Corrective Action Plans

Finding 519475 (2024-002)

Significant Deficiency 2024

Housing Authority of the County of Contra Costa

CA

Questioned Costs HUD Housing Programs Eligibility

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - E. ...

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority's files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 9,051 units. Of a sample size of eighty-nine (89) tenant files, the following was noted: • HUD-9886 Authorization for Release of lnformation was missing in 4 files Our sample size is statistically valid. Known Questioned Costs: $24,363 Cause: There is significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: Of the Eighty Nine (89) tenant files audited, four (4) tenant files contained a deficiency in the same indicator---the Authorization for the Release of lnformation/ Privacy Act Notice (HUD Form 9886) retained in the tenant file was executed after the audit date range, not within the audit period (4/1/23- 3/31/24) or within the three months prior. The HACCC discovered two contributing factors for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. First, the HACCC's Housing Choice Voucher program entered into a partnership with Paul Edwards Management and Consulting (PEM) on May 1st 2024. This partnership provides the HACCC's Housing Choice Voucher program with technical assistance and coverage of vacant positions within the Housing Choice Voucher program Continued Eligibility team. The PEM team members assigned to Continued Eligibility are responsible for completing timely Annual Recertifications for all assigned Housing Choice Voucher program participants---including the collection of any signature documents required by HUD annually. To ensure compliance with this requirement, contract performance indicators related to those positions temporarily assigned to PEM (including the timeliness of Annual Recertifications and a consolidated report of findings within the Electronic File Protocol Quality Control Audit Checklists) will be included in a corrective action plan. The enhanced monitoring provided by the corrective action plan will a) ensure the continued collection of the performance indicator data and b) provide timely feedback regarding the partnerships ability to mediate the deficiency. Second, HUD removed the expiration date from the 9886 form. Effective 01/01/2024, HUD requires Housing Authorities to collect a signature on the 9886 form once throughout the course of participation instead of requiring Housing Authorities to collect a signature on the form annually (or every 15 months). HUD issued PIH Notice 2023-27 on 09/29/2023. The notice indicated "In accordance with the final rule, all applicants must sign the consent form at admission, and participants must sign the consent form no later than their next interim or regularly scheduled income reexamination. After an applicant or participant has signed and submitted a consent form either on or after January 1, 2024 (regardless of the PHA/MFH Owner's compliance date), they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination ... ". The HACCC' s Housing Choice Voucher program began to request tenant signatures on the updated 9886 form effective 1/1/2024 (within our online recertification workflows) and effective 3/29/24 (within our paper recertification packets). Internal procedures for the storage of electronic documents ("HACCC Electronic File Protocol") related to the 9886 form were updated in accordance with the change, to in effect, retain the 9886 document as any other "vital document" or one-time verification would be stored and retained (ex. birth certificate, social security card, etc)--- storing and retaining only the most recent version of the document. The HACCC agrees that the requirement to retain a 9886 executed within the audit date range for these 4 files was not fulfilled despite the above-mentioned updates taking place within the audit date range. To ensure compliance with this requirement, Electronic File Protocol QC Checklist Procedure Training will be included in a corrective action plan. The training requirement will a) ensure the continued collection and review of the Electronic File Protocol Quality Control reports and b) provide timely feedback regarding whether having a single retention requirement applied throughout an entire fiscal year will effectively mediate this deficiency. We agree with the Auditor's observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

View Audit 338426 Questioned Costs: $1

Finding 519474 (2024-001)

Significant Deficiency 2024

Housing Authority of the County of Contra Costa

CA

Questioned Costs HUD Housing Programs Significant Deficiency

Finding 2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - N. S...

