Corrective Action Plans

Finding 528611 (2024-001)

Significant Deficiency 2024

MA

Subrecipient Monitoring Reporting Significant Deficiency

The City of Worcester, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the...

The City of Worcester, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Housing and Urban Development 2024-001 Community Development Block Grant - Assistance Listing Number 14.218 Recommendation: We recommend procedures be strengthened to ensure all required subaward reports are filed with FSRS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City of Worcester will strengthen its procedures to comply with the FSRS reporting requirements and ensure all subawards are appropriately reported in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Alexis Delgado, Assistant Budget Director – Grants Planned completion date for corrective action plan: April 30, 2025

View Audit 346595

Finding 528561 (2024-003)

Significant Deficiency 2024

Catholic Reflief Services - US Conference of Catholic Bishops

MD

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.309 § 200.403

3.1.Ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

View Audit 346571 Questioned Costs: $1

Finding 528559 (2024-002)

Significant Deficiency 2024

Catholic Reflief Services - US Conference of Catholic Bishops

MD

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.303 § 200.309 § 200.403

2.1 Ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

View Audit 346571

Finding 528520 (2024-001)

Significant Deficiency 2024

Logan University

MO

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding 2024-001 Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: May 2024 Corrective Action Plan: The funds for the affected student have been retur

View Audit 346554 Questioned Costs: $1

Finding 528512 (2024-001)

Significant Deficiency 2024

Gila Crossing Community School

AZ

Significant Deficiency

Finding Numbers: 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2025 Planned Corrective Action: Improvement from the prior year was made in this ar...

Finding Numbers: 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2025 Planned Corrective Action: Improvement from the prior year was made in this area and the Human Resources Manager has received additional training and is implementing new procedures and schedules to track the timing off renewing background checks in the future.

View Audit 346520

Finding 528511 (2024-001)

Significant Deficiency 2024

City of Meriden, Connecticut

CT

HUD Housing Programs Period of Performance Significant Deficiency

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2024 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2024-001 Period of Performance Description of Finding Community Development Block Grant – Entitlement (ALN 14.218) funds must be expended by the end of the eighth fi...

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2024 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2024-001 Period of Performance Description of Finding Community Development Block Grant – Entitlement (ALN 14.218) funds must be expended by the end of the eighth fiscal year after the fiscal year of appropriation the combined effect is to provide an expenditure period of eight fiscal years from the fiscal year of appropriation. For award B-17-MC-09-0007 (CDBG 2017), the eighth year after the year of appropriation ended on June 30, 2024. On this date, amount left unexpended after the end of the period of performance was $17,814. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action We recommend that the City review processes and controls related to timeliness of CDBG expenditures to ensure they comply with federal award requirements. Projected Completion Date June 30, 2025 Name of Contact Person Joseph Feest, Economic Development Director

View Audit 346513

Finding 528492 (2024-004)

Significant Deficiency 2024

Lyon College

AR

Significant Deficiency Matching / Level of Effort / Earmarking

Corrective Action: The Financial Aid Office notifies student of federal loan disbursements to their accounts, but was not aware that parent PLUS loan borrowers were required to be notified of PLUS loan disbursements. Beginning with the fall ’24 semester, the FAO has begun notifying PLUS loan borrowe...

Corrective Action: The Financial Aid Office notifies student of federal loan disbursements to their accounts, but was not aware that parent PLUS loan borrowers were required to be notified of PLUS loan disbursements. Beginning with the fall ’24 semester, the FAO has begun notifying PLUS loan borrowers of those disbursements to student accounts. Financial Aid is working with the internal IT department to assist with sending these notices in a timely manner. Proposed Completion Date: June 30, 2025

View Audit 346502

Finding 528491 (2024-003)

Significant Deficiency 2024

Lyon College

AR

Significant Deficiency

Corrective Action: We have used the last day of finals to be the last day in the payment period for any withdrawals in the 2024-2025 academic year. Proposed Completion Date: June 30, 2025

View Audit 346502

Finding 528490 (2024-002)

Significant Deficiency 2024

Lyon College

AR

Student Financial Aid Reporting Significant Deficiency

Corrective Action: The “Timely Reporting” issue resulted from a misunderstanding in the Registrar’s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office’s personnel and established procedures designed to prevent it from happening in ...

