Corrective Action Plans

Finding 387083 (2023-001)

Material Weakness 2023

Housing Authority of the City of Everett

WA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We starte...

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We started the process on 6/29/2022 to replace our Housing Inspector that left EHA 5/04/2022. The person that filled this Housing Inspector position started at EHA on 1/05/2023, completed training and began taking on an inspection workload in February 2023. • In March 2023, twenty-five (25) staff in EHA’s Housing Management Department attended an HQS inspections training. EHA Housing Management staff began completing initial and annual HQS inspections at EHA PBV properties on 7/01/2023. • EHA budgeted for a second Housing Inspector position in EHA’s FYE2023 budget. We started the process to hire the second Housing Inspector on 7/13/2023. The person that filled this second Housing Inspector position started at EHA on 9/19/2023, completed training and began taking on an inspection workload at the end of October 2023. • EHA budgeted for an Inspections Coordinator position in EHA’s FYE2023 budget. We started the process to hire the Inspections Coordinator on 8/14/2023. The person that filled the Inspections Coordinator position started on 11/06/2023. • On 10/30/2023, EHA’s Executive Director decided to add a third Housing Inspector to the EHA inspections team to assist with the backlog of biennial inspections. We started the process to hire the third Housing Inspector on 10/31/2023. The person that filled this third Housing Inspector position started in the position on 1/16/2024, completed training and began taking on an inspection workload in February 2024. • On 2/23/2024, an HCV Manager was appointed to supervise the inspections team (three Housing Inspectors and one Inspections Coordinator), to provide increased oversight over EHA’s inspections workload. The HCV Manager is responsible for monitoring progress towards addressing the biennial inspections backlog, delegating inspections workload to the inspections team, and providing guidance and support to the inspections team. The HCV Manager meets with the inspections team on a weekly basis as well as conducts individual check-ins with all inspections team members. Our increased inspections capacity has allowed us to make significant progress on addressing the pandemic-caused backlog of biennial inspections. Based on our expanded internal staffing resources, we expect to complete all late biennial inspections by 12/31/2024.

View Audit 299403

Finding 387074 (2023-002)

Significant Deficiency 2023

Cit of Richmond

CA

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

The City will address the misalignment by reporting the revised and accurate information in the upcoming quarterly report.

View Audit 299391

Finding 387041 (2023-004)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal cont...

2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.

View Audit 299385

Finding 387003 (2023-004)

Significant Deficiency 2023

Lindenwood University

MO

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.

View Audit 299379

Finding 387001 (2023-003)

Significant Deficiency 2023

Lindenwood University

MO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 202...

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. During the go-live in Spring 2023, the University experienced critical system reporting issues which were addressed a quickly as possible. The new system has several built in features that are supplemented with internal controls to ensure enrollment reporting requirements are completed in a timely fashion. In Spring 2024, Anthology provided the University with a audit tool to review data before uploading to promote efficiency and accuracy.

View Audit 299379

Finding 386997 (2023-001)

Significant Deficiency 2023

City of Lathrop

CA

Reporting Internal Control / Segregation of Duties

The City will update policies and procedures over reporting, including additional independent reviews to ensure accurate completion.

View Audit 299368

Finding 386971 (2023-001)

Significant Deficiency 2023

City of Westland, Michigan

MI

Subrecipient Monitoring HUD Housing Programs Reporting

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for...

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for the program year ended June 30, 2023, we have taken immediate and strategic steps to address and prevent future occurrences. These include streamlining our data collection and reporting processes for greater efficiency, enhancing staff training on reporting responsibilities, and implementing robust internal monitoring to ensure adherence to reporting deadlines. These measures, designed to address both the immediate issue and bolster our overall reporting framework, demonstrate our commitment to transparency, accountability, and continuous improvement in our program operations. Contact person responsible for corrective action: Joanne Campbell Anticipated Completion Date: October 10, 2023

View Audit 299310

Finding 386970 (2023-001)

Significant Deficiency 2023

Ottawa University

KS

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328 § 200.329

Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided ...

Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided on the University’s website. Completion Date: March 25, 2024 Contact Person: Donna Ferguson, Controller, and Carrie Stevens, Associate Vice President of Compliance

View Audit 299309

Finding 386969 (2023-002)

Material Weakness 2023

Fountain Hills Unified School District No. 98

AZ

Allowable Costs / Cost Principles Material Weakness Reporting

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on ...

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on grant compliance. The District has also designated a District employee with specific responsibility of overseeing the District grant program to ensure timely grant submissions.

View Audit 299307

Finding 386938 (2023-007)

Significant Deficiency 2023

Northern Illinois University

IL

Reporting Matching / Level of Effort / Earmarking § 200.303

Condition: Northern Illinois University (the University) did not timely report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) under the Professional and Cultural Exchange Program. Corrective Action Plan: University has taken the following c...

Condition: Northern Illinois University (the University) did not timely report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) under the Professional and Cultural Exchange Program. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University has taken proactive steps which include reviewing all active subrecipients and creating a new procedure that defines roles and responsibilities to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Individual(s) Responsible for Corrective Action: Sponsored Programs Staff Anticipated Completion Date: June 30, 2024

View Audit 299258

Finding 386914 (2023-002)

Significant Deficiency 2023

Southern Illinois University

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

2023-002. Finding: Student Enrollment Reporting– Both Campuses Response: The campuses have implemented processes to prevent further errors in enrollment reporting, despite the disconnects and system problems that have been observed. Corrective Action Plan: SIUC has implemented a process where in eac...

