Corrective Action Plans

Finding 12950 (2022-002)

Significant Deficiency 2022

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Questioned Costs Reporting Significant Deficiency

Finding 2022-002 Federal Agency Name: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds Program CFDA # 21.027 Finding Summary: Management has designed internal controls related to reporting, however, the controls were not formally documented. Responsible Individu...

Finding 2022-002 Federal Agency Name: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds Program CFDA # 21.027 Finding Summary: Management has designed internal controls related to reporting, however, the controls were not formally documented. Responsible Individuals: Thomas Krolak Corrective Action Plan: A review of required reports will be done for each federal grant and the appropriate staff will be assigned to review and approved reports prior to submission Anticipated Completion Date: June 30, 2023

View Audit 17083

Finding 12938 (2022-002)

Significant Deficiency 2022

Irvington Community Schools, Inc.

IN

Subrecipient Monitoring Questioned Costs Matching / Level of Effort / Earmarking § 200.334

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of thre...

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Management Corrective Action: While the school?s annual total meals served for the 2021-22 audit year were more than the meals claimed for reimbursement, the school was unable to reconcile all of the individual months. The school has since implemented and automated system to record lunches served. This point-of-sale system will eliminate the ongoing monthly accounting required to support monthly claims assuring the numbers served reconciles with the numbers claimed. Chris Ashmore has already implemented this system and tested the subsequent year-to-date audit period to assure this corrective action has, in fact, eliminated the problem.

View Audit 18123

Finding 12890 (2022-002)

Significant Deficiency 2022

Cambridge Community Unit School District No. 227

IL

Internal Control / Segregation of Duties Questioned Costs Cash Management

Condition: Monthly Claim for Reimbursement included second meal claims in excess of two percent of the number of first meals served to children for each meal type. Plan: Implement additional procedures to ensure t...

Condition: Monthly Claim for Reimbursement included second meal claims in excess of two percent of the number of first meals served to children for each meal type. Plan: Implement additional procedures to ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement such as but not limited to training and conferences. Additionally, the District should contact the Illinois State Board of Education for further recommendation on this finding. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: There is no disagreement with this finding and procedures will be implemented. The District will contact the Illinois State Board of Education for further recommendation.

View Audit 17428

Finding 12889 (2022-003)

Significant Deficiency 2022

Cambridge Community Unit School District No. 227

IL

Internal Control / Segregation of Duties Questioned Costs Procurement, Suspension & Debarment § 200.501 § 200.516

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regard...

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regarding this discrepancy. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: The District agrees that the expenditures claimed on the June 30, 2021 expenditure report was overstated by $10,678 and in the future will review and reconcile the expenditure reports to the accounting records before submitting to ISBE.

View Audit 17428

Finding 12888 (2022-001)

Material Weakness 2022

Eastway Corporation

OH

Questioned Costs Reporting Internal Control / Segregation of Duties

2022-001 (a) Comments on Findings and Recommendations: While management concurs with the finding and auditors? recommendation to enhance internal controls to ensure reports are filed timely, it believes the failure to report the Period 2 funds was not due to neglect but simply due to the untimely de...

2022-001 (a) Comments on Findings and Recommendations: While management concurs with the finding and auditors? recommendation to enhance internal controls to ensure reports are filed timely, it believes the failure to report the Period 2 funds was not due to neglect but simply due to the untimely death of an employee. After the death of the Organization?s employee, management called the HRSA Provider Support Line, prior to the original due date of the reporting deadline, and was told that all reports had been filed. The Organization is currently working with HRSA to determine if an exception to the late filing can be obtained for reasonable cause based upon the previously mentioned circumstances. The Organization believes it has fully earned the Provider Relief Funds as it had sufficient lost revenues to support the need for the funding. (b) Action(s) Taken or Planned: Management is aware of the requirements related to the reporting submission. Management intends to implement proper procedures and policies for all grant reporting by June 30, 2023. Furthermore, internal controls over the program are being strengthened to prevent future non-compliance.

