Corrective Action Plans

Finding 3048 (2023-003)

Material Weakness 2023

ID

Reporting § 200.510

Response to Finding 2023-003 - Schedule of Expenditures of Federal Awards (SEFA) Preparation The district will strive for monthly requests for reimbursement for all applicable federal funds, thus creating awareness of the funds and potential issues before they arise. The District Director of Finance...

Response to Finding 2023-003 - Schedule of Expenditures of Federal Awards (SEFA) Preparation The district will strive for monthly requests for reimbursement for all applicable federal funds, thus creating awareness of the funds and potential issues before they arise. The District Director of Finance will be responsible for overseeing the implementation of these responses and anticipates corrective dates to be immediate. Person(s) responsible for action: Lanell Farmer/Director of Finance

View Audit 5012

Finding 3027 (2023-001)

None 2023

New Hampshire Catholic Charities

NH

Reporting

Accuracy of Reporting: Criteria: Management was responsible for reporting COVID-related expenditures based on the terms of the grant agreement. Condition: During compliance testing, it was identified that certain expenditures included in the final report were not accurate based on the amounts re...

Accuracy of Reporting: Criteria: Management was responsible for reporting COVID-related expenditures based on the terms of the grant agreement. Condition: During compliance testing, it was identified that certain expenditures included in the final report were not accurate based on the amounts recorded within the Organization's general ledger. Context: The COVID-related expenditures reported for the period were not accurate. Cause: Certain COVID-related expenditures had inaccuracies in the expenditures reported for Period 3 and Period 4. Effect: As a result of the condition, the Organization's required reporting for this grant was misstated, however the Organization was able to recalculate the appropriate COVID-related expenditures and, in conclusion, report that there were enough expenditures to charge to this federal award to support the propriety of all funds received. Further, the expenditures reported on the Period filings were limited to the amount of funding received. Recommendation: In the future, the Organization should ensure it implements appropriate processes and controls to ensure a review is performed prior to submission to the awarding agency. Contact: David Hildenbrand, Chief Financial Officer. Corrective Actions Taken or Planned: Management acknowledges the finding and will ensure controls are implemented to prevent this error from reoccurring. Anticipated Completion Date: By December 31, 2023.

View Audit 4949

Finding 2936 (2023-001)

None 2023

Volunteers of America Southwest California, Inc.

CA

Reporting

The Corporation recognizes the importance of timely reporting as specified by the Notice of Awards. The Corporation experienced turnover in key positions that resulted in resubmission of final reports past the deadline. The Corporation has designed and implemented policies and practices to support t...

The Corporation recognizes the importance of timely reporting as specified by the Notice of Awards. The Corporation experienced turnover in key positions that resulted in resubmission of final reports past the deadline. The Corporation has designed and implemented policies and practices to support timely reporting to funding agencies. The Corporation will employ the use of calendars to show reporting deadlines outlined in the Notice of Awards and will file in advance of the submission date where feasible.

View Audit 4810

Finding 2752 (2023-002)

Material Weakness 2023

Alabama Council on Human Relations

AL

Reporting

Management agrees with the finding and has developed and begun implementation of a corrective action plan including filing previously unsubmitted reports.

View Audit 4766

Finding 2740 (2023-001)

Significant Deficiency 2023

Reed City Area Public Schools

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.308

This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Ma...

This finding is caused by Human error in transcribing amounts from the general ledger to the proper Activities and Objects on the Final Expenditure Report. The completion date for the corrective action plan is immediate. The person responsible for the corrective action is Tina Mills, the Business Manager. The plan for monitoring adherence is the business manager will double check reports before submitting them to the State of Michigan.

View Audit 4709

Finding 2677 (2023-001)

Significant Deficiency 2023

University of Oklahoma Norman Campus

OK

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

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma. 2023-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN ...