Finding 2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority's files and on discussions with management, the Authority did not properly abate one (1) out of thirty-seven (37) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of thirty-seven (37) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Our sample size is statistically valid. Known Questioned Costs: $398 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA). Effect: The Housing Voucher Cluster is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views ofresponsible officials and planned corrective action: Of the Thirty-Seven (37) tenant files audited, one (1) tenant file contained a deficiency--- the file did not contain adequate verification of the abatement cure request date justifying the HACCC's subsequent cancellation of this abatement after the deficiencies were verified as corrected. The HACCC discovered a contributing factor for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. HUD requires HACCC's Housing Choice Voucher program to abate (permanently withhold) housing assistance payments no later than the first of the month following the specified correction period (including any approved extension) when HQS deficiencies are discovered during biennial HQS inspections of subsidized units. To improve housing opportunities to families with vouchers and support landlord retention on our programs, the HACCC (in accordance with applicable regulations) offers to end the period of HAP abatement "effective on the earlier of the day the unit passes inspection or the date the correction was reported completed' as a courtesy. In this case, the unit failed inspection for non-life threatening deficiencies (ex. overgrown grass) on 6/20/2023. The deficiencies were not corrected prior to the reinspection which took place on 7/18/2023, prompting the placement of a HAP abatement on 7/26/2023 to withhold all HAP payments effective 8/1/2023 on. A reinspection was requested and the unit passed inspection in August. On 8/31/23 the abatement was subsequently cancelled in the HACCC's software and a memo was entered indicating that the landlord had requested the abatement cure reinspection prior to the abatement effective date of 8/1/23. However, it was discovered that the necessary verification of this abatement cure request was not attached to the tenant record. Due to the HACCC's inability to reproduce verification of the request date (being earlier than the day the unit passed inspection), the HACCC agrees with this finding. To ensure compliance with this requirement, the Internal HCV Inspection Procures will be updated to include systems for ensuring that necessary verification of any abatement cure request date is stored. A File Memo containing a timeline and necessary verification ofrequest date will be submitted to a manager for approval any time an abatement is ended or cancelled. The manager will be responsible for storing the executed File Memo and verification in the tenant file. The Authority has recognized the deficiencies in the Housing Voucher Cluster and has implemented internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

View Audit 338426 Questioned Costs: $1

Finding 519453 (2024-002)

Significant Deficiency 2024

Moberly Area Community College

MO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disburs...

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

View Audit 338400 Questioned Costs: $1

Finding 519451 (2024-001)

Significant Deficiency 2024

Moberly Area Community College

MO

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of t...

2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of the responsible official: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required – usually within 1-5 days from the date it is discovered. This finding of a “late return” is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college’s attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Registrar, Deans, and Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.

View Audit 338400

Finding 519421 (2024-001)

Significant Deficiency 2024

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Internal Control / Segregation of Duties Special Tests & Provisions HUD Housing Programs

Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Di...

Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Division Director Housing Stability will implement a rent reasonableness completion and review process. Responsible Individuals: Chief Program Officer Anticipated Completion Date: June 30, 2025

View Audit 338393

Finding 519406 (2024-001)

Significant Deficiency 2024

City of Westminster, Maryland

MD

Reporting Significant Deficiency Internal Control / Segregation of Duties

Staff turnover and vacancies during the fiscal year resulted in a few timesheets lacking supervisory approval. Additionally, the time sheet submission and approval process throughout the City is currently completed by paper or email. It is manual and cumbersome. To ensure time sheets are approved ti...

Staff turnover and vacancies during the fiscal year resulted in a few timesheets lacking supervisory approval. Additionally, the time sheet submission and approval process throughout the City is currently completed by paper or email. It is manual and cumbersome. To ensure time sheets are approved timely, the payroll coordinator will be auditing all timesheets every payroll and will follow up on those lacking approval to ensure they are approved and accurate. The City is also in the final stages of selecting new ERP software, which will be implemented during fiscal years 2026 and 2027. This new system will support electronic timesheets and approvals which will streamline the process and allow the payroll coordinator to audit the timesheets more efficiently.

View Audit 338355

Finding 519371 (2024-002)

Significant Deficiency 2024

San Bernardino Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The San Bernardino Community College District acknowledges and understands the recommendations associated with the Special Tests and Provisions – Enrollment Reporting audit finding. The District has examined the elements detailed by the finding and is committed to implementing appropriate controls t...