View Audit 17350 Questioned Costs: $1

Finding 12885 (2022-003)

Significant Deficiency 2022

Chief Dull Knife College

MT

Questioned Costs Reporting

Finding 2022-3: Reporting Requirements Reporting Requirements: Chief Dull Knife College will continue to review reporting requirements for all grants received. HEERF reports were posted to the College's website, but ...

Finding 2022-3: Reporting Requirements Reporting Requirements: Chief Dull Knife College will continue to review reporting requirements for all grants received. HEERF reports were posted to the College's website, but were not kept concurrent as they were required to be, but instead were replaced with the current report only, this procedure is being corrected and reviewed.

View Audit 17194

Finding 12884 (2022-002)

Material Weakness 2022

Chief Dull Knife College

MT

Cash Management Questioned Costs Procurement, Suspension & Debarment

Finding 2022-2: Cash Management Cash Management: As is the case with most higher education institutions and governmental entities, the College has struggled with the COVID pandemic and its aftermath. Essenti...

Finding 2022-2: Cash Management Cash Management: As is the case with most higher education institutions and governmental entities, the College has struggled with the COVID pandemic and its aftermath. Essential functions were disrupted, including several key accounting, finance, functions due to employees being out sick. Chief Dull Knife College had a discrepancy occur when drawing down funds in which it was done in error twice. The College had more than sufficient money in the bank to cover all of their expenses so this money was not used to cover any expenses. The College will be sure to assign duties to other employees to prevent this type of occurrence. Chief Dull Knife College takes the responsibility of drawing money from Grant Programs very crucial and will make all efforts and policies to ensure this type of error does not occur.

View Audit 17194 Questioned Costs: $1

Finding 12882 (2022-001)

Significant Deficiency 2022

Capitol Region Education Council

CT

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Government Officials Capitol Region Education Council respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 202 - June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numb...

Government Officials Capitol Region Education Council respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 202 - June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no findings in the current year that require a corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2022-001 Title I Grants to Local Educational Agencies ? Assistance Listing No. 84.010 Recommendation: We recommend that the policies and procedures related to approval process be followed to ensure that all exit forms have the proper approvals for removing a student from the adjusted regulatory cohort. Explanation of disagreement with audit finding: To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminated in the award of a regular high school diploma. From the 40 selections tested, there was 1 student for which no written documentation was maintained including parent or guardian signature to support that the student either transferred out, emigrated to another country, transferred to a prison or juvenile facility, or was deceased. Action taken in response to finding: CREC has considered the recommendations and will organize training of school and staff who work with student records that will include instruction on student withdrawal procedures. SDE and CREC accepts the request for a transcript from the receiving district as documentation for the withdrawal of the student from a CREC school. Name(s) of the contact person(s) responsible for corrective action: Jeff Ivory, Comptroller, (860) 524-4068 Planned completion date for corrective action plan: June 30, 2023

View Audit 17158

Finding 12873 (2022-001)

Significant Deficiency 2022

Hall County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.403

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Im...

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.4250 - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $116,610 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with the auditor?s reasoning that the contract terms for services should have been modified to reflect the one-time retention payments for contracted custodial personnel. Retention of contracted custodial staff members was deemed by the District to be an essential part of its effort to ensure clean, sanitary facilities in response to COVID-19 pandemic. ? The District has several internal controls in place to determine and verify the allowability of ESSER expenditures, which include: ? Authorization by the Hall County Board of Education. ? Authorization by the Georgia Department of Education through the ESSER program?s consolidated application. ? Approval of all ESSER payments and purchase orders by relevant personnel familiar with the allowability requirements of the ESSER program. ? Approval of all ESSER contract agreements by relevant personnel familiar with the allowability requirement of the ESER program. ? Documented protocols for determining District personnel eligible to be paid through ESSER funds. The District will conduct a review of its contract with third party service providers to ensure compliance with Uniform Grant Guidance. The District currently has no further plans for the provision of additional retention payments to contracted personnel using ESSER funds, and no additional corrective action is anticipated to be required for the isolated instance. Estimated Completion Date: March 31, 2023 Contact Person: Jonathan C. Boykin Telephone: 770-534-1080 Email: jonathan.boykin@hallco.org

View Audit 17388 Questioned Costs: $1

Finding 12867 (2022-004)

Material Weakness 2022

Wagner Community Memorial Hospital

SD

Special Tests & Provisions Questioned Costs Subrecipient Monitoring § 200.303

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of t...