Corrective Action: The “Timely Reporting” issue resulted from a misunderstanding in the Registrar’s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office’s personnel and established procedures designed to prevent it from happening in the future. The “Funds Not Returned Timely” reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2025

View Audit 346502

Finding 528489 (2024-005)

Significant Deficiency 2024

Orange County, North Carolina

NC

HUD Housing Programs Subrecipient Monitoring Material Weakness

The 2023 FASS-PH report is now completed, and the 2024 FASS-PH is in progress of being completed. These reports have been added to our year-end checklist.  Include FASS-PH report to closing year-end reports schedule Financial reconciliations.  FASS-PH report preparation.  Management review & appr...

The 2023 FASS-PH report is now completed, and the 2024 FASS-PH is in progress of being completed. These reports have been added to our year-end checklist.  Include FASS-PH report to closing year-end reports schedule Financial reconciliations.  FASS-PH report preparation.  Management review & approval.  Assign responsible parties for each step in the process.  Conduct weekly check-ins during reporting periods to track progress. Name of contact person: Gary Donaldson 206

View Audit 346492

Finding 528486 (2024-003)

Significant Deficiency 2024

Community Food Bank of Eastern Oklahoma, INC

OK

Subrecipient Monitoring Cash Management Significant Deficiency

Item 2024-003 Delinquent Claim Filings Significant Deficiency Recommendation: Filing claims should be incorporated into the month-end close process. Management Views: Management agrees with the finding. Action Planned: Claim filing has been incorporated into the month-end closing process as of N...

Item 2024-003 Delinquent Claim Filings Significant Deficiency Recommendation: Filing claims should be incorporated into the month-end close process. Management Views: Management agrees with the finding. Action Planned: Claim filing has been incorporated into the month-end closing process as of November 2023. Anticipated Completion date: Complete Responsible Party: Karla Davis, Chief Financial Officer

View Audit 346489

Finding 528446 (2024-003)

Significant Deficiency 2024

Village of Spring Valley Housing Authority

NY

HUD Housing Programs Eligibility Significant Deficiency

Auditee’s Response and Planned Corrective Action The Authority has had staff and consultant turnover during the period under audit. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic has resulted in delaying or receiving no responses from tenants regarding obtaining...

Auditee’s Response and Planned Corrective Action The Authority has had staff and consultant turnover during the period under audit. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic has resulted in delaying or receiving no responses from tenants regarding obtaining the necessary documentation for eligibility requirements. The Authority has evidentiary documentation supporting their attempts to obtain the required documents from the tenants, such as certified letters, and courts suspension of evictions during the eviction process. Other documentation related to the moratorium that resulted from the COVID-19 pandemic, is available which includes evictions for nonpayment and noncompliance. The Authority has been working with legal counsel on these matters and continues to pursue this vigorously. The Authority has also hired new staff and consultants who has been diligently working to implement improvements. In most of the files the checklist cover pages were included but in some files reviewed the oversite cover page checklist was missing, however the required documentations were in place. A greater effort will be made immediately that all files will have completed the control check list cover pages in place with all appropriate signatures noted. Planned Implementation Date of Corrective Action: March 4, 2025 Person Responsible for Corrective Action: Keith Burrell, Executive Director

View Audit 346459

Finding 528443 (2024-004)

Significant Deficiency 2024

Garrett-Evangelical Theological Seminary

IL

Student Financial Aid Eligibility Reporting

Condition: Of the seven students selected for enrollment reporting testing, the Seminary did not properly update the student enrollment information for one student accurately or in a timely manner. Planned Corrective Action: The Seminary will update our institutional policies and definitions of the ...

Condition: Of the seven students selected for enrollment reporting testing, the Seminary did not properly update the student enrollment information for one student accurately or in a timely manner. Planned Corrective Action: The Seminary will update our institutional policies and definitions of the various types of enrollment status’s allowed to be reported to NSLDS to conform to the federal regulations. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 2/19/25

View Audit 346451

Finding 528442 (2024-003)

Significant Deficiency 2024

Garrett-Evangelical Theological Seminary

IL

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Condition: During our review of internal controls, it was noted that the Seminary does not have a policy or procedures in place, as required by the Code of Federal Regulations Planned Corrective Action: Garrett has implemented a written policy and procedure that complies with regulations. Contact pe...

Condition: During our review of internal controls, it was noted that the Seminary does not have a policy or procedures in place, as required by the Code of Federal Regulations Planned Corrective Action: Garrett has implemented a written policy and procedure that complies with regulations. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 2/13/25

View Audit 346451

Finding 528440 (2024-001)

Significant Deficiency 2024

Southwestern Michigan College

MI

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

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: The Financial Aid Office has taken immediate action to ensure that students are sent the appropriate loan disbursement notifications and is planning a longterm automat...

