Corrective Action Plans

Finding 386090 (2023-002)

Significant Deficiency 2023

DE

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

Internal control procedures will be strengthened between Financial Aid, the Registrar’s Office, and the Bursar’s Office.

View Audit 298459 Questioned Costs: $1

Finding 386081 (2023-002)

Significant Deficiency 2023

Municipality of Guayama

PR

Reporting

Finding 2023-002: Reporting Head Start: Reports submitted after its due date Reportable Condition: See condition 2023-002 Recommendation: Due diligence of the supervisory personnel to ensure that reports are submitted within its due date. Action Taken: The Municipality will take the necessary steps ...

Finding 2023-002: Reporting Head Start: Reports submitted after its due date Reportable Condition: See condition 2023-002 Recommendation: Due diligence of the supervisory personnel to ensure that reports are submitted within its due date. Action Taken: The Municipality will take the necessary steps to ensure compliance with the financial reporting datelines by establishing additional procedures as part of the internal control procedures for compliance with reporting due dates.

View Audit 298442

Finding 386080 (2023-001)

None 2023

Town of Wakefield

MA

Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The Town of Wakefield, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: ...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The Town of Wakefield, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number 21.027 2023-001: Reporting to the Federal Government Compliance Requirement: Reporting Type of Finding: Compliance and Internal Control over Compliance – Other Matter Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the U.S. Treasury that includes reporting the total grant expenditures incurred for the reporting period. Since the Town is a Non-Entitlement Unit that was allocated less than $10.0 million in funding, the Town is required to submit, to the U.S. Department of Treasury, a project and expenditure report by April 30, 2022, and annually thereafter. Condition: The Town submitted the annual project and expenditure report timely, however the expenditures reported as of June 30, 2023, did not reconcile with the Town’s accounting ledger. Questioned Costs: None Reported. Context: The Town filed the required project and expenditure report in a timely manner; however the current period expenditures and cumulative expenditures were overstated by $7,215,950 and $6,453,661, respectively. The discrepancies were due to a misunderstanding about how expenditures should be recognized on the project and expenditure report. Effect: The expenditures reported on the Town’s project and expenditure report did not match the accounting ledger. Cause: The Town reported the total allotment of Coronavirus State and Local Fiscal Recovery Funds as expended and obligated on the project and expenditure report, instead of the expenditures incurred and obligated as of March 31, 2023. Recommendation: Management should implement procedures to ensure that current period and cumulative expenditures reported on the project all expenditure report are recorded in the corresponding period that they are reported on the Town’s general ledger. The Town should amend the previous submission so that the correct expenditures are reported. Views of Responsible Officials and Planned Corrective Actions: Management made a good faith effort to submit its reporting to the U.S. Treasury on a timely basis. This was a misunderstanding regarding how the expenditures should be recognized on the project and expenditure report. Management plans to amend the previous submission and to implement procedures to properly report expenditures going forward.

View Audit 298435

Finding 386063 (2023-001)

Significant Deficiency 2023

Rice Lake Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 298424

Finding 386053 (2023-001)

Significant Deficiency 2023

Ripon College

WI

Special Tests & Provisions Student Financial Aid Reporting

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the Natio...

Finding 2023-001 Sept. 26, 2023 Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that Department of Education (DOE) considers high risk. Statement of Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Corrective Action Plan: • The College agrees and concurs with the audit finding. • The Registrar’s Office has reviewed and remediated all files that were not accurately reported data elements in NSLDS as of September 2023. • The Registrar’s Office will work with the Financial Aid Office to review and regularly monitor student campus and program level enrollment status, especially in the cases of those that have dropped below full time, and are no longer enrolled for various reasons. • The Registrar’s Office will monitor the NSC error report which states discrepancies between NSC and NSLDS. • The Registrar’s Office will work with NSC to remediate processing issues between NSC and NSLDS reports in order to ensure that NSLDS is receiving accurate information. Names of Contact Persons Responsible for Corrective Action Plan: Michele Wittler (Associate Dean of Faculty and Registrar), wittlerm@ripon.edu, 920-748-8119 Katy Crane (Assistant Registrar), cranek@ripon.edu, 920-748-8119 Linda Kinziger (Director of Financial Aid), kinzigerl@ripon.edu, 920-748-8358 Anticipated Completion Date: This plan has been implemented with corrections already made as of September 2023 by the Registrar’s Office. It will be finalized with the fiscal year June 30, 2024 year-end review of Enrollment Reporting.