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of the United States Finding Summary: Management maintained a reserve account in a pooled investment fund which includes marketable securities backed by the full faith and credit of the United States, but based on the portfolio mix of the investment pool, was not adequate to cover the entire reserve requirement. In addition, we had not established a separate bookkeeping account and/or a separate bank account. Responsible Individuals: Bryan Slaba, Chief Executive Officer Corrective Action Plan: A separate savings account backed by the full faith and credit of the United States and bookkeeping account will be established. Anticipated Completion Date: 12/31/2022

View Audit 17145

Finding 12864 (2022-002)

Significant Deficiency 2022

Partnership Health Center

MT

Questioned Costs

Condition: The Center did not properly follow its sliding fee scale policy and procedures for patients that applied for a sliding fee discount and did not properly maintain documentation to support qualifications and the sliding fee discount received. Criteria: The Health Center Program Compliance...

Condition: The Center did not properly follow its sliding fee scale policy and procedures for patients that applied for a sliding fee discount and did not properly maintain documentation to support qualifications and the sliding fee discount received. Criteria: The Health Center Program Compliance Manual requires a health center to have operating procedures for assessing and re-assessing all patients for income and family size consistent with approved sliding fee discount program policies. Management Response to Findings: As an FQHC, the Center is required to have operating procedures for assessing and re-assessing patients for sliding fee discounts. During FY2021, the Center identified system limitations that made the sliding fee discount program application ineffective. In response to the limitations, the Center implemented a different sliding fee discount structure on April 1, 2022, in FY2022, and continued internal audits to review the application of current policies and procedures. The Center acknowledges that the sliding fee scale workflow resides in two departments, and current structures and processes are ineffective in the handling and correction of deficiencies. The Center hired two people with direct duties of setting the sliding fee scale assessments. These focused work duties will increase the accuracy and efficiencies of setting the assessments. Timing of corrective action: As of April 1, 2022, the Center has simplified the sliding fee discount structure to address system-generated errors in discount application. As of September 30, 2022 the Center has implemented an improved structure for sliding fee scale training and assessment. As of January 2023 the Center hired two people with focused work duties for setting sliding fee scale assessments. As of March 2023 the Center has enhanced internal audit procedures in place. Contact: Bryan Chalmers, Chief Finance Officer, Partnership Health Center, 401 Railroad Street W., Missoula, MT 59802; chalmersb@phc.missoula.mt.us, (406)258-4445

View Audit 17094

Finding 12859 (2022-006)

Material Weakness 2022

Veterans Northeast Outreach Center, Inc.

MA

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

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resour...

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

View Audit 17771

Finding 12858 (2022-005)

Material Weakness 2022

Veterans Northeast Outreach Center, Inc.

MA

Internal Control / Segregation of Duties Questioned Costs Matching / Level of Effort / Earmarking

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resour...

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

View Audit 17771

Finding 12856 (2022-001)

Material Weakness 2022

City of Bristol, Connecticut

CT

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.326

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-001 Procurement Description of Finding The City is required to utilize a sealed bidding process...

