Corrective Action Plans

Finding 369029 (2023-001)

Significant Deficiency 2023

TN

Subrecipient Monitoring HUD Housing Programs Reporting

Planned Corrective Actions: The City continues to work with a consultant to assist staff with administration of the Community Development Block Grants program. Community Development has also hired a new Assistant Director and Grant Coordinator during FY 24 who have worked with the consultant to revi...

Planned Corrective Actions: The City continues to work with a consultant to assist staff with administration of the Community Development Block Grants program. Community Development has also hired a new Assistant Director and Grant Coordinator during FY 24 who have worked with the consultant to review processes and implement changes as necessary. Process reviews include reviewing methods for tracking and reporting time and activity spent on the programs.

View Audit 290453

Finding 367381 (2023-006)

Significant Deficiency 2023

City of Belmont

NC

Reporting Significant Deficiency Internal Control / Segregation of Duties

Significant Deficiency Finding 2023-006: Name of Contact Person: Jared Pyles, Finance Director Corrective Action: The City mistakenly reported budgeted costs rather than cumulative costs as part of the compliance reporting for ARPA Funds. The City will correct on its next reporting and will inclu...

Significant Deficiency Finding 2023-006: Name of Contact Person: Jared Pyles, Finance Director Corrective Action: The City mistakenly reported budgeted costs rather than cumulative costs as part of the compliance reporting for ARPA Funds. The City will correct on its next reporting and will include an additional layer of review to prevent future reporting errors. Proposed Completion Date: Immediately.

View Audit 290376

Finding 367378 (2023-002)

Material Weakness 2023

The Inner Voice, Inc.

IL

Internal Control / Segregation of Duties Material Weakness Reporting

Management will be reviewing policies and procedures in the month of May every year. Additionally, the Director of Finance has been hired and joined Inner Voice effective October 16, 2023. The additional member of the finance department will allow for stronger internal controls and segregation of du...

Management will be reviewing policies and procedures in the month of May every year. Additionally, the Director of Finance has been hired and joined Inner Voice effective October 16, 2023. The additional member of the finance department will allow for stronger internal controls and segregation of duties.

View Audit 290359

Finding 367377 (2023-001)

Material Weakness 2023

The Inner Voice, Inc.

IL

Internal Control / Segregation of Duties Material Weakness Reporting

Inner Voice hired a Director of Finance with extensive experience in accounting and HR on October 16, 2023. The Director of Finance reports directly to the CFO.

View Audit 290359

Finding 367238 (2023-001)

Material Weakness 2023

Esperanza United

MN

Material Weakness Reporting § 200.512

The Organization continues to work with the contract financial team who plans to have the books closed in a timely manner going forward. The Organization is also actively working with their auditor to improve communication during the audit so a future break-down in communication does not occur. We e...

The Organization continues to work with the contract financial team who plans to have the books closed in a timely manner going forward. The Organization is also actively working with their auditor to improve communication during the audit so a future break-down in communication does not occur. We expect the issue will be mitigated for the 2023 audit.

View Audit 290340

Finding 367209 (2023-001)

Significant Deficiency 2023

Southern California Institute of Architecture

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action wa...

Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action was implemented in December 2023. The school's management agrees with the finding and has implemented procedure whereby changes in enrollment status reported to the National Student Clearinghouse will be sample reviewed by the Registrar within NSLDS five business days following the reporting date to ensure the accuracy of the information. As an additional layer, the Financial Aid Manager will also calendar a review reminder. Permanent address changes will be reported on a six-week cycle after the add/drop period each term. Address changes will also be sample reviewed to ensure accuracy within NSLDS.

View Audit 290324

Finding 367196 (2023-002)

Significant Deficiency 2023

Hamline University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are b...

Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.

View Audit 290314

Finding 367181 (2023-001)

Significant Deficiency 2023

City of Clarksville

TN

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 3...

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 30, 2023.

View Audit 290301

Finding 367079 (2023-001)

Significant Deficiency 2023

Avondale Elementary School District No. 44

AZ

Questioned Costs Cash Management Reporting

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Vanessa Bonfim Anticipated Completion Date: March 6, 2024 Planned Corrective Action: • In order to ensure that correct claim numbers are ...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Vanessa Bonfim Anticipated Completion Date: March 6, 2024 Planned Corrective Action: • In order to ensure that correct claim numbers are submitted to AZ Department of Education, the Food Services Department will perform double monthly checks when claims are entered into ADEConnect website, before actual submission. • Claims are entered into ADEConnect by the Food Service Liaison and double check will occur at the same time by the food service supervisor. • Monthly scheduled time will be set once a month to process claims.