View Audit 298423

Finding 386039 (2023-003)

Material Weakness 2023

Paoli Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required ...

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Greg Walker, Superintendent Contact Phone Number and Email Address: 812-723-4717 and walkerg@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent will enter information into the annual data report required for ESSER and once completed the Corporation Treasurer will review the information entered for accuracy. The Corporation Treasurer will sign off that the information entered is correct and then the Superintendent will submit the data report. Anticipated Completion Date: Projected date of completion is April 2024.

View Audit 298416

Finding 385654 (2023-001)

Significant Deficiency 2023

Idaho State University

ID

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 ...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: ISU should implement formal review procedures to document review and approvals over required reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU had a formal review procedure in place, but due to personnel changes it was not being followed. Staff has been trained and procedures will be followed. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented FY24

View Audit 298414

Finding 385615 (2023-001)

Material Weakness 2023

South Spencer County School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent...

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385594 (2023-003)

Significant Deficiency 2023

Hyacinth Aids Foundation, INC

NJ

Reporting Significant Deficiency

Material Weakness: Significant deficiency in internal control over compliance. Corrective Action Plan: Due to difficulty in hiring and engaging a fulltime Chief Financial Officer, Management has made the decision to outsource our finance department and has engaged the services of Withum, a premier a...

Material Weakness: Significant deficiency in internal control over compliance. Corrective Action Plan: Due to difficulty in hiring and engaging a fulltime Chief Financial Officer, Management has made the decision to outsource our finance department and has engaged the services of Withum, a premier accounting services firm. Management has implemented new accounting software with more robust cost allocation tools and internal controls. Management has also implemented cost allocation methodologies and grant management rules into the workflow and new process definitions associated with implementing new software. Grant reporting rules and cost allocations will be built into the accounting software. A quarterly review of grant expenditures and cash flow management will be conducted by the Board of Trustees Finance committee quarterly. Anticipated Completion Date: The engagement with Withum was entered into in May 2023. The financial systems update went live on February 1, 2024. Quarterly review of grant expenditures and cash flow management will be ongoing April – June 2024.

View Audit 298321

Finding 385592 (2023-009)

Significant Deficiency 2023

Clarkson College

NE

Reporting Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

2023-009 Higher Education Emergency Relief Funding (HEERF) – Assistance Listing No. 84.425 Recommendation: We recommend the College establish a review process to ensure accurate submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken ...

2023-009 Higher Education Emergency Relief Funding (HEERF) – Assistance Listing No. 84.425 Recommendation: We recommend the College establish a review process to ensure accurate submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will ensure that review procedures are in place to ensure accurate submission. Name(s) of the contact person(s) responsible for corrective action: Robyn Hansen Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385533 (2023-006)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Reporting Significant Deficiency

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement wit...

2023-006 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review procedures and starting immediately, all disbursements reported to COD will be reported within the appropriate timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385528 (2023-001)

Significant Deficiency 2023

Clarkson College

NE

Student Financial Aid Internal Control / Segregation of Duties Reporting

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in tit...

2023-001 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar Office reports enrollment statuses to the National Student Clearinghouse (Clearinghouse) and then the Clearinghouse reports enrollment statuses to NSLDS. Clarkson College Financial Aid will resume a procedure put in place in July 2022, according to the 2022 Corrective Action Plan, prior to the new Financial Aid staff that started in June 2023. The procedure is for one Financial Aid staff person to work with the Registrar each time enrollment is reported and that all errors are cleared in the allowed timeframe. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: April 2024

View Audit 298311

Finding 385519 (2023-010)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventin...

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

View Audit 298302

Finding 385517 (2023-009)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.208 § 200.302 § 200.303 § 200.305 § 200.328

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in prev...