2023-002. Finding: Student Enrollment Reporting– Both Campuses Response: The campuses have implemented processes to prevent further errors in enrollment reporting, despite the disconnects and system problems that have been observed. Corrective Action Plan: SIUC has implemented a process where in each time an NSLDS roster is received (twice a month), it is run against a list of Title IV aid students to identify any that are not on the roster in order to remedy the omission as soon as possible. The current course of action at SIUE is to monitor students per term who are up for graduation but are not enrolled for the full semester. Students who are up for graduation will be enrolled in UNIV 500 for the remainder of the term after completing requirements earlier in the semester in which they are graduating. This would be in line with our Continuous Enrollment Policy 1L16. While this is currently a manual process, SIUE continues to look for ways to systematically indicate the student is withdrawn in later part of term in which they are graduating, or to withdraw the student from the later part of the term. Contact Person: Rachel Frazier (SIUC) and Patrick Sears (SIUE) Anticipated completion date: December 2023 (SIUC) and Spring 2024 (SIUE)

View Audit 299240

Finding 386909 (2023-009)

Significant Deficiency 2023

City of Wilmington

DE

HUD Housing Programs Reporting Subrecipient Monitoring

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together cons...

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together constitutes the Grantee’s annual performance report to HUD. Included in this submission is the Grantee Performance Report and all of the Provider Performance Reports together. Staff in the Real Estate and Housing Department review them to the best of our ability for accuracy and completeness. The finding notes that the documentary evidence of this review was not retained other than the subsequent data validation which occurs with HUD’s Technical Assistance (TA) HOPWA Data Validation team and through Cloudburst email. In the future the Real Estate and Housing Department will note to file the email confirmation of the received report is as complete and error free as possible.

View Audit 299217

Finding 386908 (2023-001)

Significant Deficiency 2023

School District of Philadelphia

PA

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action Plan Finding number 2023-001 Reporting Head Start FFATA Compliance - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Diane Castelbuono Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-...

Corrective Action Plan Finding number 2023-001 Reporting Head Start FFATA Compliance - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Diane Castelbuono Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-400-6242 View of Responsible Officials and Planned Corrective Action The School District of Philadelphia concurs with the finding and recommendations. The District has implemented a systematic process for reporting Fiscal Year 2024 subawards under the Federal Head Start Program which is required to report under FFATA. Moving forward, the process is established to ensure reporting will be maintained.

View Audit 299211

Finding 386907 (2023-002)

Significant Deficiency 2023

School District of Philadelphia

PA

Reporting Special Tests & Provisions Significant Deficiency § 200.19

Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of ...

Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092 Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from the school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024.

View Audit 299211

Finding 386896 (2023-003)

Material Weakness 2023

Pittsfield Housing Authority

RI

Eligibility HUD Housing Programs Material Weakness

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained re...

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained regarding eligibility determinations and rent calculations, checklists are being developed and regular internal QCs performed, with an objective of full compliance by the end of calendar year 2024.

View Audit 299209

Finding 386885 (2023-001)

Material Weakness 2023

Belmond-Klemme Community School District

IA

Internal Control / Segregation of Duties Reporting

WE WILL REVIEW PROCEDURES AND PLAN TO MAKE CHANGES TO IMPROVE INTERNAL CONTROL WHERE POSSIBLE.

View Audit 299203

Finding 386880 (2023-001)

None 2023

Town of Wilmington, Massachusetts

MA

Subrecipient Monitoring Reporting § 200.1

Condition: Obligations were overstated by $5,676,345 on the March 31, 2023 Project and Expenditure report Corrective Action Planned: The Town is aware of the reporting error. The Town will make any necessary corrections and if needed make corrections in the subsequent year. Anticipated Completion ...

Condition: Obligations were overstated by $5,676,345 on the March 31, 2023 Project and Expenditure report Corrective Action Planned: The Town is aware of the reporting error. The Town will make any necessary corrections and if needed make corrections in the subsequent year. Anticipated Completion Date: April 30, 2024 Contact: Michael Morris, Interim Finance Director

View Audit 299189

Finding 386872 (2023-010)

Material Weakness 2023

Griffith Public Schools

IN

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

FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 ...

FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Reporting Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Anticipated Completion Date: June 30, 2025

View Audit 299183

Finding 386863 (2023-006)

Material Weakness 2023

Griffith Public Schools

IN

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2023-006 Subject: Title I Grants to Local Educational Agencies – Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A1900...

FINDING 2023-006 Subject: Title I Grants to Local Educational Agencies – Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility, Reporting, Special Tests and Provisions - Assessment System Security Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Anticipated Completion Date: June 30, 2025

View Audit 299183

Finding 386844 (2023-001)

Significant Deficiency 2023

Woodside Village, Inc. 042-Hd112

OH

HUD Housing Programs Cash Management Reporting

Response Management has completed the required deposit to the prohibited amenities escrow of $3,971 in September 2023.

View Audit 299175

Finding 386842 (2023-001)

Significant Deficiency 2023

Accessible Country Trail, Inc. 042-Hd033

OH