Corrective Action Plans

As part of the 2023-2024 FY audit, there was a finding of non-compliance on financial reporting for a late filing. The corrective action plan is to implement new policies to ensure timely financial compliance with all grant requirements. For questions, please contact Katie Harris, the Director of Finance. The board plans to enact these new policies as of June 30th, 2025.

Current Year Audit Findings: 2024-006 Questioned Cost – Employee Stipends (Federal Single Audit) Corrective Action Planned: The district will keep complete financial records and any stipend amount for federal funds will be signed off by the Superintendent and noted in each employees HR file. Anticipated Completion Date: 08/31/2025 Contact Person(s): Eric Tober, Addison Kraus and Dr Brian McCraw.

Corrective Action Plan: The District will follow the guidance provided by the Department of Elementary and Secondary Education (DESE) regarding the Federal program expenditures and ensure the proper internal controls are in place. Anticipated Completion Date: December 31, 2024.

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority's files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 9,051 units. Of a sample size of eighty-nine (89) tenant files, the following was noted: • HUD-9886 Authorization for Release of lnformation was missing in 4 files Our sample size is statistically valid. Known Questioned Costs: $24,363 Cause: There is significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: Of the Eighty Nine (89) tenant files audited, four (4) tenant files contained a deficiency in the same indicator---the Authorization for the Release of lnformation/ Privacy Act Notice (HUD Form 9886) retained in the tenant file was executed after the audit date range, not within the audit period (4/1/23- 3/31/24) or within the three months prior. The HACCC discovered two contributing factors for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. First, the HACCC's Housing Choice Voucher program entered into a partnership with Paul Edwards Management and Consulting (PEM) on May 1st 2024. This partnership provides the HACCC's Housing Choice Voucher program with technical assistance and coverage of vacant positions within the Housing Choice Voucher program Continued Eligibility team. The PEM team members assigned to Continued Eligibility are responsible for completing timely Annual Recertifications for all assigned Housing Choice Voucher program participants---including the collection of any signature documents required by HUD annually. To ensure compliance with this requirement, contract performance indicators related to those positions temporarily assigned to PEM (including the timeliness of Annual Recertifications and a consolidated report of findings within the Electronic File Protocol Quality Control Audit Checklists) will be included in a corrective action plan. The enhanced monitoring provided by the corrective action plan will a) ensure the continued collection of the performance indicator data and b) provide timely feedback regarding the partnerships ability to mediate the deficiency. Second, HUD removed the expiration date from the 9886 form. Effective 01/01/2024, HUD requires Housing Authorities to collect a signature on the 9886 form once throughout the course of participation instead of requiring Housing Authorities to collect a signature on the form annually (or every 15 months). HUD issued PIH Notice 2023-27 on 09/29/2023. The notice indicated "In accordance with the final rule, all applicants must sign the consent form at admission, and participants must sign the consent form no later than their next interim or regularly scheduled income reexamination. After an applicant or participant has signed and submitted a consent form either on or after January 1, 2024 (regardless of the PHA/MFH Owner's compliance date), they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination ... ". The HACCC' s Housing Choice Voucher program began to request tenant signatures on the updated 9886 form effective 1/1/2024 (within our online recertification workflows) and effective 3/29/24 (within our paper recertification packets). Internal procedures for the storage of electronic documents ("HACCC Electronic File Protocol") related to the 9886 form were updated in accordance with the change, to in effect, retain the 9886 document as any other "vital document" or one-time verification would be stored and retained (ex. birth certificate, social security card, etc)--- storing and retaining only the most recent version of the document. The HACCC agrees that the requirement to retain a 9886 executed within the audit date range for these 4 files was not fulfilled despite the above-mentioned updates taking place within the audit date range. To ensure compliance with this requirement, Electronic File Protocol QC Checklist Procedure Training will be included in a corrective action plan. The training requirement will a) ensure the continued collection and review of the Electronic File Protocol Quality Control reports and b) provide timely feedback regarding whether having a single retention requirement applied throughout an entire fiscal year will effectively mediate this deficiency. We agree with the Auditor's observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