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385476 (2023-001)

Significant Deficiency 2023

Hatfield-McCoy Regional Recreation Authority

WV

Reporting

Federal Program: Economic Development Cluster: Economic Adjustment Assistance Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Pass-through Agency: N/A Award Number: N/A Award Year: 2023 Compliance Requirement: Reporting Questioned Costs: None Condition The Authority ...

Federal Program: Economic Development Cluster: Economic Adjustment Assistance Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Pass-through Agency: N/A Award Number: N/A Award Year: 2023 Compliance Requirement: Reporting Questioned Costs: None Condition The Authority did not submit the Form SF-425, Federal Financial Report, for the period of September 30, 2022. Corrective Action Plan Corrective Action Planned: Management has implemented controls to monitor on-going compliance with grant agreements. Additionally, when management became aware of the non-compliance, a Form SF-425 , Federal Financial Report, was submitted for the period of September 30, 2022. The submission was approved by U.S. Department of Commerce on February 6, 2023. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeffery Lusk, Executive Officer Anticipated Completion Date: February 6, 2023

View Audit 298291

Finding 385466 (2023-003)

Material Weakness 2023

Weston School District

WI

Material Weakness Reporting Internal Control / Segregation of Duties

Finding #2023-003 – Material Adjustments (Prior year finding #2022-004) Condition: Johnson Block and Company, Inc., proposed numerous adjusting journal entries. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in its...

Finding #2023-003 – Material Adjustments (Prior year finding #2022-004) Condition: Johnson Block and Company, Inc., proposed numerous adjusting journal entries. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in its accounting system prior to the audit, a material weakness exists in the District’s internal controls. Effect: This means that the proper recording and reporting of financial information may not occur within a timely manner. Cause: Financial information was not recorded in a timely manner and material adjustments were required in order to correct various transactions. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditors. In addition, new finance accounting staff are receiving training to assist with correcting this finding. Contact Person: Gary Syftestad Anticipated Completion: Ongoing

View Audit 298276

Finding 385430 (2023-002)

Material Weakness 2023

Metropolitan School District of Southwest Allen County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director...

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Once􀀃the􀀃Deputy􀀃Treasurer􀀃completes􀀃the􀀃report,􀀃they􀀃will􀀃give􀀃the􀀃report􀀃and􀀃all􀀃 supporting􀀃documentation􀀃to􀀃the􀀃Asst.􀀃Director􀀃of􀀃Business􀀃for􀀃review.􀀃􀀃After􀀃thorough􀀃 review,􀀃the􀀃report􀀃and􀀃supporting􀀃documentation􀀃will􀀃be􀀃signed􀀃by􀀃both􀀃the􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃and􀀃the􀀃Deputy􀀃Treasurer.􀀃􀀃Once􀀃reviewed,􀀃the􀀃report􀀃and􀀃supporting􀀃 documentation􀀃will􀀃be􀀃given􀀃to􀀃the􀀃Director􀀃of􀀃Business􀀃for􀀃final􀀃approval􀀃and􀀃signature.􀀃􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

View Audit 298274

Finding 385418 (2023-002)

Material Weakness 2023

University of Puerto Rico

PR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Finding Number 2023-002 – Various ALN – Reporting Management’s Response The UPR concurs with this finding. The UPR Finance Office at Central Administration will send reminders to the employees in charge of preparing or sending the reports to the corresponding federal agencies or pass through entit...

Finding Number 2023-002 – Various ALN – Reporting Management’s Response The UPR concurs with this finding. The UPR Finance Office at Central Administration will send reminders to the employees in charge of preparing or sending the reports to the corresponding federal agencies or pass through entities. • For CSLFRF program reports, the Finance Office at Central Administration will send a biweekly reminder to the employee in charge of submitting the reports. • HEERF program reports are sent by the responsible person at each one of the eleven (11) campuses. For these reports, the Finance Office will send an e-mail to the employees responsible for submitting quarterly reports and annual reports, reminding them of their due dates. For the quarterly reports, this e-mail will be sent in the first week of the months of April, July, and October 2024. Additionally, for the 2024 annual report, a reminder will be sent on the first week of March 2025. • For Family Planning program reports, the Finance Office will issue a reminder for quarterly reports in the first week of the months of April, July, October, and January. For the progress reports, a reminder will be sent in the first week of February and for the annual report, a reminder will be sent in the month of April. • The Central Finance Office will issue a circular letter to the finance directors of the 11 units requesting them to instruct all their staff responsible for issuing federal program reports to schedule a reminder in their Outlook calendar 10 days before the issuance of each report. Responsible Person or Office: Finance Office at Central Administration / Finance Office at the eleven campuses Timeline: 2024-2025

