Corrective Action Plans

Finding 45022 (2022-001)

Significant Deficiency 2022

GA

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

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Federal Awarding Agency: U.S. Department of Education Pass-Thr...

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

View Audit 39876 Questioned Costs: $1

Finding 44958 (2022-001)

Material Weakness 2022

Coalition for Independent Living Options INC

FL

Reporting Material Weakness Matching / Level of Effort / Earmarking § 200.303

2022-001 ? Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) ? We feel that much was learned in the audit process by Organization staff and Palm Beach Accounting and Financial Services. We will make the Schedule of Expenditures of Federal Awards a priority in the next audi...

2022-001 ? Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) ? We feel that much was learned in the audit process by Organization staff and Palm Beach Accounting and Financial Services. We will make the Schedule of Expenditures of Federal Awards a priority in the next audit, and if need will retain an expert consultant to assist in the preparation prior to providing to the audit firm.

View Audit 45794

Finding 44948 (2022-002)

Significant Deficiency 2022

Albright College

PA

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corr...

Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corrective Action Plan The College has corrected the misstated reports. To help ensure this does not occur again, the College will appropriately assign all necessary data collection responsibilities and ensure that corresponding submission deadline are clearly communicated. The Assistant Controller will be assigned the responsibility to coordinate the collection of necessary data and the compilation of the report. The Controller will then review the draft report and make timely submission. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeffrey Strader ? Vice President, Finance and Strategic Partnerships Anticipated Completion Date: Reports have been corrected as of February 2023 and secondary review will be performed in quarters going forward. Procedures will be incorporated into the College?s work processes during Fiscal Year 2022-2023

View Audit 39624

Finding 44947 (2022-001)

None 2022

King's College

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year -...

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.

View Audit 38808

Finding 44891 (2022-002)

Significant Deficiency 2022

University of Miami

FL

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

2022-002: FOL and Pell Reporting Management Views and Opinion ...

2022-002: FOL and Pell Reporting Management Views and Opinion The University of Miami acknowledges that the disbursements as reflected on the individual student account were different by one day from the date reported to COD (Common Origination and Disbursement system). This error occurred due to the timing of scheduled jobs to run financial aid disbursement. The file process to disburse jobs ran late at night prior to midnight, but the job to post the disbursed aid ran after midnight and therefore showed a day later than reflected on the financial aid system. Corrective Action Plan In mid-August 2022, the University changed the evening job schedule to ensure that Federal financial aid will be both disbursed from the-financial aid system and posted to the Student Account on the same calendar day. This evening schedule job change will resolve this situation moving forward. Timeline for Action Plan The underlying issue was already corrected in August 2022. Responsible Individuals Daniel T. Barkowitz Roosevelt Deleveaux Norma De La 0

View Audit 46839

Finding 44890 (2022-001)

Significant Deficiency 2022

University of Miami

FL

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

2022-001 Enrollment Reporting Management Views and Opinion ...

2022-001 Enrollment Reporting Management Views and Opinion Graduation Status Change UM management agrees that I out of 40 students had graduated but whose graduation status change was not reported at the campus or program level. While this student's graduation status change was not reported at the campus or program level, the student's record was reported as withdrawn within the allotted 60 days and therefore NSLDS was aware student was no longer enrolled. Enrollment Status Change UM management agrees that 14 out of 40 students' program level withdrawal date did not match their campus level withdrawal date. While all the students' withdrawal statuses were reported within the NSDLS guidelines and the final day of the Fall 2021 semester was used for their campus level withdrawal date, the first day of the Spring 2022 semester was incorrectly used for the program level withdrawal date. Corrective Action Plan Graduation Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status changes. Enrollment Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status updates based on the National Student Clearinghouse (NSC) Error Resolution Report. Timeline for Action Plan Graduation Status Change The review process for graduation status changes was implemented effective December 9, 2022. Enrollment Status Change The review process for enrollment status changes was implemented effective December 9, 2022. Responsible Individuals Allen Augustin, Associate Registrar

View Audit 46839

Finding 44889 (2022-005)

Significant Deficiency 2022

University of Miami

FL

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking § 200.303

2022-005 Reporting Management Views and Opinion UM management agrees that the PRF Period 1 reporting submission was subseq...