View Audit 290291 Questioned Costs: $1

Finding 367063 (2023-002)

Material Weakness 2023

City of Burton, Michigan

MI

Reporting § 200.502 § 200.510

Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: The City will be implementing a procedure whereby the Controller’s Office receives copies of all contracts to ensure all reporting requirements are met and financial deliverable...

Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: The City will be implementing a procedure whereby the Controller’s Office receives copies of all contracts to ensure all reporting requirements are met and financial deliverables are completed according to the schedules. Contact person responsible for corrective action: Brandy Ruth Anticipated Completion Date: June 2024

View Audit 290236

Finding 367039 (2023-001)

Significant Deficiency 2023

Monterey Peninsula Community College District

CA

Student Financial Aid Reporting Significant Deficiency

We concur with the condition noted above. Management believes that the controls in place are appropriately designed to prevent and or detect errors. This instance was isolated and resulted from a coding error related to incorrectly keying the accounting string into our accounting system, which went ...

We concur with the condition noted above. Management believes that the controls in place are appropriately designed to prevent and or detect errors. This instance was isolated and resulted from a coding error related to incorrectly keying the accounting string into our accounting system, which went undetected. Management reassessed the controls over reporting and compliance with laws and regulations. The following steps have been taken to strengthen controls: • Implement enhanced management tools i.e. ERP and shared weekly ledger reports • Staff training in accounts payable to identify and correct errors • Develop operating procedures requiring weekly budget monitoring and updates for program managers

View Audit 290204

Finding 366983 (2023-005)

None 2023

Town of Bluefield, Virginia

VA

Reporting § 200.516

The Town concurs with the finding; however, it will be corrected as the Town will have fully spent the funds by the next filing due March 31, 2024.

View Audit 290163

Finding 366974 (2023-003)

Significant Deficiency 2023

Adrian Public Schools

MI

Allowable Costs / Cost Principles Reporting

Finding: 2023-003 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting U.S. Department of Agriculture – Child Nutrition Cluster (ALN 10.CNC); Passed through MDE; All project numbers. Auditor Description of Condition and Effect: During our audit procedures over the District's...

Finding: 2023-003 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting U.S. Department of Agriculture – Child Nutrition Cluster (ALN 10.CNC); Passed through MDE; All project numbers. Auditor Description of Condition and Effect: During our audit procedures over the District's reporting process, we noted that none of the claim requests selected for testing were subject to an independent review and approval process. We also noted that one out of the three reports selected for testing had the incorrect number of snack meals. As a result of this condition, the District did not comply fully with the reporting requirements under this federal award. In addition, the District was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Auditor Recommendation: We recommend that the District establish procedures to ensure that the number of meals being submitted for reimbursement agrees to the actual meal counts, and that all reports are subject to review and approval by an independent employee prior to submission. Corrective Action: The Food Services Director will review and total actual meal counts monthly, and the Food Services Administrative Assistant will review and verify the actual meal counts. The Business Manager will review and verify the monthly meal count after it is filed with the Business Office each month. Responsible Person: Shelley Miller, Food Service Director and Daniel Pena, Business Manager Anticipated Completion Date: June 30, 2024

View Audit 290150

Finding 366946 (2023-002)

Significant Deficiency 2023

West Virginia Public Transit Association

WV

Reporting Internal Control / Segregation of Duties

CONTROLS OVER GRANT REPORTING Department of Health and Human Services 93.788 Management within West Virginia Public Transit Association appreciates and shares the auditors’ concern with integrity as it relates to controls over grant reporting. The State Opioid Response Transportation Project Manage...

CONTROLS OVER GRANT REPORTING Department of Health and Human Services 93.788 Management within West Virginia Public Transit Association appreciates and shares the auditors’ concern with integrity as it relates to controls over grant reporting. The State Opioid Response Transportation Project Manager will submit all future grant reports to the West Virginia Public Transit Association Treasurer for review prior to submission to grantor. The Treasurer will document approval in writing. This will begin with the quarter ending September 29, 2023.

View Audit 290117

Finding 366945 (2023-001)

None 2023

West Virginia Public Transit Association

WV

Reporting

GRANT REPORTING RECONCILIATION Department of Health and Human Services 93.788 Program management will implement policies and procedures to ensure proper grant reporting reconciliation. The State Opioid Response Project Manager will reconcile all reports submitted to the grantor to the underlying ac...