Finding 2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority's files and on discussions with management, the Authority did not properly abate one (1) out of thirty-seven (37) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of thirty-seven (37) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Our sample size is statistically valid. Known Questioned Costs: $398 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA). Effect: The Housing Voucher Cluster is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views ofresponsible officials and planned corrective action: Of the Thirty-Seven (37) tenant files audited, one (1) tenant file contained a deficiency--- the file did not contain adequate verification of the abatement cure request date justifying the HACCC's subsequent cancellation of this abatement after the deficiencies were verified as corrected. The HACCC discovered a contributing factor for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. HUD requires HACCC's Housing Choice Voucher program to abate (permanently withhold) housing assistance payments no later than the first of the month following the specified correction period (including any approved extension) when HQS deficiencies are discovered during biennial HQS inspections of subsidized units. To improve housing opportunities to families with vouchers and support landlord retention on our programs, the HACCC (in accordance with applicable regulations) offers to end the period of HAP abatement "effective on the earlier of the day the unit passes inspection or the date the correction was reported completed' as a courtesy. In this case, the unit failed inspection for non-life threatening deficiencies (ex. overgrown grass) on 6/20/2023. The deficiencies were not corrected prior to the reinspection which took place on 7/18/2023, prompting the placement of a HAP abatement on 7/26/2023 to withhold all HAP payments effective 8/1/2023 on. A reinspection was requested and the unit passed inspection in August. On 8/31/23 the abatement was subsequently cancelled in the HACCC's software and a memo was entered indicating that the landlord had requested the abatement cure reinspection prior to the abatement effective date of 8/1/23. However, it was discovered that the necessary verification of this abatement cure request was not attached to the tenant record. Due to the HACCC's inability to reproduce verification of the request date (being earlier than the day the unit passed inspection), the HACCC agrees with this finding. To ensure compliance with this requirement, the Internal HCV Inspection Procures will be updated to include systems for ensuring that necessary verification of any abatement cure request date is stored. A File Memo containing a timeline and necessary verification ofrequest date will be submitted to a manager for approval any time an abatement is ended or cancelled. The manager will be responsible for storing the executed File Memo and verification in the tenant file. The Authority has recognized the deficiencies in the Housing Voucher Cluster and has implemented internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

In response to the findings on the andit of federal programs the district will implement the following: Each month when reporting our financials all federal grant accounts will be separated and will be reviewed for accuracy and to insure proper project codes are correct also expenditures for 1 % professional development will be reviewed for accuracy. All payment request for federal fund grants will be approved prior to submission by the Superintendent. Ann Wallace will provide this listing to the Superintendent for approval each month. Corrective Action Plan has been implemented July 25, 2024.

When cash becomes available, the Organization will deposit the underfunded amount into the replacement reserve account.

Condition: The District was not in compliance with the Uniform Guidance as it was noted that management of the District was not preparing time and effort distribution records and could not produce source documentation to support the time and effort applied to payroll expense that was charged to Title I Grants to Local Education Agencies. Cause: The District's internal controls to identify and document employees that require support for time and effort charged to Title I Grants to Local Education Agencies were not effective for the year ended June 30, 2024. Auditor Recommendation: We recommend the District review their internal controls to strengthen processes and improve procedures. We recommend the District complete all required time and effort certiflcations in a timely manner. Plan of Action: Ashland School District will identify administrative-level staff to oversee federal programs, including Title I, to ensure compliance with all relevant Uniform Guidance activities. District and building staff will review guidelines and documentation requirements for all federal programs to improve record keeping and to allow appropriate review of federal program activities. Date of lmplementation: lmmediately and ongoing.

2024-003 Reporting Federal Assistance Listing Number: 10.553, 10.555, and 10.559 Program: Child Nutrition Cluster Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Pass-Through Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $4,397.30 of underreported claims Repeat Finding: This is not a repeat finding. Condition/Context: The District did not properly calculate, and report meal claims accurately for three of 4 months selected during the current year. This led to the District under-reporting $4,397.30 in student meal claims. Criteria: The Uniform Guidance compliance supplement. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines. Child Nutrition Program claim forms should be supported by documentation showing the number of meals for which reimbursement was requested and document that the meals were served prior to the date of the reimbursement request. The claim reports should be filed on a timely basis. Corrective Action: The District will implement review procedures as part of the meal claim process to ensure claims reported match with District records. The District will ensure any over/under reporting is investigated and resolved in a timely manner. The District will review reports from FY24 and ensure any unclaimed meals are properly reconciled, as applicable. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Lori Wilson, Business Manager

Management should implement a procedure requiring authorization and approval from Chief Financial Officer, Chief Executive Officer or Chief Operating Officer for all nonrecurring purchases prior to initiation of the purchase.

Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.

Finding: 2024-008 Name of contact person: Dr. Justin Hoggard, Board President and CFO Corrective Action: Management will reconcile student fees to actual activity each year. Proposed Completion Date: April 30, 2025 Anticipated Completion: April 30, 2025

In the future, we intend to advertise for a longer period of time and if needed re-advertise for a second job walk. We will note each company that attends and if they did or did not chose to bid the job. The documentation of each bid and the board approval for the awarded bid will now be maintained at both the Construction, Maintenance, and Operations Department and the District Office to lessen the loss of documentation due to employee turnover.