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-001 Procurement Description of Finding The City is required to utilize a sealed bidding process for expenditures in excess of the $250,000 threshold per Uniform Guidance. As a result of our testing, we noted two vendors with expenditures in excess of the threshold which did not utilize the sealed bidding process. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action Corrective action will be taken to ensure the correct procurement procedures are followed. Name of Contact Person Lynn Boisvert, Director of Finance and Operations Projected Completion Date June 30, 2023

View Audit 17761 Questioned Costs: $1

Finding 12853 (2022-001)

Significant Deficiency 2022

Maine Technology Insititute

ME

Questioned Costs Procurement, Suspension & Debarment

Responsible Party: Gregory N. Lee, Director of Finance and Administration, Anticipated Completion Date: 11/30/2022; Subsequent to the funding of awards, management initiated a search of the SAM database of exclusions and found that no awardees were on that list. This was completed October 7, 2022. F...

Responsible Party: Gregory N. Lee, Director of Finance and Administration, Anticipated Completion Date: 11/30/2022; Subsequent to the funding of awards, management initiated a search of the SAM database of exclusions and found that no awardees were on that list. This was completed October 7, 2022. Future contracts for the award of federal funds will include a clause requiring a recipient to attest that they are not suspended or debarred from participating in transactions covered under the Federal Acquisition Regulation. Contracts will also indicate that the recipient consents to verification of all provided information. Management will also be undertaking a search of the SAM database of exclusions prior to the award of any funds. This step will be incorporated into the policies and procedures around the award approval process and staff will be provided with training to perform such a search.

View Audit 17758

Finding 12850 (2022-002)

Material Weakness 2022

Moniteau School District

PA

Questioned Costs Procurement, Suspension & Debarment

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 specifically, Section 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidan...

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 specifically, Section 2 CFR 200.318(i) and 2 CFR 200.320(a)(2)(i) of the Uniform Guidance, and 24 PS 8.807.1. The timeframe for completion of this process will commence and be finalized during the District?s 2023-2024 fiscal year and will be revised on an ongoing basis as required by new policy directives from oversight agencies. In addition, management will respond with additional measures considered necessary by the Pennsylvania Department of Education upon review of this finding and management?s corrective action plan.

View Audit 17757 Questioned Costs: $1

Finding 12848 (2022-001)

Material Weakness 2022

Moniteau School District

PA

Questioned Costs Procurement, Suspension & Debarment

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 specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for comp...

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 specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for completion of this process will commence and be finalized during the District?s 2023-2024 fiscal year and will be revised on an ongoing basis as required by new policy directives from oversight agencies. In addition, management will respond with additional measures considered necessary by the Pennsylvania Department of Education upon review of this finding and management?s corrective action plan.

View Audit 17757 Questioned Costs: $1

Finding 12810 (2022-002)

Significant Deficiency 2022

Milwaukee Area Technical College

WI

Student Financial Aid Questioned Costs Reporting

Finding No. 2022-002 ? Report Filed After Due Date Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: By October 1 the institution should submit its...

Finding No. 2022-002 ? Report Filed After Due Date Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: By October 1 the institution should submit its ED Form 646-1, Fiscal Operations Report, and Application to Participate (FISAP) that includes the Fiscal Operations Report for the preceding award year and the Application to Participate for the upcoming award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition / Context: The FISAP for award year 2021-2022 was filed on October 12, 2022. Our sample was statistically valid. Cause: As MATC approached the deadline for FISAP submission, responsible MATC personnel were not aware of the outstanding reporting items and the immediate need to employ an alternative plan to ensure the timely submission of the FISAP. Questioned Costs: Unknown Effect: This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Delays in filing of this report could result in delays with subsequent year funding. Recommendation: MATC should implement a reporting calendar, including deadlines for draft, review and approval of the FISAP to ensure timely filing. District Response: MATC agrees with the finding and has developed, documented and implemented a process and calendar to ensure timely completion of the annual FISAP. Al Pinckney, Executive Director of Financial Aid 12/6/2022

View Audit 17732

Finding 12809 (2022-003)

Significant Deficiency 2022

Milwaukee Area Technical College

WI

Questioned Costs Student Financial Aid Period of Performance

Finding No. 2022-003 ? R2T4 Return Calculation Errors Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: For returns of Title IV Funding when a stud...