GRANT REPORTING RECONCILIATION Department of Health and Human Services 93.788 Program management will implement policies and procedures to ensure proper grant reporting reconciliation. The State Opioid Response Project Manager will reconcile all reports submitted to the grantor to the underlying accounting records used to prepare the schedule of expenditures of federal awards. Beginning FY24, WVPTA State Opioid Response grant funds will be reported on an accrual basis rather than a cash basis. Additionally, the State Opioid Response Project Manager will work with all participating transit agencies to ensure timely submission of quarterly expenses so reconciliations accurately portray expenses incurred during that time period.

View Audit 290117

Finding 366935 (2023-001)

Significant Deficiency 2023

Lake Orion Community Schools

MI

Cash Management School Nutrition Programs Subrecipient Monitoring

Finding Number: 2023-001 Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the free, reduced and total number of meals. Therefore, if the number of free or reduced meals is typed incorrectly, the difference automatically adds...

Finding Number: 2023-001 Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the free, reduced and total number of meals. Therefore, if the number of free or reduced meals is typed incorrectly, the difference automatically adds or subtracts to the number of fullpaid meals. While there is review and approval of amounts prior to entering meal counts into the MiND system, the district did not consider that once free and reduced meals are entered into the system, the number of full pay meals auto fills to the number required to match/balance the total meals served. This resulted in the District not identifying that two claims requests undercounted reimbursable meals which shorted the District receiving additional funding of $7,639. Planned Corrective Action: After an in-depth review of the circumstances that led to the incorrect (under count) request for meal reimbursement error, an additional review and approval procedure has been implemented. This will ensure the final meal claims data, including the MiND system auto calculated data reflects the district’s internal meal count data reporting. Contact person responsible for corrective action: John Fitzgerald, Assistant Superintendent for Business & Finance Completion Date: July 31, 2023

View Audit 290110

Finding 366932 (2023-003)

Material Weakness 2023

Bernalillo Public School District

NM

Reporting

2023‐003 (2022‐004) — Inaccurate Reporting on Impact Aid Application (Material Weakness/Material Noncompliance) – District is working closely with the Impact Aid office at the federal level and with local Pueblos to address this finding and ensure that all proper signatures are obtained for submissi...

2023‐003 (2022‐004) — Inaccurate Reporting on Impact Aid Application (Material Weakness/Material Noncompliance) – District is working closely with the Impact Aid office at the federal level and with local Pueblos to address this finding and ensure that all proper signatures are obtained for submission. The responsible party for these corrective actions is the Grant Coordinator.

View Audit 290108

Finding 366925 (2023-002)

Significant Deficiency 2023

Calumet College of St. Joseph

IN

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

The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from N...

The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from Notepad) with the help of the Institutional Research office to ensure that data meets the criteria required by the clearinghouse and is free of errors. The responsibility to ensure that data submitted to the National Clearinghouse and NSLDS remains with the Registrar’s office at CCSJ. The Registrar’s office at CCSJ will review data for accuracy, timeliness, and completeness before uploading to the FTP Clearinghouse site. Furthermore, the Director of Student Financial Services has been added as a secondary administrator to the college’s FTP clearinghouse account in which he and the Registrar will receive alerts generated through the Clearinghouse when reports have been uploaded to the site. The Registrar is the primary party responsible for clearing alerts, but the Director of Student Financial Services will verify that the alerts have been cleared. Responsible officers: Marlena Avalos, Assistant Vice President of Academic Affairs (mavalos@ccsj.edu); Derek Shouba, Vice President of Academic Affairs Estimated completion date: March 31, 2024

View Audit 290098

Finding 366914 (2023-002)

Significant Deficiency 2023

City of Santa Fe Springs

CA

Reporting

Action taken in response to finding: The City is aware of the reporting requirement. This is a final report; no further report is needed moving forward. Name(s) of the contact person(s) responsible for corrective action: Lana Dich Planned completion date for corrective action plan: This is the final...

Action taken in response to finding: The City is aware of the reporting requirement. This is a final report; no further report is needed moving forward. Name(s) of the contact person(s) responsible for corrective action: Lana Dich Planned completion date for corrective action plan: This is the final report; no further report will be required.

View Audit 290078

Finding 366913 (2023-001)

Significant Deficiency 2023

Brevard Housing Authority

NC

HUD Housing Programs Reporting Significant Deficiency § 200.512

Corrective Action Plan: The Brevard Housing Authority procured the auditor in year of 2019 for a three (3) year term. The engagement letter was signed for the FY 2023 audit on October 4, 2023. The auditors started the audit on October 13, 2023 by requesting Cash Disbursement testing selections. Mana...