The San Bernardino Community College District acknowledges and understands the recommendations associated with the Special Tests and Provisions – Enrollment Reporting audit finding. The District has examined the elements detailed by the finding and is committed to implementing appropriate controls to prevent future non-compliance. The District will enhance current internal controls, develop and implement new supporting procedures and institute best practices as part of this corrective action. Actions to be taken include: the improved collaboration between District Support Services, the Financial Aid Office, and the Admission and Records Office to ensure accurate enrollment data reporting. District staff shall report to the Financial Aid Office immediately after each submission is completed to the National Clearinghouse. The Financial Aid Office shall utilize NSLDS reports to ensure all records are submitted and modified in a timely manner. Immediate action has taken place to address this deficiency, and collaborative efforts will continue to ensure compliance in this reporting area by the start of the Spring 2025 semester.

View Audit 338261

Finding 519366 (2024-001)

Significant Deficiency 2024

Cerritos Community College District

CA

Student Financial Aid Reporting Significant Deficiency

View of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure student enrollment information is updated and accurate on the NSLDS Access website.

View Audit 338254

Finding 519293 (2024-001)

Significant Deficiency 2024

Urban Minority Alcoholism and Drug Abuse Outreach Program of Lucas County, Inc.

OH

Reporting Significant Deficiency

2024-001 Inaccurate Report Submitted to the Funders Criteria: According to the terms of the funding agreements and applicable grant management guidelines, the Organization is required to submit accurate, complete, and timely financial and performance reports to funders. These reports must align with...

2024-001 Inaccurate Report Submitted to the Funders Criteria: According to the terms of the funding agreements and applicable grant management guidelines, the Organization is required to submit accurate, complete, and timely financial and performance reports to funders. These reports must align with the Organization's internal controls, including the data maintained in its program management system. Accuracy and consistency between internal data and reports submitted to funders are essential to ensure compliance with funding requirements and maintain transparency. Client Response: During the program, the designated compliance manager passed away. Moving forward, the organization will ensure that multiple people are trained to complete compliance obligations. Proposed Implementation Date – December 1, 2024 Name of Contact Person – John Edwards, Sr. Email:jledwards@umadaop.org Phone: 419-255-4444

View Audit 338059

Finding 519280 (2024-002)

Significant Deficiency 2024

Corona-Norco Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

The District has reviewed the ESEA requirements with other departments and have implemented trainings to ensure adequate documentation for all students removed from the cohort is maintained in the system.

View Audit 337991

Finding 519279 (2024-004)

Significant Deficiency 2024

North Wasco County Sd #21

OR

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Ensure Federal Programs are Complaint - All employees charged with federal program compliance have been instructed that private schools must receive equitable services

View Audit 337982

Finding 519276 (2024-002)

Significant Deficiency 2024

Page Unified School District No. 8

AZ

Procurement, Suspension & Debarment Special Tests & Provisions Reporting

2024-002 Davis-Bacon Act Compliance Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (O...

2024-002 Davis-Bacon Act Compliance Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $-0- Repeat Finding: This is not a repeat finding. Condition/Context: The District did not retain documentation sufficient to determine the Davis-Bacon compliance clause was included in advertised specifications for construction projects paid with federal Impact Aid monies. In addition, weekly certified payrolls were not collected and maintained for any relevant weeks during the fiscal year. Criteria: Department of Labor (DOL) 29 CFR part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction. Non-federal entities shall include in their federally funded construction contracts in excess of $2,000, that are subject to the Wage Rate Requirements of the Davis-Bacon Act, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the U.S. Department of Labor weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). This reporting is often done using Optional Form WH-347, which includes the required statement of compliance. Corrective Action: The District will implement monitoring procedures over the procurement process to ensure provisions of the Davis-Bacon Act are implemented into contracts and that certified payrolls are obtained, when necessary. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Lori Wilson, Business Manager

View Audit 337968

Finding 519273 (2024-003)

Significant Deficiency 2024

Page Unified School District No. 8

AZ

Questioned Costs Internal Control / Segregation of Duties Cash Management

2024-003 Reporting Federal Assistance Listing Number: 10.553, 10.555, and 10.559 Program: Child Nutrition Cluster Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Pass-Through Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: Ju...