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma. 2023-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN 84.268 Federal Direct Student Loans, Department of Education, Award Year 2023 Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR § 690.83(b)(2) and 34 CFR §685.309(b)(1) Finding Summary: The University is required to implement a system of internal controls that ensure enrollment information is reported to Department of Education's National Student Loan Data System (NSLDS) each 60 days, at minimum. Enrollment information for eight students graduating in Spring 2023 was not reported timely to NSLDS. Explanation of Agreement/Disagreement: Management concurs with the finding and proper internal controls are being implemented during FY2024. Officials Responsible for Ensuring Corrective Action: Courtney Henderson, Acting Financial Aid Director. Planned Completion for Corrective Action: Corrected enrollment information was submitted to NSLDS on August 18, 2023. Corrective internal controls have been implemented as of October 12, 2023. Plan to Monitor Completion of Corrective Action: Management concurs with the finding and proper internal controls were implemented during FY2024. Management has implemented regular monthly meetings between the Financial Aid Services and Academic Records departments of the University to review graduation error reports and ensure timely processing.

View Audit 4516

Finding 2675 (2023-002)

None 2023

Lincoln County, Nebraska

NE

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

West Central NE Development District will need to collect reports from various offices (County Clerk & County Treasurer) to verify all expenditures and disbursements match and perform their own calculations.

View Audit 4513

Finding 2649 (2023-001)

Significant Deficiency 2023

Albuquerque Health Care for the Homeless, Inc.

NM

Internal Control / Segregation of Duties Procurement, Suspension & Debarment HUD Housing Programs § 200.302

Albuquerque Health Care for the Homeless, Inc.’s Finance Team will work to ensure that Policy and Procedure 4011 regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained by the Accounting Manager on the importance of obt...

Albuquerque Health Care for the Homeless, Inc.’s Finance Team will work to ensure that Policy and Procedure 4011 regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained by the Accounting Manager on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding. Persons Responsible: Leon Paboucek, Accounting Manager Estimated Completion Date: October 25, 2023

View Audit 4466

Finding 2630 (2023-001)

Significant Deficiency 2023

Alight

MN

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

Views of Responsible Officials: As part of our investigation, we determined staff involved in the embezzlement colluded to circumvent Alight’s systems of internal controls at the directions of an Alight manager. In addition to taking the immediate actions listed above, including terminating the empl...

Views of Responsible Officials: As part of our investigation, we determined staff involved in the embezzlement colluded to circumvent Alight’s systems of internal controls at the directions of an Alight manager. In addition to taking the immediate actions listed above, including terminating the employment of staff involved, we also took the following actions:  We filed a police report, and are pursuing legal actions against the key actors involved in the malfeasance.  Alight’s executive leaders conducted policy, procedures and fraud notification training with the Thai staff including how to report suspected incidence of fraud.  Executive leaders and Thai leaders traveled to field offices to review operations and provide staff the opportunity to report issues. We believe these actions reinforce management’s zero tolerance to fraud and offer staff the knowledge and opportunity to report potential issues going forward.

View Audit 4459

Finding 2523 (2023-001)

Significant Deficiency 2023

Kent State University

OH

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.413 § 200.516

Upon learning of the possibility of frauduelent activity, the University began an internal audit review and all activity on the grant was stopped. Throughout the process, the University coordinated with the Ohio Department of Development. The internal audit procedures led to the determination that $...

Upon learning of the possibility of frauduelent activity, the University began an internal audit review and all activity on the grant was stopped. Throughout the process, the University coordinated with the Ohio Department of Development. The internal audit procedures led to the determination that $209,101 was incorrectly reported by the program advisor and was not detected by the program director. These funds were returned to the Ohio Department of Development on October 11, 2023. The program has been termianted and program income returned. The individuals involved with this program are no longer employees of the University. The University is in the process of seeking reimbursement from the former employee. An internal controls questionnaire was prepared and reviewed for the other Small Business Development Center (SBDC) program noting no areas of concern. The FY24 internal audit plan will include additional review of the remaining SBDC program as well as review of controls within the department which previously managed the program noted in the finding. In addition, training related to roles and responsibilities for supervisors/approvers will be provided in FY24 to emphasize the guidance provided in the grants manual. Contact person responsible for the corrective action: Mark Polatajko, Senior Vice President for Finance and Administration.