2022-005 Reporting Management Views and Opinion UM management agrees that the PRF Period 1 reporting submission was subsequently revised to remove $14,854,235 of Other Provider Relief Fund Expenses. The Other Provider Relief Fund Expenses removed from the Period 1 submission were allowable. However, given the dynamic reporting guidance and best practices circulated subsequent to the Period 1 reporting submission, it was determined by management to utilize lost revenues to support the PRF funding rather than expenses incurred. Corrective Action Plan UM management believes this to be an isolated incident due to the novel COVID-19 virus. While management will work to avoid the need for revised reporting submissions, management will continue to ensure the reports align with the latest guidance and best practices. Timeline for Action Plan UM management identified the need for a revised report and has already completed the revised submission. Responsible Individuals Charity Fannin, Chief Accounting Officer Craig McAllister, Assistant VP Risk Management

View Audit 46839

Finding 44887 (2022-004)

Significant Deficiency 2022

University of Miami

FL

Reporting Matching / Level of Effort / Earmarking § 200.303

2022-004 Reporting Management Views and Corrective Action Plan Quarterly Report Posting There was minimal reporting guida...

2022-004 Reporting Management Views and Corrective Action Plan Quarterly Report Posting There was minimal reporting guidance available during the initial HEERF I disbursement period. Although there are no more funds to report, UM management will ensure to follow the guidelines of reporting, and all required content is timely posted on the UM website. Quarterly Report Submission While the submission to the Department of the Education was on time, the posting on the website was slightly delayed for calendar quarters ended June 30, 2021, and September 30, 2021. Although funds have been fully disbursed, UM management will complete future required reports with ample time to allow the website team to post the required content prior to the deadline. Additionally, UM management will confirm posting took place by the deadline for tracking and assurance purposes. Quarterly Report Data Based on input from financial aid, the differences are immaterial and could be due to appeals granted after publication. The quarter report ended June 30, 2021, posted on the UM website, has a percentage error of 2.9% in the total amount distributed to students. The quarter report that ended December 31, 2021, posted on the UM website, has a percentage error of 0.2% in the total amount distributed and 0.9% in the total number of eligible students. Although funds have been fully disbursed, UM management will ensure compliance with reporting guidelines, and we will update the website if appeals have been granted after the reporting deadline. Timeline for Action Plan The corrective action plan will begin immediately with the first quarter of the calendar year 2023. Responsible Individuals Aintzane Celaya, Associate Vice President Financial Planning & Analysis and Chief Budget Officer

View Audit 46839

Finding 44881 (2022-001)

Significant Deficiency 2022

Alight

MN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken ...

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.

View Audit 44660

Finding 44873 (2022-002)

Significant Deficiency 2022

West Virginia Perinatal Partnership, Inc.

WV

Reporting Internal Control / Segregation of Duties

2022-002 CONTROLS OVER GRANT REPORTING (93.788, 93.912, and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) The Executive Director is currently cc?d on all grant report filings when they are submitted to the granting agency. Starting in 2023, the Financial Director shares all grant reports wi...

2022-002 CONTROLS OVER GRANT REPORTING (93.788, 93.912, and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) The Executive Director is currently cc?d on all grant report filings when they are submitted to the granting agency. Starting in 2023, the Financial Director shares all grant reports with the Executive Director for review and approval prior to their submission.

View Audit 40204

Finding 44872 (2022-001)

None 2022

West Virginia Perinatal Partnership, Inc.

WV

Reporting

2022-001 TIMELY GRANT REPORTING (93.788 and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) Due to the late receipt of the approved grant contracts, we were unable to timely file all required quarterly grant reports. In some instances, the due date for quarterly filings elapsed before the cont...

2022-001 TIMELY GRANT REPORTING (93.788 and 93.243 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES) Due to the late receipt of the approved grant contracts, we were unable to timely file all required quarterly grant reports. In some instances, the due date for quarterly filings elapsed before the contract was presented to us for signature. The late receipt of the contracts causes the entire process to be backlogged, from the incurring of expenses in a shortened time frame to the grant reconciliation reporting process. To remediate the finding, the Executive Director plans to request approval from the grantors of an extension of quarterly reconciliation report filings in the event any contract is entered into past the reporting deadlines. Due to the timing of the start of the 2022 audit being after the reconciliation report deadlines for this fiscal year, we expected to have this finding repeated. To remedy this concern, we will request retroactive approval for a filing extension of the reports or a waiver of the late filings due to it being a result of delayed contract approval from our grantor for 2023.