View Audit 298262

Finding 385411 (2023-004)

Material Weakness 2023

University of Puerto Rico

PR

Student Financial Aid Eligibility Reporting

Finding Number 2023-004 – Student Financial Assistance (SFA) Cluster – Various ALN Numbers – Enrollment Reporting Management’s Response The UPR concurs with this finding. In the previous three years, cases have been reported in which the change in the student's status was never reported, the change...

Finding Number 2023-004 – Student Financial Assistance (SFA) Cluster – Various ALN Numbers – Enrollment Reporting Management’s Response The UPR concurs with this finding. In the previous three years, cases have been reported in which the change in the student's status was never reported, the change in status was incorrectly reported, or the change in status was reported after 60 days. For FY2023, the auditors only pointed out that the UPR reported the change in the student's status over 60 days. This is evidence that the measures implemented before are achieving their objective. The UPR has implemented provisions to prevent the change in status from ever being reported or the incorrect status from being reported. However, we still must comply 100% to ensure that changes in student status are reported on time. For this, the UPR will issue written instructions and will have meetings with the Deans of Academic Affairs of the eleven (11) campuses to ensure they guide their staff to understand the importance of complying with the academic calendars and the implications of not doing so; including: (a) the importance of submitting grades on time (b) the importance of Bachelor or Master’s degrees being conferred on time. For the four cases of UPR-Bayamon campus, the registrar has evidence that they were reported to the National Student Clearinghouse (NSC) on June 30, 2023. UPR-Bayamon campus will contact the NSC to determine why these cases were reported on August 30, 2023, and will implement the necessary actions to prevent this from happening again. Responsible Person/Office: Executive Vice President for Academic Affairs and Research. Timeline: June 2024, so we will notice their effect during fiscal year 2024-2025.

View Audit 298262

Finding 385401 (2023-022)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.403 § 200.77

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budg...

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

View Audit 298253 Questioned Costs: $1

Finding 385399 (2023-023)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.303

The Department will continue refining the capabilities of the Contract Tracking System (CTS) Database, utilized for regulatory reporting, to contain all of the necessary reporting data elements required for timely and accurate FFATA reporting. This includes configuring the database to allow for fund...

The Department will continue refining the capabilities of the Contract Tracking System (CTS) Database, utilized for regulatory reporting, to contain all of the necessary reporting data elements required for timely and accurate FFATA reporting. This includes configuring the database to allow for fund source splits to ensure contract awards are not duplicated and capturing the FSRS reporting date. Additional internal controls will be implemented, including a reconciliation of the CTS Database every quarter by the Grants Manager. The long-term goal is to migrate this legacy system to a new platform that incorporates validation to eliminate or reduce errors. DBHDD will update the internal controls related to Transparency Act Reporting and SF-425 Federal Financial Reports (FFR) for Mental Health Services Block Grant (MHBG) and Substance Abuse Prevention and Treatment Block Grant (SABG) no later than March 31, 2024. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than April 30, 2024.

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Finding 385398 (2023-021)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.403 § 200.77

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budg...

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

View Audit 298253 Questioned Costs: $1

Finding 385364 (2023-030)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Reporting Special Tests & Provisions Subrecipient Monitoring § 200.303

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification...

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. The crossmatch process is conducted using software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. GDOL developed an aggressive plan to complete all crossmatches. We are running cross matches on all the state and federal programs. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing non-overpayment staff to assist with overpayment investigations. Additionally, we are utilizing temporary agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. We are slated to run our last accelerated crossmatch in March 2024 and will resume our regular crossmatch schedule in June 2024. Additionally, GDOL has procured a vendor to build and implement a modernized unemployment insurance (UI) system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Summary: The current unemployment system is obsolete and cannot be remediated at this time Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

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Finding 385355 (2023-026)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.302 § 200.303

GDOL concurs with this finding: Regarding the pandemic Grants noted that were all under #UI34710-20-55-A-13: • The unemployment insurance (UI) Regular Grant typically provides the amount of available grant funds in advance based on 1.) and estimated number of claims to be processed in the current ...