View Audit 4303 Questioned Costs: $1

Finding 2519 (2023-002)

Significant Deficiency 2023

C.h.i.l.d, Inc.

RI

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

FINDINGS - FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY 2023-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that management monitor reporting deadlines to meet all reporting requirements. Explanation of disagreement with audit finding: There is no...

FINDINGS - FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY 2023-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that management monitor reporting deadlines to meet all reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding, however, once again we plead considerable staff shortage. Action planned/taken in response to finding: We have now filled a critical position which will allow us to distribute responsibilities more effectively and ensure that internal controls are consistently applied. Name of the contact person responsible for corrective action: Anne Paglia Planned completion date for corrective action plan: December 2023. If the Department of Health and Human Services has questions regarding this plan, please call Anne Paglia at 401-732-5200

View Audit 4302

Finding 2502 (2023-001)

Significant Deficiency 2023

Florence County School District No. 5

SC

Reporting Internal Control / Segregation of Duties

Management continues to monitor the stiuation to determine the cost/benefit to the District. Presently, management believes that the costs outweighs the benefit to implement this particular safeguard.

View Audit 4274

Finding 2492 (2023-001)

Significant Deficiency 2023

Three Square

NV

Special Tests & Provisions Reporting School Nutrition Programs § 200.303

2023-001 Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a sys...

2023-001 Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete.

View Audit 4240

Finding 2455 (2023-001)

Material Weakness 2023

Wpc Housing Corp. Danford Hall Apartments

MO

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED FEBRUARY 28, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED FEBRUARY 28, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended February 28, 2023. Finding 2023-001 Responsible Party Name: Tamara Wallace Position: Executive Director – Management Agent Telephone Number: 816-233-4250 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Rental and Cooperative Housing (Section 221(d)(4)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action We will ensure that the accounts reconcile to source documents as part of our month-end closing process. Anticipated Completion Date September 30, 2023

View Audit 4230

Finding 2432 (2023-001)

Material Weakness 2023

Oneida, Herkimer, and Madison Counties Boces

NY

School Nutrition Programs Cash Management Material Weakness

Finding 2023-001 – Reporting The BOCES concurs with the finding 2023-001. Corrective Action: To correct this in the future 2 steps will be implemented by the BOCES: 1. A manual total of meals from the Etrition claim reports will be calculated and compared to the total meals on the CNMS claim; and 2....

Finding 2023-001 – Reporting The BOCES concurs with the finding 2023-001. Corrective Action: To correct this in the future 2 steps will be implemented by the BOCES: 1. A manual total of meals from the Etrition claim reports will be calculated and compared to the total meals on the CNMS claim; and 2. The School Food Service Director and Director of Shared Food Services will review and verify each other's work. Additional checks and balances will be put in place immediately so that reliance is not solely on the computerized system. Contact Person: Kate Dorr, Director of Shared Food Service (315) 738-0848 kdorr@oneida-boces.org

View Audit 4195

Finding 2403 (2023-001)

Significant Deficiency 2023

Town of Cary

NC

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding: 2023-001 Name of Contact Person: Kimberly Branch, Finance Director Corrective Action: Cary has implemented a more formal review process over the report prior to submission, which includes evidence of the review. This has already been corrected with the recent quarterly report submission. Pr...

Finding: 2023-001 Name of Contact Person: Kimberly Branch, Finance Director Corrective Action: Cary has implemented a more formal review process over the report prior to submission, which includes evidence of the review. This has already been corrected with the recent quarterly report submission. Proposed Completion Date: October 31, 2023

View Audit 4130

Finding 2395 (2023-002)

Significant Deficiency 2023

Amarillo Independent School District

TX

Reporting

Additional monitoring and comprehensive review of expenditure reporting will take place, with emphasis on matching accounting data presented in the District’s financial system.

