Corrective Action Plans

Finding 390407 (2023-002)

Significant Deficiency 2023

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: ...

Finding Number: 2023‐002, 2022‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Julia Donald, Principal / Faron Logan, Business Manager / Jeremy Simpson, Support Service Director Anticipated Completion Date: April 30, 2024 Planned Corrective Action: Business Manager did get clarification from auditors and BIE around prevailing wage rates documentation. Projects completed did not have sufficient documentation showing wage rates and Business Manager now knows exactly what kind of documentation is needed to justify wage rates. BIE has assisted the Business Manager in where to get current wage rates on Sam.gov. All construction projects moving forward will have correct documentation for wage rates.

View Audit 301207

Finding 390406 (2023-003)

Significant Deficiency 2023

Hunters Point Boarding School, Inc.

AZ

Reporting Significant Deficiency Program Income

Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Busines...

Finding Number: 2023‐003, 2022‐003, 2021‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager Anticipated Completion Date: March 31, 2024 Planned Corrective Action: Since April 2023 the Business Manager has corrected the dates for the SF‐425 reporting. SF‐425 reports are turned in on time and all current SF‐425 reports have correct dates.

View Audit 301207

Finding 390305 (2023-002)

Significant Deficiency 2023

Memphis Housing Authority

TN

HUD Housing Programs Significant Deficiency Special Tests & Provisions

March 29, 2024 U.S. Department of Housing and Urban Development The Memphis Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2023. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit peri...

March 29, 2024 U.S. Department of Housing and Urban Development The Memphis Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2023. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit period: July 1, 2022 - June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARDS 2023-002 Special Tests and Provisions - Waiting List Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of 40 applicants that were selected from the waiting list for testing, 14 lacked documentation to show their current status and whether they were given the opportunity to be housed. In addition, there were difficulties obtaining any historical waiting lists for the Public Housing properties. Auditor’s Recommendations: The Authority should implement archiving procedures for its historical waiting lists on a routine basis. In addition, the Authority should document for proper auditing purposes, those given the opportunity to be housed from the waiting list and their current status. The Authority should provide proper training for all staff at the properties to ensure procedures and policies are being followed consistently across all of the Authority’s Public Housing properties. Action Taken: • MHA will ensure we have a saved copy of all public housing site-based waiting lists. LaTonia Young, Director of Asset Management, will save copies of the waiting list for all Public Housing sites on a monthly basis effective March 28, 2024. Tomecia Brown, Director of Compliance and Training will ensure that all site staff are trained on how to pull from the waiting list during the monthly site staff meeting effective April 23, 2024.

View Audit 301166

Finding 390304 (2023-001)

Significant Deficiency 2023

Memphis Housing Authority

TN

HUD Housing Programs Eligibility Significant Deficiency

2023-001 Eligibility Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of an approximate population of 2,083 tenants, 44 tenant files were tested and the following def...

2023-001 Eligibility Public and Indian Housing Program - AL No. 14.850 Significant deficiency in internal control Other matter required to be reported in accordance with Uniform Guidance Condition: Out of an approximate population of 2,083 tenants, 44 tenant files were tested and the following deficiencies were noted: • 1 file was missing the support packet for the fiscal year 2023 recertification including but not limited to income support, third party verification, and flat rent sheet, • 3 files had late recertifications, • 2 files were missing support of inspection, • 1 file was missing tenant wage support, and • 1 file was missing a valid 9886 form. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: • 1 file was missing the support packet for the fiscal year 2023 recertification LaTonia Young, Director of Asset Management, lyoung@memphisha.org, 901-544-1129, is working with the new Community Manager to make the corrections for the missing information no later than April 30, 2024. Going forward Tomecia Brown, Director of Compliance and Training, tbrown1@memhisha.org, 901-544-6402, will continue to conduct file reviews to ensure that the required documentation is in the file. •3 files had late recertifications. We will ensure that all recertifications are completed within 30 – 120 days of the effective date. Tomecia Brown, Director of Compliance and Training, will complete a recertification due review on a monthly basis effective April 1, 2024. • 2 file was missing support of inspection. LaTonia Young, Director of Asset Management, will ensure that all units are inspected on an annual basis. In our monthly site staff meeting, Asset Management will inform staff to ensure that all inspections are in the file. • 1 file was missing tenant wage support. We will have the new Community Manager verify wages and make corrections by April 5, 2024. MHA will be sending the owner a non-compliance letter no later than April 30, 2024. Tomecia Brown, Director of Compliance and Training, will continue to complete file reviews on a monthly basis and train staff on the Public Housing process. • 1 file was missing a valid 9886 form. Tomecia Brown, Director of Compliance and Training, will continue to conduct file reviews to ensure that the HUD 9886 form is in the file for all Public Housing sites effective April 23, 2024.