The district has been and will continue to follow the guidelines and regulations for the grants awarded and will continue to review the documentation provided to support the claims for reimbursements for accuracy.

2024-007 - Student Financial Aid Cluster- (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not accurately complete refund calculations for 1 out of 9 students (11.1%) tested. Additionally, funds were not timely returned and withdrawal dates were not timely determined for three out of nine students (33%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-003. Corrective Action Plan Montreat College is reviewing the faculty record-keeping process and the Registrar's Office’s Last Date of Attendance (LDA) data confirmation. LDAs must be reported accurately and reported in a timely manner. Student Financial Services is developing a two-person process where two staff members review all Return to Title IV funds (R2T4). Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Stephanie Connelly, Assistant Director of Records & Registration Marie Wisner, Associate Dean for Calling & Career Montreat Cabinet Implementation Date of Corrective Action Plan June 30, 2025

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2025.

HUD Section 202, Capital Advance – Assistance Listing No. 14.157 Recommendation: Management should implement a review process of the management fee rate upon any changes to that rate or system utilized to calculate that rate to ensure the HUD approved rate is utilized. Management should repay the amount due the Organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The controller will annually review the calculation of the management fee that is being billed to the property by the accounting manager to validate the amount is in compliance with HUD form 9839-B. The overpayment from fiscal year 2024 was corrected in October 2024 Name of the contact person responsible for corrective action: Troy Marschel. Planned completion date for corrective action plan: 10/1/2024

Management agrees with the finding and has made the transfer of cash back to the property.

Management agrees with the finding and will request that the surplus cash payment be returned to the property.

FINDING #2024-002: EDUCATION STABILIZATION FUNDS – EQUIPMENT AND OTHER CAPITAL EXPENDITURES (5000) Corrective Action Plan: Compton USD will act with diligence and care. Under the new Director of Fiscal Services, a pre-approval checklist for all grant expenditures, including mandatory CDE approval for equipment and capital expenditures, has been implemented.

Authority Response: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designated to be responsible for implementing this corrective action by March 31, 2025.

Authority Response: The Authority has recognized the significant deficiency in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designated to be responsible for implementing this corrective action by March 31, 2025.

U.S. Department of Education Clinton School District #124 respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Daniel Brungardt, Superintendent Clinton School District #124 Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2024-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements. Action Taken: Over the last five years, the school district's fund increased due to securing a contract at a low initial rate, while also benefiting from higher reimbursement rates and increased participation. This year, the district will once again go through the rebid process, and the estimated increase in costs is expected to range from 10% to 15%. This increase will likely surpass the amount the district receives in reimbursements, leading to a budget deficit. Additionally, student participation in the lunch program has declined over the years.

Below are the participation percentage rates. Current Participation Rates for Oct 2024 (percentages) HS - 52.53 lunch with 56.38 being free/reduced 36.64 breakfast with 62.5 being free/reduced MS- 66.94 lunch with 62 being free/reduced 23.42 breakfast with 82.85 being free/reduced CIS - 65.48 lunch with 73.70 being free/reduced 44.38 breakfast with 78.07 being free/reduced HE - 70.41 lunch with 74.53 being free/reduced 47.93 breakfast with 76.72 being free/reduced Participation Rates from Oct 2019 (percentages) HS - 59.03 lunch with 52.65 being free/reduced 32.23 breakfast with 69.64 being free/reduced MS- 69.74 lunch with 68.01 being free/reduced 55.13 breakfast with 72.28 being free/reduced CIS - 77.87 lunch with 72.29 being free/reduced 44.54 breakfast with 83.43 being free/reduced HE - 76.88 lunch with 71.27 being free/reduced         45.09 breakfast with 84 being free/reduced Additionally, during the rebid process, the school district will seek companies that have successfully increased participation, as this could also impact the overall cost of the program. The district will reduce the fund based on the following: Increased Contract Costs: District administration believes that through the rebid process and the new contract, the district will achieve at least a 10% reduction in contract costs. Indirect Costs: The school district has not been claiming indirect costs as part of its food service allocation in the past. However, beginning next year, the district will start including indirect costs in its food service budget. This change will help ensure that the full scope of expenses associated with operating the food service program is accounted for, providing a more accurate reflection of the program’s financial needs New Equipment: The district operates four kitchens, with only one having received upgrades in the past 10 years. A list of necessary equipment upgrades has been compiled. Below is a forecast of additional costs for the next three years, along with the equipment that will be purchased that will reduce the food service budget by $940.874.48