View Audit 4100

Finding 2341 (2023-001)

Significant Deficiency 2023

Claremont Lincoln University

CA

Student Financial Aid Reporting Significant Deficiency

Management’s Corrective Action Plan Finding 2023-001 Special Tests and Provisions- Enrollment Reporting- Significant Deficiency in Internal Control over Compliance. Responsible Office and Individuals The Associate Vice President of Student Financial Services, Jazmin Martin and the Executive Vice Pre...

Management’s Corrective Action Plan Finding 2023-001 Special Tests and Provisions- Enrollment Reporting- Significant Deficiency in Internal Control over Compliance. Responsible Office and Individuals The Associate Vice President of Student Financial Services, Jazmin Martin and the Executive Vice President/Chief Operations Officer, Mark Mendoza are responsible for the development of the processes, and implementation of the corrective actions described in the Corrective Action Plan. The corrective actions will result in timely and accurate reporting to NSLDS. Corrective Action Plan Management accepts responsibility for this significant deficiency in internal control over compliance and has implemented a new financial aid management system (Campus Ivy) and process to ensure that students’ statuses are reported timely. To maintain accuracy and compliance with the Title IV regulations, Campus Ivy will perform weekly, monthly, and bi-monthly National Student Loan Data System (NSLDS) enrollment reporting. Enrollment reporting is a process by which a student’s enrollment status and program of study is reported to NSLDS on a timely basis to meet the U.S. Department of Education’s 30-day and 60-day reporting requirements. The Student Financial Services Department will provide accurate and timely information to Campus Ivy and Campus Ivy will report that information timely and accurately to NSLDS. Campus Ivy’s Core system receives the NSLDS Enrollment Roster as scheduled on the 5th of the month every 60-days. The Core system will automatically load the roster and update all relevant enrollment data based on the information sent from CLU through the secure data import on an ongoing basis. These updates are then batched by the system to be transmitted to NSLDS. The Student Financial Services Department, through the student information system (Maestro), will provide student information updates. The Student Financial Services Department will sync updates to the Campus Ivy Core Financial Aid Management System (Core) with all students’ academic and demographic information from Maestro, by imports through Campus Ivy’s secure encrypted portal or through direct integration. The Student Financial Services Department will be responsible for timely and accurate updates of the Core system. The Student Financial Services Department will ensure daily updates from Maestro to clear any failed validations. The student data import process has built in validations to assist CLU with maintaining accurate data. These validations are on both the student’s demographic and academic information. In addition to the bi-monthly roster process, Campus Ivy also sends bi-weekly updates to NSLDS to record enrollment updates on an ongoing basis, well within the 30-day timeframe set by the Department of Education. The NSLDS module within Campus Ivy stores all roster batches processed by the system. CLU will have access to view our Roster Batches at any time and can request changes through our 24/7 Support Site. Anticipated Completion Date The anticipated completion date of the corrective action plan is November 30, 2023

View Audit 4011

Finding 2340 (2023-003)

Significant Deficiency 2023

Antelope County

NE

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

Antelope County will complete the annual expenditure report as required by ARPA Funding.

View Audit 4002

Finding 2326 (2023-002)

Significant Deficiency 2023

Marquette Area Public Schools

MI

Allowable Costs / Cost Principles Reporting § 200.430

The School District recognizes the issue identified during the audit and has made all necessary adjustments to ensure compliance with spending down the remaining ESSER III funding.

View Audit 3993

Finding 2325 (2023-003)

Significant Deficiency 2023

Holt County

NE

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

Holt County will create a spreadsheet that will track expenditures and obligations.

View Audit 3982

Finding 2319 (2023-002)

Material Weakness 2023

Harrison County Community Hospital District

MO

Questioned Costs Material Weakness Reporting

Identification: 93.498 United States Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution; Noncompliance Finding/Material Weakness; Activities Allowed Compliance Requirement. Corrective Action Plan: The Hospital District will make improvements to ...