View Audit 40204

Finding 44825 (2022-002)

Significant Deficiency 2022

Corona-Norco Family Young Men's Christian Association

CA

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Reporting § 200.430

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 The findings from the schedule of findings and questioned cos...

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT 2022 ? 001 ? Significant Deficiency ? Financial Statements Closing and Reporting Recommendation: We recommend improving the independent review of monthly financial statements, in particular to the area of collectability of receivable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our organization moved from one accounting system to another causing an error in entry/recording. Our organization has implemented the following: Monthly financial reviews including receivable oversight. Review is conducted by organization?s outsourced accountant, Finance Committee as a board function, Department Program Directors, back office administrative person and the YMCA Leadership staff team. Line items are reviewed, and variances are reported in written format each month. Additionally, all receivables are reported and collected within 90 days with a 30-60-90 day follow up plan. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Service 2022 ? 002 ? Cost Principles: Compensation ? Personal Services Federal Program Name: Child Care and Development Block Grant Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing Number: 93.575, 93.576 Recommendation: We recommend the entity implement procedures to ensure that documentation in place as in accordance with the OMB's Uniform Guidance. In situation that it was reporting error from a third-party provider, we recommend the entity implement alternative procedures to maintain sufficient documentation. View of Responsible Officials: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: Our organization moved from written time sheets to a digital payroll platform. The training and staff implementation has included ongoing training with policies being rolled out and followed up with each month. Human resources has since reminded all staff of the requirement to approve their timesheets and all supervisors were reminded of this in recent staff meeting. This will be reviewed each payroll period and strong adherence will be followed with follow up action in place. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 If the U.S Department of Health and Human Services has questions regarding this plan, please call Audrie Echnoz, Chief Executive Officer at 951-479-4779.

View Audit 46033

Finding 44824 (2022-001)

None 2022

Citizens for Better Living, Inc.

MI

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form...

Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form to the Federal Audit Clearinghouse within the required time period. Management agrees to the finding and recommendation. Action(s) Taken or Planned on the Finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on October 11, 2022, no further action is required.

View Audit 46027

Finding 44823 (2022-001)

Significant Deficiency 2022

Cit of Richmond

CA

Cash Management Subrecipient Monitoring Reporting

Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: F...

Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: FEMA-4308-DR-CA Name of pass-through Entity: California Office of Emergency Services Name(s) of the contact person: Nickie Mastay, Daniel Chavarria Corrective Action Plan: Since noting the deficiencies, the Public Works Department has successfully hired a new Public Works Director, a new Deputy Public Works Director, project managers, and support staff to improve and adhere to necessary grant reporting and reimbursement with proper supporting documentation. Management has assigned a team to review and track all grants monthly, including the Via Verdi project. All team members will be trained on grant reporting and drawdown, and reminders set in their calendars to ensure these tasks are completed in a timely manner. Anticipated Completion Date: Fiscal Year 23-24

View Audit 45353

Finding 44822 (2022-002)

None 2022

City of Hawthorne

CA

HUD Housing Programs Reporting

Finance staff will review trial balances and expenditures versus expected program funding quarterly and at year end internally and with department?s grant coordinator. This will begin August 1, 2023, followed by another year end meeting November 1, 2023. Additionally, expected new internal new hire ...

Finance staff will review trial balances and expenditures versus expected program funding quarterly and at year end internally and with department?s grant coordinator. This will begin August 1, 2023, followed by another year end meeting November 1, 2023. Additionally, expected new internal new hire will add an extra layer of review to the process.

View Audit 44240

Finding 44819 (2022-001)

Material Weakness 2022

Fulton Theatre Company

PA

Internal Control / Segregation of Duties Reporting

Management's Response The Theatre has received, reviewed and accepted all journal entries, prior period adjustments, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Management expects that it wi...

Management's Response The Theatre has received, reviewed and accepted all journal entries, prior period adjustments, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Management expects that it will continue to outsource the preparation of the annual financial statements to its audit firm as this is the most cost effective manner to produce this information.

View Audit 44233

Finding 44790 (2022-067)

Significant Deficiency 2022

State of Oregon

OR

Cash Management Reporting Significant Deficiency § 200.302 § 200.303

2022-067 Oregon Department of Education Ensure accuracy of federal reporting Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19) Compliance Requireme...