Finding No. 2022-003 ? R2T4 Return Calculation Errors Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: For returns of Title IV Funding when a student does not complete the enrollment period for which funds were disbursed, the amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student's withdrawal date. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew (34 CFR 668.22(e)). Condition / Context: The auditor selected 21 unenrolled students who had Title IV returns for testing. For each student selected, the return amount was incorrectly calculated because the payment period was not used as the basis for the determination. Our sample was statistically valid. Cause: Unauthorized break periods and start dates were used to determine the base period for calculation. MATC's review process was not effective to detect and correct this error. Staff responsible for calculating R2T4 returns were not properly trained in the requirements. Questioned Costs: $5,097 Effect: MATC has determined that a total of 425 returns were incorrectly calculated, with an estimated net error of $5,097. Recommendation: We recommend MATC re-evaluate its review process for Title IV returns, and provide additional training for management and staff to ensure the calculations and compliance requirements are understood and that control processes are operating effectively to ensure proper returns. District Response: MATC agrees with the finding and has developed, documented and implemented a process and correct the student record errors, provide updated training and update R2T4 procedures to ensure proper calculation going forward. Al Pinckney, Executive Director of Financial Aid 12/6/2022

View Audit 17732 Questioned Costs: $1

Finding 12771 (2022-004)

Significant Deficiency 2022

Charles County Public Schools

MD

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.303 § 200.308 § 200.309 § 200.403

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period o...

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Fiscal Services will improve internal controls over the procedures that ensure expenditures to a program are incurred within an award?s allowable period of performance. During the year-end close out process, the Lead Restricted Funds Accountant will review the close out of all restricted funds against the grant periods. If expenditures are inadvertently incurred outside of the grant period, the expenditures will be reclassified to an existing like grant if allowable or to the operating budget. If the Lead Restricted Funds Accountant is unavailable or has closed out grants themselves, this review will be done by the Budget Manager. The school district will implement a new financial system in July 2023. The implementation of this new system will allow for more automated internal controls. Name(s) of the contact person(s) responsible for corrective action: Rosa Aquino and/or Sherri Fisher-Davis Planned completion date for corrective action plan: December 31, 2022

View Audit 17731

Finding 12728 (2022-002)

Significant Deficiency 2022

Hot Springs County

WY

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.303

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding...

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding, the County is in the process of developing written policies and procedures relative to internal controls over federal awards, to help achieve: - County wide consistency over compliance regulations and standards - Decrease the risk of grant agreement noncompliance - Reduce the risk of undetected errors in processing of financial transactions relative to federal awards. Steps taken include: - Familiarization of requirements in 2 CFR 200.303 - Obtain draft examples of policies and procedures adopted by other Counties - Discussion with governance and county attorney regarding development and adoption of policies and procedures In addition, the County is continuing to suggest departments implement effective internal control structures to - Protect assets against theft and waste - Ensure accurate and reliable operating and accounting data The conditions noted in this finding were previously reported in finding 2021-002 Completion Date Estimated June 2023 - policy written, approved by Commissioners, and disseminated ot departments Training - ongoing County Contact Becky Kersten, County Clerk

View Audit 17708

Finding 12725 (2022-001)

None 2022

Rodeo Senior Apartments, Inc.

CA

HUD Housing Programs Questioned Costs Reporting

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 Management Agent will refund all amounts owed to property per Audit finding. Going forward only HUD approved fees will be charged to property. 12/31/2022 Bipin Patel ? Accounting Manager

View Audit 17646 Questioned Costs: $1

Finding 12722 (2022-001)

Material Weakness 2022

Legacy Health

OR

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

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund porta...