Identification: 93.498 United States Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution; Noncompliance Finding/Material Weakness; Activities Allowed Compliance Requirement. Corrective Action Plan: The Hospital District will make improvements to its procedures over federal grant reporting to ensure that future reporting submissions do not contain duplicated expenditures. Anticipated completion date: The Hospital District will implement improvements to its procedures over federal grant reporting beginning in FY 2024.

View Audit 3969 Questioned Costs: $1

Finding 2292 (2023-002)

Material Weakness 2023

Bellin College, Inc.

WI

Reporting Internal Control / Segregation of Duties

Finding 2023-002 Pell Under Awarded It was discovered during the annual audit that Pell Grant awards for the 2022-2023 academic year were calculated on the original Pell Grant Payment Schedules released by the US Dept of Education. The financial aid office did not see the communication from the US ...

Finding 2023-002 Pell Under Awarded It was discovered during the annual audit that Pell Grant awards for the 2022-2023 academic year were calculated on the original Pell Grant Payment Schedules released by the US Dept of Education. The financial aid office did not see the communication from the US Dept of Education regarding the Revised Pell Grant Payment Schedules which were released later in the spring of 2022. As a result, students were under awarded. Corrective Action The Director of Financial Aid (DFA) contacted the US Dept of Education for guidance on how to rectify the issue. The DFA was instructed to request an extension of the 2022-2023 Pell Grant processing via a link on the COD website. The extension was approved. The DFA then manually processed a Pell Grant disbursement for each Pell Grant recipient to increase the total Pell Grant award for each to the amount entitled. Each of the 80 Pell Grant recipients was issued a check as payment for the balance of the Pell Grant award. The checks were distributed the week of October 16, 2023 to each student along with a written explanation of the oversight. Going forward, the DFA will periodically check the US Dept of Education Knowledge Center website to ensure any schedule revisions are obtained. Person Responsible for Corrective Action: Ginger Krummen Schraven Timing of Corrective Action: October 2023

View Audit 3929

Finding 2291 (2023-001)

Significant Deficiency 2023

Bellin College, Inc.

WI

Reporting Internal Control / Segregation of Duties

Finding 2023-001 Common Origination and Disbursement (COD) Reporting Two instances were found in which the disbursement date on COD did not match the date on the student ledger. Corrective Action Going forward, the Director of Financial Aid (DFA) will provide the Bursar with a report from the COD...

Finding 2023-001 Common Origination and Disbursement (COD) Reporting Two instances were found in which the disbursement date on COD did not match the date on the student ledger. Corrective Action Going forward, the Director of Financial Aid (DFA) will provide the Bursar with a report from the COD that reflects the disbursement date. Before posting federal award batches, the Bursar will verify the date on the batch matches the SIS system. Person Responsible for Corrective Action: Ginger Krummen Schraven Timing of Corrective Action: October 2023

View Audit 3929

Finding 2286 (2023-001)

Material Weakness 2023

Mitchell Public Schools

NE

Reporting Internal Control / Segregation of Duties

2023-001 SEGREGATION OF ACCOUNTING FUNCTIONS Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Education should constantly be aware of the possibil...

2023-001 SEGREGATION OF ACCOUNTING FUNCTIONS Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Education should constantly be aware of the possibility that errors or fraud could occur and continue current practices mitigating these possibilities and examine and implement other mitigating controls when appropriate. Action Taken: The District has assessed the benefits and costs associated with proper segregation of duties for the district and has determined that costs would outweigh benefits received. The District understands the inherent risks associated with improper segregation of accounting functions. Management has communicated the need for transactions to be well supported by documentation as well as seeking appropriate authorization when appropriate. The District requires monthly reporting to the Board of Education for all disbursements to ensure transactions are proper and potential errors and irregularities are identified on a timely basis. The District will continue to review accounting procedures and processes to further mitigate this internal control deficiency whenever possible and feasible.

View Audit 3928

Corrective Action Plans

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