2022-067 Oregon Department of Education Ensure accuracy of federal reporting Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19) Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(b); 2 CFR 200.303(a) Federal regulations require that federal reports include all activity of the reporting period and be supported by applicable accounting records. Federal regulations also require that the department file a separate report for the Governor?s Emergency Education Relief (GEER) expenditures for the period ending June 30, 2021. The department reported GEER information for the local education areas (LEAs) related to the comprehensive distance learning grant program. LEAs submit reimbursement to the department and this information is tracked in an excel database. The database includes various information, including funding types, dates, and amounts. During FY 2022, the department completed the reports using the database, but incorrectly filtered the data so some expenditures were not captured. This resulted in an underreporting of GEER expenditures by $13.9 million. We recommend department management ensure that accurate expenditure data is submitted to the federal government for federal reporting. MANAGEMENT RESPONSE: We agree with this recommendation. ODE has noted the mistake in data filtering and will remedy to ensure accurate expenditure reporting this year. Annual reporting for GEER will enable this error to be corrected moving forward. Anticipated Completion Date: June 22, 2023 Contact: Cynthia Stinson, Senior Manager of Federal Investments & Pandemic, Renewal Effort, OTLA

View Audit 45093

Finding 44784 (2022-028)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Material Weakness Reporting § 200.303

2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers...

2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19); ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness, Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 2 CFR 170, Appendix A I(a) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. The Federal Funding Accountability and Transparency Act (FFATA) requires the department to submit information for any subaward action that equals or exceeds $30,000. Program guidance required the department to report detailed subaward information directly to the federal awarding agency. This detailed subaward information encompassed all requirements related to FFATA, and the federal awarding agency gave the department the option of filing required FFATA reports on their behalf. The department stated they did not provide the detailed subaward information to the federal awarding agency to complete FFATA reporting on their behalf, and they did not complete any alternate FFATA submissions during the fiscal year due to grant award information not being available on the federal website to file their reports. As a result, the department is not in compliance with FFATA reporting requirements. We recommend department management ensure FFATA reporting is completed. MANAGEMENT RESPONSE: We agree with this recommendation. Oregon was not unique. Many states experienced frustration with the lack of clarity in the reporting process. For example, the National Coalition for State Housing Agencies sent a Feb 8, 2022 letter to urge Treasury to fix technology problems with its reporting portal, streamline reporting requirements and provide technical assistance to ERA grantees. Oregon also experienced challenges getting responses from Treasury about around reporting questions, but we understand that our federal partners were also operating under emergency circumstances and were also strained to capacity. Corrective action plan: OHCS has attempted multiple times to submit the FFATA, however the award was never made available to report on within the system. OHCS has also reached out to US Treasury multiple times to confirm that we were not required to report but have yet to hear directly from US Treasury. OHCS was able to confirm and received a response from US Treasury that went to another state that grantees were not required to complete the FFATA on the federal reporting website as US Treasury was doing that on behalf of the recipient, and OHCS did share that correspondence with SOS. Although US Treasury has been nonresponsive, OHCS will continue to attempt to obtain a direct response from US Treasury for our own records. Anticipated Completion Date: December 31, 2023 Contact: Beth Brown, Accounting Manager

View Audit 45093

Finding 44783 (2022-027)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.303

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Ye...

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

View Audit 45093

Finding 44763 (2022-061)

Significant Deficiency 2022

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award N...

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021, AA36341LA0; 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 170; 2 CFR 200.303 The WIOA Cluster is subject to subaward reporting under the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires the department to submit information for any subaward action that equals or exceeds $30,000 in the FFATA Subaward Reporting System (FSRS). Reports should be submitted no later than the end of the month following the month in which the subawards were made. Federal regulations also require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Upon inquiry of the department, we determined it had not submitted any subaward information to the FSRS during fiscal year 2022. Department management stated FFATA reporting was not completed due to staff turnover. We also reviewed information the department had submitted at USAspending.gov and determined the department had not submitted any subaward information to FSRS since 2017. The agency is not in compliance with FFATA reporting requirements. Additionally, the department is not transparent in the spending decisions of these federal awards. We recommend department management implement controls to timely prepare and submit the monthly FFATA reports as required by federal regulations. The department should also work with the federal awarding agency to determine what actions it should take for older reports not submitted. MANAGEMENT RESPONSE: We agree with this recommendation. According to the findings, the HECC didn?t submit any subaward information to the FSRS during fiscal year 2022. Furthermore, the Department had not submitted any subaward information to FSRS since 2017. The HECC acknowledges these findings are correct. Due to these findings, HECC has implemented procedures to ensure timely entry into the FFATA Subaward Reporting System (FSRS) of all awards that equal or exceed $30,000. In addition, HECC has granted FSRS access to several high-level accountants to ensure that there is always staff on hand to make these entries. The procedures include a checkbox on the cover page of every agreement that delineates when a FSRS entry is required. Anticipated Completion Date: May 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