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund portal. Additionally, Legacy claimed expenses that were duplicated within the reporting portal. The general distribution report for Legacy Health for Period 1 shows $35,760,843 in expenses applied against the PRF funds in the PRF portal report for Legacy as a consolidated entity. Separately, the stand-alone reports for targeted funds received by Emanuel Hospital & Health Center for Period 1, Legacy Silverton Medical Center for Period 1, Legacy Clinics, LLC for Period 1, and Legacy Meridian Park Hospital for Period 2 also include expenses totaling $12,291,293 that are included in the $35,760,843 listed in the consolidated report above. This results in duplicate reporting of the same expenditures. During testing over reporting and allowability it was observed that the lost revenues attributable to Coronavirus were reported in both the parent entity?s PRF reports on the general distribution payments and the subsidiary entities? PRF reports on the targeted distribution payments (i.e., lost revenues were duplicated). Lost revenues shown on the subsidiary reports as available to be applied against PRF that related to lost revenues also reported in the parent entity?s report were related to Emanuel Hospital & Health Center for Period 1 in the amount of $27,106,110 and Legacy Silverton Medical Center for Period 1 in the amount of $10,269,349. Actions Taken and Status As noted within the portal filing summary, for reporting period 1, Legacy consolidated COVID-19 expenses ($35,760,843) plus lost revenue ($150,037,450) totaled $185,798,293. Payments from the PRF totaled $89,818,954. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF funds received, regardless of the questioned costs above. Therefore, management believes no repayment of PRF funds received would be required. Further, management considered the finding. Reporting for the Legacy parent reporting entity was based on the ?Post-Payment Notice of Reporting Requirements (6/11/21)?, which includes the following requirement: ?Reporting entities will submit consolidated reports.? Neither the methodology utilized by Legacy or application of the methodology advocated by KPMG result in repayment of any of the funds received from the PRF. Management is implementing a process to identify and resolve situations in which reporting requirements are inconclusive, in conflict, or ambiguous. Outside subject matter expertise will be accessed as needed. Person responsible for the implementation of the corrective action plan: Tom Haywood Legacy Health 1919 NW Lovejoy St Portland OR 97219 503-415-5793 thaywood@lhs.org

View Audit 17558 Questioned Costs: $1

Finding 12720 (2022-006)

Significant Deficiency 2022

The Inner Voice, Inc.

IL

Significant Deficiency Internal Control / Segregation of Duties Questioned Costs

Department of Veterans Affairs 2022-006 VA Homeless Providers Grant and Per Diem Program ? Assistance Listing No. 64.024 Recommendation: We recommend the Inner Voice review its policies and procedures at the conclusion of an award period and obtain authorization from the federal awarding agency for...

Department of Veterans Affairs 2022-006 VA Homeless Providers Grant and Per Diem Program ? Assistance Listing No. 64.024 Recommendation: We recommend the Inner Voice review its policies and procedures at the conclusion of an award period and obtain authorization from the federal awarding agency for costs incurred after the award period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Inner voice has approached VA Authority on this issue and they have no issue as this cost is immaterial. However, moving forward Inner voice will not allocate cost to the program and grant unless work is completed or approved by the funder in instances where the work cannot be completed during the program year. Name of the contact person responsible for corrective action: CFO Planned completion date for corrective action plan: Effective immediately.

View Audit 17548

Finding 12719 (2022-005)

Significant Deficiency 2022

The Inner Voice, Inc.

IL

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

2022-005 VA Homeless Providers Grant and Per Diem Program ? Assistance Listing No. 64.024 Recommendation: The Inner Voice should implement a procurement policy and procedure that includes the selection and documentation of procurement rationale, controls and oversight. This policy should be follow...

2022-005 VA Homeless Providers Grant and Per Diem Program ? Assistance Listing No. 64.024 Recommendation: The Inner Voice should implement a procurement policy and procedure that includes the selection and documentation of procurement rationale, controls and oversight. This policy should be followed for all procurement transactions and include compliance requirements UG ?200.318 general procurement standards, UG ?200.319 competition, and ?200.320 methods of procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement policy is drafted and under discussion before bring this to the Board for a formal approval and its implementation. Name of the contact person responsible for corrective action: CFO Planned completion date for corrective action plan: After the approval of the Board that is planned to be held during the month of March.

View Audit 17548

Corrective Action Plans

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