GDOL concurs with this finding: Regarding the pandemic Grants noted that were all under #UI34710-20-55-A-13: • The unemployment insurance (UI) Regular Grant typically provides the amount of available grant funds in advance based on 1.) and estimated number of claims to be processed in the current year (based on the average of two years prior activity) and 2.) the average processing times (based on the average of two years prior processing times). • In contrast, many of the pandemic grants are based on actual claims activity with monies being awarded “after the fact” with no consideration given to the aforementioned criteria as no prior- year basis exists. • GDOL experienced delays in some pandemic allocations due to delays in programing and the submission of the new reports for pandemic activities (Federal Pandemic Unemployment Compensation (FPUC), Pandemic Emergency Unemployment Compensation (PEUC) and Pandemic Unemployment Assistance (PUA)). All late reports have been submitted and we are reconciling grants as deemed appropriate. • With reimbursement based on pandemic claims activity, there was no clear mechanism for GDOL to be able to “forecast” the amount of time and effort needed to process the cyclical and unpredictable number of pandemic claims. As such, best efforts were made to estimate in this regard. • The 3073 FPUC grant is the only grant for which we have been reimbursed at 100%. However, due to the most recent implementation of stop/gain loss, we are no longer being reimbursed at the full amount. • Regarding the Employment Service/ Wagner-Peyser Funded Grants noted, the program period of performance was July 1, 2022 thru September 30, 2025. GDOL received instructions from USDOL on January 19, 2023 requesting a final ETA-9130 report be submitted by February 15th for grants that were being transferred to TCSG and offered technical assistance in completing the reports. The National office was designated to de-obligate the funds remaining and issue new grant numbers to obligate these funds at TCSG; however, several things occurred that caused the process to be delayed: o The required action was to check box 6 as yes (for the final 9130 reports) and 10g (Federal Share of Unliquidated Obligation) had to be zero although there were Unliquidated Obligations in the system. o Although the Wagner Peyer program was transferred to TCSG in January 2023, eligible costs continued. o The need for expenditure reconciliations was discussed with USDOL Regional Office and anticipated funds were drawn in lieu of billing TCSG. o Associated eligible costs were reconciled to the Wagner Peyser Ledger via manual journal entries in lieu of billing TCSG. o In addition, USDOL implemented a new GrantSolutions to replace its legacy grant processing system, E-Grants. USDOL replaced its legacy E-Grants Grantee Reporting System (GRS) by transitioning to PMS for grant recipients submission of the quarterly ETA-9130 financial reports on February 6,2023. o Although training was taken for this process, the overall reconciliation process was delayed, all reconciling items were resolved by the 9/30/23 reporting period.

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Finding 385353 (2023-024)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328

The following corrective actions are being taken by Criminal Justice Coordinating Council (CJCC), effective for all federal reporting for the performance and financial period ending March 31, 2024: Federal Financial Report (FFR) Processes are updated as follows: • Federal Financial Report respons...

The following corrective actions are being taken by Criminal Justice Coordinating Council (CJCC), effective for all federal reporting for the performance and financial period ending March 31, 2024: Federal Financial Report (FFR) Processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the CJCC Budget Team. • Because the US DOJ Just Grants system does not allow for review or secondary viewers in the financial reporting items the FFRs are to be printed digitally by the completing analysts/director. • FFR’s will be reviewed with written certification of review by a budget team member that was not responsible for primary submission of the report for each grant. • Any corrections will be made within the period of correction for the report to prevent a misstated report from becoming a permanent record. Prepared Federal Funding Accountability and Transparency Act (FFATA) and Performance Measures Tool (PMT) reports processes are updated as follows: • All PMTs and FFATA data will be routed for review through the Victims Assistance Division – Director of Operations for certification of completeness and accuracy.

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Corrective Action Plans

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