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: The Financial Aid Office has taken immediate action to ensure that students are sent the appropriate loan disbursement notifications and is planning a longterm automated solution. Southwestern Michigan College does not automatically package loans in a student's initial financial aid offer. This strategy was part of a default management plan developed in 2014. As a result, we manually process loan requests throughout the semester as students notify us that they wish to borrow, and complete the Entrance Counseling and Master Promissory Note requirements on studentaid.gov. We will now run the disbursement notification process each week throughout the entire semester to ensure timely notifications. We are also planning to implement a long-term automated solution. This would be a process in our ERP system and will run automatically using our scheduler software. The process will send an email notification to students as new loans are processed. A record of this notification will be retained in our ERP system. Contact person responsible for corrective action: Lauren Mow, Director of Financial Aid Anticipated Completion Date: Immediate corrective action taken with automation planned for Fall 2025.

View Audit 346439

Finding 528438 (2024-006)

Significant Deficiency 2024

New Mexico Highlands University

NM

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Auditor’s Recommendation: We recommend the University strengthen the controls in place to provide assurance that proper review occurs and retain documentation needed for an audit. Views of Responsible Officials and Planned Corrective Action: In regards to the Stipends sample, the University cannot d...

Auditor’s Recommendation: We recommend the University strengthen the controls in place to provide assurance that proper review occurs and retain documentation needed for an audit. Views of Responsible Officials and Planned Corrective Action: In regards to the Stipends sample, the University cannot determine the accuracy of the audit without seeing the sample materials with the deficiencies. Our corrective action at this time is as follows: We will evaluate our current process and look for a breakdown in the process. We will then revise the process and policy accordingly. In all cases, ORSP will review for compliance and we will monitor the processes for potential deficiencies throughout FY25. Timeline and Estimated Completion Date: June 30, 2025 Responsible Party: Office of Research and Sponsored Projects and Grant Principal Investigators.

View Audit 346437

Finding 528364 (2024-010)

Significant Deficiency 2024

Penasco Independent School District

NM

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Significant Deficiency § 200.430

Recommendation We recommend that for hourly employees, both the employee and the supervisor sign the timecard, either manually or electronically, to provide evidence that the employee takes responsibility for the hours worked and the supervisor can attest to the hours worked. Management Response Co...

Recommendation We recommend that for hourly employees, both the employee and the supervisor sign the timecard, either manually or electronically, to provide evidence that the employee takes responsibility for the hours worked and the supervisor can attest to the hours worked. Management Response Corrective Action: The District has actively been working with staff and management to review and sign their timesheets before processing payroll. Due Date of Completion: June 30, 2025 Responsible Party(ies): Business Manager

View Audit 346420

Finding 528363 (2024-009)

Significant Deficiency 2024

Penasco Independent School District

NM

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Recommendation We recommend that the District follow the guidance in NM PED's PSAB Supplement 13, Purchasing. Management Response Corrective Action: A purchasing policy is being developed by the district so the staff can have a clear understanding of the expectations regarding the purchasing proces...

Recommendation We recommend that the District follow the guidance in NM PED's PSAB Supplement 13, Purchasing. Management Response Corrective Action: A purchasing policy is being developed by the district so the staff can have a clear understanding of the expectations regarding the purchasing process. The District will work with employees to follow the policy and obtain purchase orders before receiving items and/or placing orders. Due Date of Completion: June 30, 2025 Responsible Party(ies): Business Manager

View Audit 346420

Finding 528358 (2024-001)

Significant Deficiency 2024

Southwest Wisconsin Technical College

WI

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Education The Southwest Wisconsin Technical College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 to June 30, 2024 The findings from the schedule of findings and questioned costs are discussed b...

U.S. Department of Education The Southwest Wisconsin Technical College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 to June 30, 2024 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 Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-001 Student Financial Assistance Cluster – Assistance Listing No. 84.063 and 84.268 Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Work with Student Information System (SIS) vendor to correct issues in the report used to submit Clearinghouse reports. This is a priority issue and has been escalated to the highest level and is under progress. 2. Created a report in SIS to identify student status errors to be corrected. 3. Submit enrollment reports more frequently. Name(s) of the contact person(s) responsible for corrective action: Kelly Kelly, Controller Planned completion date for corrective action plan: June 30, 2025 *** If the U.S. Department of Education has questions regarding this plan, please call Kelly Kelly, Controller, at (608) 822-2305.