2024-003 Reporting Federal Assistance Listing Number: 10.553, 10.555, and 10.559 Program: Child Nutrition Cluster Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Pass-Through Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $4,397.30 of underreported claims Repeat Finding: This is not a repeat finding. Condition/Context: The District did not properly calculate, and report meal claims accurately for three of 4 months selected during the current year. This led to the District under-reporting $4,397.30 in student meal claims. Criteria: The Uniform Guidance compliance supplement. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines. Child Nutrition Program claim forms should be supported by documentation showing the number of meals for which reimbursement was requested and document that the meals were served prior to the date of the reimbursement request. The claim reports should be filed on a timely basis. Corrective Action: The District will implement review procedures as part of the meal claim process to ensure claims reported match with District records. The District will ensure any over/under reporting is investigated and resolved in a timely manner. The District will review reports from FY24 and ensure any unclaimed meals are properly reconciled, as applicable. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Lori Wilson, Business Manager

View Audit 337968 Questioned Costs: $1

Finding 519263 (2024-002)

Significant Deficiency 2024

Rowan County, North Carolina

NC

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges three instances where an employee’s file did not include a signed confidentiality document.A new orientation process has been implemented in which all new staff receive and review t...

Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges three instances where an employee’s file did not include a signed confidentiality document.A new orientation process has been implemented in which all new staff receive and review the agency’s confidentiality agreement, which is reviewed and signed with employee supervisor.The IT Security Office receives a list of new staff and follows up after orientation to collect and store the confidentiality agreement. Confidentiality training will continue to be provided on an annual basis for both the ESD and SWS divisions. The next annual training for both ESD and SWS will be completed in January 2025.

View Audit 337930

Finding 519239 (2024-003)

Significant Deficiency 2024

Elko County School District

NV

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Fed Agency Name: US Department of Agriculture Program Name: Impact Aid CFDA #: 84.041 Finding Summary: Impact aid annual application did not have evidence of the reporting figures used at the time of submission of the report. Corrective Action Plan: The District will set up a system to store ...

Fed Agency Name: US Department of Agriculture Program Name: Impact Aid CFDA #: 84.041 Finding Summary: Impact aid annual application did not have evidence of the reporting figures used at the time of submission of the report. Corrective Action Plan: The District will set up a system to store and track the necessary records for reporting, ensuring they are available for future audits. Responsible Individual: Cassandra Stahlke Chief Financial Officer Anticipated Completion Date: June 30, 2025

View Audit 337882

Finding 519237 (2024-001)

Significant Deficiency 2024

Rialto Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

The District has revised its drop protocol documentation to provide a clearer, more streamlined process for staff, ensuring all required documentation is collected before processing drop codes in CALPADS. Additionally, comprehensive training has been provided to all staff responsible for this task t...

The District has revised its drop protocol documentation to provide a clearer, more streamlined process for staff, ensuring all required documentation is collected before processing drop codes in CALPADS. Additionally, comprehensive training has been provided to all staff responsible for this task to support accurate and efficient implementation.

View Audit 337878

Finding 519213 (2024-001)

Significant Deficiency 2024

South San Francisco Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

The District will be updating its process and procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and the data accurately inputted into the CALPADS system. Our Director who oversees CALPADS will be responsible for ensuring training is prov...

The District will be updating its process and procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and the data accurately inputted into the CALPADS system. Our Director who oversees CALPADS will be responsible for ensuring training is provided to staff responsible for this task.

View Audit 337865

Finding 519209 (2024-002)

Significant Deficiency 2024

Grayson College

TX

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring § 200.303

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Cle...