View Audit 301166

Finding 390280 (2023-007)

Material Weakness 2023

Commonspirit Health

IL

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

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Find...

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 3 of 30 students selected for disbursement testing for direct loans within 30 days of funds being disbursed. CHI Health School of Radiologic Technology did not send loan notifications to 14 of 14 students for disbursement testing with direct loans within 30 days of funds being disbursed. Corrective Action Plan: This finding has been corrected for Good Samaritan. As of May 2023, for April 2023 loan disbursements, compliance is verified monthly through internal audit of student disbursements. A sample of disbursements is checked for proper and timely notifications. Timeliness of notifications is checked and verified by the Compliance Oversight Committee monthly. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator CHI Health School of Radiologic Technology Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390276 (2023-010)

Significant Deficiency 2023

Commonspirit Health

IL

Special Tests & Provisions Eligibility Reporting § 200.303

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Tech...

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science and CHI Health School of Radiologic Technology did not have internal controls over enrollment reporting. Corrective Action Plan: This finding has been corrected for Good Samaritan as of April 2023. Enrollment reporting to the National Student Clearinghouse is conducted 5 times per year and reconciled monthly with loan borrowers to ensure active enrollment. Additional Status Update: The Dean of Enrollment Management validates and reports to the oversight committee regarding the monthly reporting. Monthly reporting to the GSC Compliance committee has verified completion since May 2023 and has been timely thereafter. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator, CHI Health School of Radiologic Technology Expected Completion: April 2023 (Good Samaritan) and June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390236 (2023-003)

Significant Deficiency 2023

National University

CA

Procurement, Suspension & Debarment Eligibility Significant Deficiency

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assuran...

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assurance team will oversee a weekly review of the cost of attendance to ensure financial aid packages align with approved budgets, enabling early identification of discrepancies for prompt correction. Based on these reviews, individual and group coaching will be implemented to address areas of concern. A refresher training and updated tools and guidance will be completed to reinforce best practices and align with institutional policy and procedure for calculating the cost of attendance. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390231 (2023-003)

Significant Deficiency 2023

Rider University

NJ

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanat...

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Recognizing the importance of resolving this finding the University intends to adjust policies and procedures around reviewing the third-party servicer processes around regulations and compliance items therein. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/26/2024

View Audit 301124

Finding 390230 (2023-002)

Significant Deficiency 2023

Rider University

NJ

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

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: T...

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: In addition to the University’s automated procedures, Financial Aid and the Registrar will reconcile the finalized listing of graduates for each semester to confirm that all students are receiving exit counseling requirements and ensure proper counseling is provided to students. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/19/2024

View Audit 301124

Finding 390228 (2023-001)

Significant Deficiency 2023

Rider University

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the ...

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Registrar's Office can confirm the National Student Clearing House (NSC) enrollment history for all two students is accurate. It appears that there have been challenges with the National Student Loan Data System (NSLDS) receiving current data from NSC in a timely manner. We take action to ensure that we will work with Financial Aid and crossreference the Registrar's monthly submission report and/or weekly Withdrawal Report with an NSLDS' report provided by Financial Aid to address any discrepancies. We will also work with the NSC audit team to ensure if there are any other processes, that we can implement on our end to better oversee the submission with our third-party servicer (NSC). Name(s) of the contact person(s) responsible for corrective action: Justina Nicita, Assistant Registrar, and Miranda Cole, Director of Financial Aid. Planned completion date for a corrective action plan: 3/19/2024.