Corrective Action Plan: The Brevard Housing Authority procured the auditor in year of 2019 for a three (3) year term. The engagement letter was signed for the FY 2023 audit on October 4, 2023. The auditors started the audit on October 13, 2023 by requesting Cash Disbursement testing selections. Management provided all information and responded to all questions timely and notified the team of office closures for holidays in November and December. Management will procure a new audit firm to ensure the due date is met in the future. Name of Responsible Person: Tara Irby, Executive Director Projected Completion Date: December 31, 2024

View Audit 290075

Finding 366871 (2023-002)

Significant Deficiency 2023

Wentworth Institute of Technology, Inc.

MA

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

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, three students were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSC and from NSC to NSLDS, utilizing enhanced exception reporting and a structured process to identify any discrepancies in the data. Names of Contact Persons Responsible for Corrective Action: Nadira Dookharan, Registrar and Anne-Marie Caruso, Associate Vice President, Student Financial Services Anticipated Completion Date: November 30, 2023

View Audit 289972

Finding 366823 (2023-002)

Material Weakness 2023

South Suburban College - Community College District #510

IL

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

FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure SSCR information is...

FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure SSCR information is remitted timely as well as properly reviewed and approved. Plan South Suburban College's Financial Aid Director will work in conjunction with the Director of Registration to review and verify the Student Status Change Report (SSCR) submitted to the Clearinghouse is cross-referenced with the Title IV students in the National Student Loan Data System (NSLDS). To administer this process control the Financial Aid Director will establish a monthly meeting with the Director of Registration to ensure that student status changes are being accurately reported from the Clearinghouse database to the NSLDS. If corrections are needed within the 30-day window the Financial Aid Director will notify the Financial Aid Manager to work with the registration department to reconcile and update any student status changes. Maintaining the control implemented will allow South Suburban College to remain in compliance with the Uniform Guidance in the Compliance Supplement. This was also identified during the audit request. Documentation was provided that the National Student Loan Data System was having issues with their system reporting accurate student status changes during that timeframe. *This corrective plan has been implemented. Anticipated Date of Completion 1/24/24 Name of Contact Person Avianca Taylor, MBA

View Audit 289882

Finding 366822 (2023-001)

Material Weakness 2023

South Suburban College - Community College District #510

IL

Student Financial Aid Reporting

FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER-REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures regarding timely submission of COD inform...

FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER-REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures regarding timely submission of COD information. Plan South Suburban College Financial Aid Department has implemented cross-training between the Financial Aid Manager, Financial Aid Coordinator, and Financial Aid Advisor to reinforce in the case of possible turnover the established controls for processing Pell Common Origination and Disbursement payments within the 15 days of submission window per the required Uniform Guidance in the Compliance Supplement. For instance, the control will consist of one of the designated staff members listed to process the batches weekly. This will allow all batches to be processed within 7 days assuring that the 15-day submission period is within compliance. In addition, the Director of Financial Aid has added a weekly calendar reminder for all trained staff to avoid missing batch processes due to personnel being out of the office or working from home. This control process was executed after positions were successfully filled and staff trained, in the Fall 2022 term. The process has been accomplished in Spring 2023. *The corrective action plan has been implemented. Anticipated Date of Completion 1/24/24 Name of Contact Person Avianca Taylor, MBA

View Audit 289882

Finding 366792 (2023-004)

Material Weakness 2023

School District of Stratford

WI

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

2023-004 ESSER - Segregation of Duties – Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants. Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/T...

2023-004 ESSER - Segregation of Duties – Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the ESSER grants. Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/Taken in Response to Finding: Lauren Lucius will prepare the ESSER claim and either Tonya Gebert or Rodney Huther will approve the claim before it is submitted. Name of the Contact Person Responsible for Corrective Action: Lauren Lucius Planned Completion Date for Corrective Action Plan: December 15, 2023

View Audit 289834

Finding 366770 (2023-001)

None 2023

Nebraska Wesleyan University

NE

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

We discovered the program was only reporting students as lessthan- half-time (“L”), half-time (“H”), and full-time (“F”). We have already adjusted the enrollment reporting program to properly report students who are enrolled at a ¾-time (“Q”) level. We will also work with the National Student Cleari...

We discovered the program was only reporting students as lessthan- half-time (“L”), half-time (“H”), and full-time (“F”). We have already adjusted the enrollment reporting program to properly report students who are enrolled at a ¾-time (“Q”) level. We will also work with the National Student Clearinghouse to ensure the enrollment effective dates are correctly reported for both the campus and program levels. Contact person: Tom Ochsner, Director of Scholarships and Financial Aid Planned completion date for corrective action plan: October 2023 If the Department of Education has questions regarding this plan, please call Tom Ochsner at (402) 465- 2212.

View Audit 289817

Corrective Action Plans

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