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Clearinghouse (NSC). Once enrollment is validated and certified, it is reported directly to the National Student Loan Data System (NSLDS). Grayson College does not report enrollment directly in NSLDS. The OFA requests a copy of the validated and certified NSC enrollment report from the Admissions and Records Office to double check accuracy by performing a random selection of students to confirm they have been reported correctly in NSLDS. If, for some reason, a student’s enrollment is not correct in NSLDS, the OFA contacts NSC to get an understanding as to why it is not reported correctly to NSLDS. This happens after each validated and certified cycle, including all module terms (8-week and mini-mester). The College is investigating how to conduct a batch validation, which will be more robust than the sampling method. GC Financial Aid staff have received additional training and understand the importance of V4 and V5 verification coupled with accurate reporting to the NSLDS. They are committed to making sure these actions as stated occur each semester. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025

View Audit 337828

Finding 519205 (2024-001)

Significant Deficiency 2024

Grayson College

TX

Special Tests & Provisions Subrecipient Monitoring Reporting

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special Tests and Provisions - Verification Corrective Action Plan: The Office of Financial Aid (OFA) has begun to monitor students that are selected for V4 and V5 verification by t...

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special Tests and Provisions - Verification Corrective Action Plan: The Office of Financial Aid (OFA) has begun to monitor students that are selected for V4 and V5 verification by the U.S. Department of Education. Once available on FSA Partner Portal, the OFA reports any students that have or have not submitted necessary paperwork to finalize verification. After initial reporting, the OFA continues to monitor and report new V4 & V5 students within the 60-day timeframe requirement. Once students fulfill the verification request, the OFA updates the Verification of Identity portal as applicable. As of December 2, 2024, the Verification of Identity portal is not available for either 2024-25 or 2025-26 reporting for any Institution of Higher Education. At this time, it is unknown when the portal for reporting will be available. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025

View Audit 337828

Finding 519187 (2024-001)

Significant Deficiency 2024

Southwestern Illinois College Community College District #522

IL

Subrecipient Monitoring Reporting Significant Deficiency § 200.303 § 200.328

2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timel...

2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine communication between program directors and accounting staff will include discussion of reporting timeline in order to ensure timely submission. The Finance Department will review and approve required reports that are prepared by grant program directors. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: February 28, 2025.

View Audit 337794

Finding 519181 (2024-002)

Significant Deficiency 2024

Southwestern Illinois College Community College District #522

IL

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Expla...

2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The records identified with incorrect R2T4 calculations have been recalculated, reported to COD and funds returned. In order to best ensure policies and procedures for R2T4 calculations, additional staff have been trained to ensure calculations are checked and double checked to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson, Director of Financial Aid, Veteran Services & Student Employment Planned completion date for corrective action plan: All corrections have been submitted as of October 9, 2024. Training of additional staff in progress – to be completed by February 28, 2025.

View Audit 337794

Finding 519163 (2024-001)

Significant Deficiency 2024

Eugenio Maria De Hostos Charter School

PA

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

Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a...

Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a preliminary award for the following school year  In the first week of July, Grant Coordinator submits consolidated application with grant budget o Grant Budget (eGrants) prepared by Grant Coordinator needs to match with school-wide plan (FRCPP) by Principals o Grant coordinator will request salaries and benefits information from Payroll Director and vendor information based on plans o THe positions listed in the plan and budget need to meet twice a year. The school principals need to document it. The Grant Coordinator will communicate it. o Grant Coordinator needs to provide the award letter and the consolidated application/agreement to the Accounting Department as soon as it’s approved.  In July, Senior Accountant needs to accrue the revenues based on the preliminary allocation o The Senior Accountant needs to update the AR workpaper to reflect the allocation.  Starting in January during the school year, the Senior Accountant needs to file the quarterly cash on hand report (three reports) based on estimated expenses. The report is due by the 10th of the month following the conclusion of each quarter. o When grant expenses need to be reconciled and reclassified between Grant Coordinator and Accounting Supervisor monthly. The Accounting Supervisor sets up the recurring calendar invite. o Accounting Supervisor needs to review and confirm o The Accounting Supervisor sets up a calendar reminder for the Senior Accountant to prepare the quarterly cash on hand report and another one for the due date.  In January, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from July (or whenever the grant period starts) to December  In February, PDE issues the revised allocation. The Grant Coordinator needs to forward those revised award letters to the Accounting Department as soon as they’re received.  In March, Senior Accountant needs to reconcile and accrue revenues based on revised allocation. If needed, a retroactive adjustment is made for year to date revenues o Senior Accountant needs to update AR work paper to reflect the revised allocation  By April, Grant Coordinator needs to submit the revised application along with the budget to match the school wide plan o The Grant Coordinator needs to send a copy of the revised consolidated agreement to the accounting department as soon as they’re approved.  In July, Grant Coordinator needs to compile the expenses for final expenditure report (FER) and submit the reports o A copy of the FER needs to be provided to the accounting department.  In July, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from January to June  In August, the AR workpaper needs to reconciled to be audit ready in both cash receipts and revenue accrual

View Audit 337715

Finding 519157 (2024-001)

Significant Deficiency 2024

Antonia Pantoja Community Charter School

PA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a...

Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a preliminary award for the following school year  In the first week of July, Grant Coordinator submits consolidated application with grant budget o Grant Budget (eGrants) prepared by Grant Coordinator needs to match with school-wide plan (FRCPP) by Principals o Grant coordinator will request salaries and benefits information from Payroll Director and vendor information based on plans o THe positions listed in the plan and budget need to meet twice a year. The school principals need to document it. The Grant Coordinator will communicate it. o Grant Coordinator needs to provide the award letter and the consolidated application/agreement to the Accounting Department as soon as it’s approved.  In July, Senior Accountant needs to accrue the revenues based on the preliminary allocation o The Senior Accountant needs to update the AR workpaper to reflect the allocation.  Starting in January during the school year, the Senior Accountant needs to file the quarterly cash on hand report (three reports) based on estimated expenses. The report is due by the 10th of the month following the conclusion of each quarter. o When grant expenses need to be reconciled and reclassified between Grant Coordinator and Accounting Supervisor monthly. The Accounting Supervisor sets up the recurring calendar invite. o Accounting Supervisor needs to review and confirm o The Accounting Supervisor sets up a calendar reminder for the Senior Accountant to prepare the quarterly cash on hand report and another one for the due date.  In January, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from July (or whenever the grant period starts) to December  In February, PDE issues the revised allocation. The Grant Coordinator needs to forward those revised award letters to the Accounting Department as soon as they’re received.  In March, Senior Accountant needs to reconcile and accrue revenues based on revised allocation. If needed, a retroactive adjustment is made for year to date revenues o Senior Accountant needs to update AR work paper to reflect the revised allocation  By April, Grant Coordinator needs to submit the revised application along with the budget to match the school wide plan o The Grant Coordinator needs to send a copy of the revised consolidated agreement to the accounting department as soon as they’re approved.  In July, Grant Coordinator needs to compile the expenses for final expenditure report (FER) and submit the reports o A copy of the FER needs to be provided to the accounting department.  In July, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from January to June  In August, the AR workpaper needs to reconciled to be audit ready in both cash receipts and revenue accrual

View Audit 337713

Finding 519114 (2024-002)

Significant Deficiency 2024

City of Detroit, Michigan

MI

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

Federal Program, Assistance Listing Number and Name - ALN 97.036, Department of Homeland Security, Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Condition: Original Finding Description - The FEMA grant expenses are charged to various funds in the general ledger over...

Federal Program, Assistance Listing Number and Name - ALN 97.036, Department of Homeland Security, Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Condition: Original Finding Description - The FEMA grant expenses are charged to various funds in the general ledger over several years but is managed and tracked by project in a manual spreadsheet which agrees to the amount of expenses reported on the fiscal year 2024 Schedule of Expenditures of Federal Awards (SEFA). FEMA expenditures are reported on the SEFA when there is an award and expenditures. Given that the award is made subsequent to the expenditures being incurred a manual spreadsheet is used to track expenditures being charged to the grant. There were instances of duplicated costs in the manual spreadsheet. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Istakur Rahman; Anticipated completion date: June 2025 Planned Corrective Action - The identified duplicate cost was an isolated occurrence caused by an oversight during the spreadsheet preparation process. While existing controls are in place, management will perform a secondary review of the end-to-end process to enhance these controls.

View Audit 337640

Finding 519103 (2024-001)

Significant Deficiency 2024

Rim of the World Unified School District

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

The District has implemented a secondary review of ESSER reports prior to final submission.

View Audit 337594

Corrective Action Plans

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