View Audit 301124

Finding 390227 (2023-003)

Significant Deficiency 2023

Do Good Multnomah

OR

Reporting Significant Deficiency Internal Control / Segregation of Duties

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that invoices can be prepared by someone other than the approver. In the immediate interim, invoices will be reviewed and signed by the CEO before submission by th...

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that invoices can be prepared by someone other than the approver. In the immediate interim, invoices will be reviewed and signed by the CEO before submission by the CFO.

View Audit 301123

Finding 390226 (2023-002)

Significant Deficiency 2023

Do Good Multnomah

OR

Allowable Costs / Cost Principles Cash Management Reporting

We have implemented additional levels of approval and oversight for point-of-sale and invoice spending to ensure that receipts are captured and retained correctly, and that at invoices are reviewed and approved before payment. We have also provided additional training for spenders on best practices ...

We have implemented additional levels of approval and oversight for point-of-sale and invoice spending to ensure that receipts are captured and retained correctly, and that at invoices are reviewed and approved before payment. We have also provided additional training for spenders on best practices of recording and maintaining records. We have since also consolidated our supply chain so that spenders are able to procure most supplies through one vendor, which will have reporting and tracking capabilities. We will also be making significant changes to how mileage reimbursement is documented and approved.

View Audit 301123

Finding 390216 (2023-003)

Significant Deficiency 2023

Enlace Chicago

IL

Reporting Significant Deficiency

Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There ...

Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago is committed to timely completion of report submissions. Enlace Chicago has continued to review and approve reports prior to submission as required by the state agency. We will continue to put forth best efforts to take a step further and document preparation and review on the report form to satisfy the internal process requirement. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Finance Planned completion date for corrective action plan: June 30, 2024.

View Audit 301111

Finding 390197 (2023-004)

None 2023

College Dreams, INC

OR

Reporting Significant Deficiency

Finding # 2023-004: Significant deficiency over preparation of schedule of expenditures of federal awards (SEFA). 93.677 Social Services Block Grant Department of Health and Human Services Finding: The Organization should have systems in place to prepare a complete and accurate SEFA. The Organizati...

Finding # 2023-004: Significant deficiency over preparation of schedule of expenditures of federal awards (SEFA). 93.677 Social Services Block Grant Department of Health and Human Services Finding: The Organization should have systems in place to prepare a complete and accurate SEFA. The Organization did not identify all federal awards and adjustments were made to the SEFA prepared by management. Recommendation: The Organization should implement additional procedures and controls to accurately capture all activity under federal awards in preparing the SEFA. Corrective Action: The Executive Director and Business Manager will use a grant and contract tracking log to ensure they are aware of all federal awards. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390196 (2023-003)

Significant Deficiency 2023

College Dreams, INC

OR

Reporting Significant Deficiency

Finding # 2023-003: Significant deficiency over reporting Immaterial noncompliance over reporting U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: An annual report is due within 90 days after end of the budget period. The annual performance report was not ...

Finding # 2023-003: Significant deficiency over reporting Immaterial noncompliance over reporting U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: An annual report is due within 90 days after end of the budget period. The annual performance report was not submitted timely. Recommendation: Management should keep track of due dates for reports to avoid late submission. Corrective Action: We will have the Executive Director, Business Manager and College+ Program Manager monitor and ensure reports are remitted timely. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390195 (2023-002)

Significant Deficiency 2023

College Dreams, INC

OR

Eligibility Significant Deficiency

Finding # 2023-002: Significant deficiency over eligibility Immaterial noncompliance over period of performance U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Applications to the program should be reviewed and approved prior to acceptance into the program...

Finding # 2023-002: Significant deficiency over eligibility Immaterial noncompliance over period of performance U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Applications to the program should be reviewed and approved prior to acceptance into the program. Twenty applications out of 40 tested did not have proof of either initial or secondary review. Recommendation: Applications should have advisors or college prep specialists sign off and review prior to the program manager doing secondary review and acceptance. Corrective Action: We will have the Executive Director and College+ Program Manager ensure that all advisors review applications before sending to the College+ Program Manager for approval and acceptance. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390170 (2023-001)

Significant Deficiency 2023

Prince William Sound Science and Technology Institute

AK

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting....

