institute document the approval and acceptance of the policy. In addition, we recommend management review internal control processes for special tests and provisions on an annual basis. Status: In progress, anticipated completion September 2024 Corrective Action: Management agrees with the finding. We are currently developing a comprehensive cybersecurity policy to address 16 CFR 314.4 (b), which will be formalized, approved by Senior Staff, and reviewed annually. We are now conducting annual penetration tests, the most recent in December 2023, to address internal control processes. We have contracted with a planning team at CDW to determine best practices and perform training. We have begun providing a quarterly GLBA Compliance update to our board, with an annual comprehensive GLBA review to the board. Contact Matt Ogden Director of Technology 414.847.3223 mattogden@miad.edu Submitted Feb 23, 2024

View Audit 295200

Finding 380419 (2023-001)

Material Weakness 2023

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Questioned Costs Special Tests & Provisions

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakn...

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024

View Audit 295200

Finding 377380 (2023-005)

Significant Deficiency 2023

University of California

CA

Questioned Costs Cash Management § 200.303 § 200.305

2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Eme...

2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion Assistance Listing Numbers: 84.425E and 84.425F Award Year: 2022-2023 Pass-through entity: Not applicable Cash Management Interest in the amount of $172,641.83 was remitted to DHHS on December 8, 2023. Effective June 2022, a new standard operating procedure (SOP) was implemented requiring a full reconciliation of costs prior to drawdowns to ensure only actual costs are drawn. The reconciliation must also be reviewed and approved by the Project Portfolio Financial Management Supervisor prior to the draw. The SOP applies to all Federal draws and therefore would apply to any “ad hoc” emergency programs moving forward. Eligibility In the event of any future “ad hoc" emergency federal programs with eligibility requirements, our policy has been updated as of 2/13/2024 to require two approvals and to document the approvals. • The reports used to determine student eligibility will be written and implemented by the Assistant Director of Financial Aid Systems. • The Deputy Director will then direct the awarding of direct grant payments which is executed by the Financial Aid Systems team. • Payments awarded to cover balances will be awarded by various members of the Financial Aid team during the processing of special circumstance appeals. Period of Performance As a result of the unallowable cost, the University took the following action in February 2024: • The Vice Chancellor for Student Affairs (VCSA) conducted a comprehensive review of current financial management policies and processes with specific attention to grant expenditure guidelines and timelines and provided training and educational resources to VCSA office staff since they do not ordinarily have responsibility for federal funding. Specifically, VCSA office staff have been trained on federal cost principles and now have responsibility for reviewing expense requests for allowability and allocability. Policies, training documents, and all resources developed as a result of this effort have been saved to a shared location for future reference. • Additionally, the unallowable charge identified in the audit was reversed and HEERF balance instead used for lost revenue previously accrued but not claimed. Reporting The Office of Financial Aid and Scholarships (OFAS) conducted a comprehensive review of the reporting process for HEERF and in October of 2023, established and documented a more systematic approach to reconcile the reports to the underlying data. At this time, updates to the 2022-2023 quarterly HEERF reports were also made. For inquiries regarding this finding, please contact Amanda Preston-Nelson at anelson10@ucmerced.edu who is responsible for the corrective action.

View Audit 295197 Questioned Costs: $1

Finding 377379 (2023-002)

None 2023

University of California

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

2023-002 – Transfer of costs from HEERF to FEMA not reported in HEERF quarterly report Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) – Institutional Portion Award Number: P425F202631 - 20B Assistance ...

2023-002 – Transfer of costs from HEERF to FEMA not reported in HEERF quarterly report Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) – Institutional Portion Award Number: P425F202631 - 20B Assistance Listing Title: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425F Award Year: 2020-2021 Pass-through entity: Not applicable The campus amended the March 31, 2021, quarterly HEERF institutional report by prominently highlighting the modifications. • A revised report has been uploaded to the campus website (UCLA Financial Aid and Scholarships – HEERF Institutional Portion Reports) alongside the other completed quarterly HEERF reports. • In accordance with ED guidelines, the old report has been replaced with the updated version, clearly indicating the date of the revision. For inquiries regarding this finding, please contact Selina Martin at selinamartin@finance.ucla.edu who is responsible for the corrective action.

View Audit 295197

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