View Audit 346400

Finding 528331 (2024-001)

Significant Deficiency 2024

Panhandle Public Health District

NE

Reporting Internal Control / Segregation of Duties Significant Deficiency § 200.512

Panhandle Public Health District engaged with a firm demonstrating the capacity to perform PPHD's audit in time for the required submission deadline to the Federal Audit Clearing House. PPHD engaged HBE LLP from Lincoln, NE to conduct audits of Fiscal Year 2024, 2025, and 2026. Subsequent engagement...

Panhandle Public Health District engaged with a firm demonstrating the capacity to perform PPHD's audit in time for the required submission deadline to the Federal Audit Clearing House. PPHD engaged HBE LLP from Lincoln, NE to conduct audits of Fiscal Year 2024, 2025, and 2026. Subsequent engagement planning will prioritize timely repo11ing.

View Audit 346374

Finding 528301 (2024-001)

Significant Deficiency 2024

Miles College

AL

Student Financial Aid Reporting Subrecipient Monitoring

Finding 2024-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Supplemental Opp...

Finding 2024-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2024; Teachers Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Instances of noncompliance were noted as more fully described in the context below. Questioned Costs – $0 Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: (a) Six (6) out of 6 students tested for withdrawals and the return of Title IV funds were completed using the incorrect semester dates. 34 CFR 668.22. (b) Three (3) out of 3 students tested for Enrollment Reporting had untimely reporting. 34 CFR 685.309(b), 34 CFR 682.610(c), 34 CFR 674.33(j). (c) We noted postings for the Fall and Spring awards in Direct Loans and Pell were posted to student accounts after the payment period and fiscal year ended June 30, 2024. Cause – Oversight by responsible employees of properly monitoring regulatory requirements. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. View of Responsible Officials – (a) All six students have been recalculated with the correct date. The issue originated from implementing the Colleague (ERP) system. The College has now established a procedure to ensure this process is reviewed during the RT24 calculation. (b) The College has hired a financial professional with experience in the Colleague (ERP) system. This professional has provided staff training and established standard operating procedures to promote better operating efficiency and effectiveness. (c) The issue resulted from implementing the Colleague (ERP) system. Standard Operating Procedures have been developed, and the financial aid staff has been trained to help prevent these types of issues in the future.

View Audit 346360

Finding 528296 (2024-001)

Significant Deficiency 2024

National Health Care for the Homeless Council, Inc.

TN

Period of Performance Reporting Significant Deficiency

Corrective Action: More than one person has been given access to the portal to upload financial reports in case of turnover or other unforeseen circumstances. Person Responsible: Melinda Graham, Director of Finance Timing for Implementation: Effective October 1, 2024

View Audit 346341

Finding 528203 (2024-001)

Significant Deficiency 2024

Glendale Union High School District No. 205

AZ

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

Annual Reporting for ESSER ‐ District Annual Report for ESSER FTE was keyed incorrectly 1. District will assign Business Manager and CFO to verify and review reports prior to submission.

View Audit 346267

Finding 528190 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Brownsville

TX

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers program. Leticia Gonzalez, Director of Client Services, will be respo...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers program. Leticia Gonzalez, Director of Client Services, will be responsible to implement this corrective action by June 30, 2025.

View Audit 346245 Questioned Costs: $1

Finding 528184 (2024-001)

Significant Deficiency 2024

Workforce Investment Council of Clackamas County Dba Clackamas Workfor

OR

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Condition: While performing audit procedures over payroll disbursements, we identified three separate instances where the allocation of an employee’s hours by grant in the monthly timesheet distribution spreadsheet was not consistent with the actual time charged to the respective grants as reflected...

Condition: While performing audit procedures over payroll disbursements, we identified three separate instances where the allocation of an employee’s hours by grant in the monthly timesheet distribution spreadsheet was not consistent with the actual time charged to the respective grants as reflected in the employee’s approved timesheet for the pay period. As a result, the payroll allocation journal entries recorded for those months was not consistent with the actual work performed for each grant. Cause of Condition: Internal controls in place are not adequately designed and implemented to ensure payroll allocation journal entries are determined based on actual hours worked on the employees’ timesheets for the respective pay periods. Corrective Plan: CWP will separate duties. The error occurred at the beginning of the payroll process while entering hours from the timesheets. The Executive Assistant will enter hours from the timesheets into the distribution spreadsheet. The Fiscal Manager will review and signoff the data entered. Implementation Date: February 1, 2025 Responsible Staff: Laura Kropf, Fiscal Manager

View Audit 346243

Corrective Action Plans

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