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting. A second procedure outlines how to complete the required reporting. All existing subcontracts over $30,000 were reported as required. Proposed completion date: December 15, 2023.

View Audit 301086

Finding 390151 (2023-002)

Significant Deficiency 2023

Vermont Adult Learning, Inc.

VT

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

Finding # 2023 -002 Issue: During our audit procedures we identified instances where there was no documented rate approval or pay rate support within personnel files. Pay rates and pay rate changes should be reviewed and approved by department supervisors and human resource director at the time o...

Finding # 2023 -002 Issue: During our audit procedures we identified instances where there was no documented rate approval or pay rate support within personnel files. Pay rates and pay rate changes should be reviewed and approved by department supervisors and human resource director at the time of pay changes and documented in personnel files. Root Cause: The Organization is not properly following the internal controls in place over the documentation of such pay rate changes. Corrective Action Plan: ● The Organization has discussed internally how to more accurately and efficiently submit, sign and record pay rates and pay rate changes. The Human Resources department, as well as all supervisors are dedicated to retaining accurate and complete personnel records. The Organization will send each employee a letter when their raise comes up that documents their old rate and new rate. This letter will be signed by the employee, then the Supervisor, as well as the HR Director. Once all three signatures are obtained, HR will send a final, signed copy to the supervisor, and will keep a copy in a secure, central location that is accessible to the Supervisors and Directors. Timeline: This will be implemented as soon as possible Person Responsible for Corrective Action Plan: Joe Przyperhart, Program Director/Interim Executive Director, David Justice, Program Director/Interim Executive Director, Human Resources Director, Grant Managers and Regional Directors will oversee changes to ensure all payroll rate changes are reviewed, approved and appropriately filed in a secure location.

View Audit 301059

Finding 390147 (2023-001)

Significant Deficiency 2023

Vermont Adult Learning, Inc.

VT

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking

Finding # 2023-001 Issue: During our audit procedures we identified instances where there was no documented approval of invoices over expense transactions. Expenses should be reviewed and approved by someone other than the purchaser. Root Cause: The Organization is not properly following the in...

Finding # 2023-001 Issue: During our audit procedures we identified instances where there was no documented approval of invoices over expense transactions. Expenses should be reviewed and approved by someone other than the purchaser. Root Cause: The Organization is not properly following the internal controls in place over the approval of such expense transactions. Corrective Action Plan: We are committed to ensuring that we have approval of all expense transactions. To that end we have: ● VAL implemented procedures that all expenses must be accompanied by a purchase approval form for approval before the payment occurs. The purchase approval form is initiated by the purchaser, then signed by a manager or director and is submitted with the invoice or credit card receipt to Bill.com (A/P) or Dext (CC transactions) for payment and/or documentation retention. Multiple levels of additional approval are documented and retained in Bill.com (A/P). Purchases through vendor websites also include a level of approval (for example Staples and Amazon). In these cases, staff create an order and submit it for approval. The order is not processed until the Office Administrator approves every order. Invoices from these vendors still go through the regular approval process. There is just an extra layer of approval to ensure accuracy in reporting. ● Recurring expenses - The purchase approval process is also initiated for the initial payment of a recurring expense, noting that the expense will be a recurring charge. When expenses occur after the initial expense, any documentation related to the expense will be saved, but no approval form is required for future expenses as long as the amount or coding doesn’t change. This includes, but is not limited to, monthly lease payments, job search subscriptions, parking subscriptions, health/dental/vision/FSA expenses, etc. Timeline: This updated process has been implemented as of April 2023. Staff and management have been more diligent regarding including purchase approval forms to all expenses incurred. VAL has also verified that all expenses are reviewed for accuracy by managers, directors, and the outsourced accounting firm. Person Responsible for Corrective Action Plan: Joe Przyperhart, Program Director/Interim Executive Director, David Justice, Program Director/Interim Executive Director, Grant Managers and Regional Directors will oversee changes to ensure all expenses include the appropriate approval documentation.