View Audit 45093

Finding 44751 (2022-005)

Material Weakness 2022

Anoka County

MN

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

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appr...

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appropriately report the revenue offset that may impact federal programs, we have updated our quarterly process ensuring that any federal revenue offsets are included in the appropriate fund and report. In some instances, this may still require the County to file amendments to federal reports; however, they will be completed no later than eight weeks following the end of the quarter. Anticipated Completion Date: December 31, 2023

View Audit 43802 Questioned Costs: $1

Finding 44746 (2022-004)

Significant Deficiency 2022

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Reporting Significant Deficiency

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the ...

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 43800

Finding 44743 (2022-002)

Significant Deficiency 2022

Galveston Bay Foundation, Inc.

TX

Procurement, Suspension & Debarment Reporting Significant Deficiency

Finding #2022-002 ? Significant Deficiency and Other Noncompliance Recommendation: Develop policies and procedures to meet the contract reporting requirements. Planned corrective action: In 2023, Galveston Bay Foundation created a new Director of Program Operations position. This person will be...

Finding #2022-002 ? Significant Deficiency and Other Noncompliance Recommendation: Develop policies and procedures to meet the contract reporting requirements. Planned corrective action: In 2023, Galveston Bay Foundation created a new Director of Program Operations position. This person will be responsible for the oversight of grant reporting in addition to the oversight of program operations. The Director of Program Operations will maintain a spreadsheet of all grant reporting requirements with applicable due dates. Although each grant program manager is responsible for submission of program and financial reporting related to their grant, the Director of Program Operations will work closely with each grant program manager to ensure reports due were submitted timely as required by the individual grant contract. Responsible officer: Robert Stokes, President and CEO Estimated completion date: Immediately

View Audit 40559

Finding 44738 (2022-001)

None 2022

Universidad Central Del Caribe, Inc.

PR

Student Financial Aid Eligibility Reporting

The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the follo...

The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs will also attend to facilitate thediscussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent totwo consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letter to the faculty from the Office of the Dean of Academic Affairs to highlight the importance to promptly refer any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status. n addition to the above-mentioned procedures the following measures will be taken: 1. Late reporting of graduation dates in NSLDS and effective dates: a. Prior to graduation all academic program directors review the degrees to be conferred and certify candidates eligible for graduation b. The Registrar?s Office changes the status to graduate in the NSLDS Report after graduation date. c. To assure that all degrees are reported on time and accurately to the NSLDS system from now on, the Registrar?s Office, within ten days after graduation date, will process the changes in the NSLDS system. After the Registrar?s Office processes the changes in the NSLDS system, it will send to all program directors the list of all the students processed as graduated in the NSLDS system and they will be asked to double verify and attest accuracy of the lists of conferred degrees and asked to provide a certification within two days that the changes processed were accurate and that they agree with their record of students officially graduated during the last graduation date. This double certification of conferred degrees within the proposed time-frame will provide a second opportunity to add or delete any missing information within the NSLDS system increasing accuracy and timelines. d. A copy of the certification will be submitted to the Office of the Dean of Academic Affairs as evidence of the compliance with the new process established.

View Audit 39697

Finding 44725 (2022-002)

Material Weakness 2022

Parkview School District

WI

Material Weakness Reporting Internal Control / Segregation of Duties

Finding #2022-002- Material Adjustments (Prior Year Finding #2021-002) Condition: Johnson Block and Company, Inc. proposed multiple 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 acc...

Finding #2022-002- Material Adjustments (Prior Year Finding #2021-002) Condition: Johnson Block and Company, Inc. proposed multiple 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. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. 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 needed in order to report properly. 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 auditor Contact Person: Tracy Case Anticipated Completion: Not Applicable

View Audit 39098

Corrective Action Plans

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