View Audit 301059

Finding 390145 (2023-001)

Significant Deficiency 2023

Health Care for All, INC

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 301052

Finding 390139 (2023-001)

Significant Deficiency 2023

Reynolds School District

OR

Significant Deficiency

Reynolds School District respectfully submits the following corrective action plan in response to deficiencies reported in our audit of the fiscal year ended June 30, 2023. The audit completed by theindependent auditing firm December 28, 2023 reported the deficiency listed below. The plan ofaction w...

Reynolds School District respectfully submits the following corrective action plan in response to deficiencies reported in our audit of the fiscal year ended June 30, 2023. The audit completed by theindependent auditing firm December 28, 2023 reported the deficiency listed below. The plan ofaction was adopted by the governing body at their meeting on February 28, 2024, as indicated bysignatures below.Listed below is the deficiency as provided by the auditor followed by the district’s adopted Plan ofAction and implementation timeframe.1. Deficiency #1: SA-2023-001 a. Significant Deficiency—Compliance with Federal Award Program for Davis-Bacon Act • Condition: The District did not get certified payrolls for many contractors within the ESSER grant • Recommendations: We recommend that the District put in place a system where invoices for contracts are not paid until they receive certified payrolls, or some sort of system that ensures compliance. b. Plan of Action • The district will review its processes to ensure contracts include the Davis-Bacon Act provision when applicable and indicate the requirement to provide prevailing wages. • The district will include a requirement to receive documentation of certified payroll from the contractor when applicable as a condition of (and prior to) payment of invoices. c. Implementation Timeframe • The district implemented the review process immediately upon notification from the auditors of this deficiency. Contracts with payments from federal resources will include the Davis-Bacon Act provision to pay prevailing wages and provide documentation through certified payroll. Payment of invoices will not be completed without required documentation.

View Audit 301042

Finding 390121 (2023-003)

Significant Deficiency 2023

Integrated Living, Inc.

KS

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings ...

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2023‐001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Directors and management should review the impact of the current year adjustments on the financial reporting process. Once this review is complete, the Organization should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with U.S. GAAP. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2023‐002 Review and Approval of Project Expenditures (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should obtain proper approval of all project expenditures and that evidence of that approval is documented and maintained.. Action Taken (Unaudited): Management is in the process of updating its control procedures to ensure proper approval of all project expenditures. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. 2023‐003 Written Procedures of Internal Control over Compliance (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. If HUD has questions regarding this plan, please call Patrick Gardner at 785-242-5035. Sincerely yours, Patrick Gardner CEO, COF Training Services, Inc. (Management Agent of Integrated Living, Inc.)

View Audit 301005

Finding 390120 (2023-002)

Significant Deficiency 2023

Integrated Living, Inc.

KS

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings ...

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2023‐001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Directors and management should review the impact of the current year adjustments on the financial reporting process. Once this review is complete, the Organization should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with U.S. GAAP. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2023‐002 Review and Approval of Project Expenditures (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should obtain proper approval of all project expenditures and that evidence of that approval is documented and maintained.. Action Taken (Unaudited): Management is in the process of updating its control procedures to ensure proper approval of all project expenditures. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. 2023‐003 Written Procedures of Internal Control over Compliance (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. If HUD has questions regarding this plan, please call Patrick Gardner at 785-242-5035. Sincerely yours, Patrick Gardner CEO, COF Training Services, Inc. (Management Agent of Integrated Living, Inc.)

View Audit 301005

Finding 390109 (2023-001)

Significant Deficiency 2023

City of San Diego

CA

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

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All not...

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All notification receipts and various forms of verification will be saved in house, on the City of San Diego’s network. This corrective action was set in place as of March 28, 2023, based on findings from the water arrearages program audit. The sewer arrearages program was also completed prior to the original corrective action plan date of March 28, 2023. This was the same finding for both the water and sewer arrearage program audits. Moving forward with this action on a continual basis, once email notifications are sent to customers using an external service provider, notification confirmations will be immediately archived at the City of San Diego. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. This affords the City full control and oversight of the verification process for all future noticing. All available notification verifications from the third-party vendor will be downloaded and saved to the City network for future inquiries. Furthermore, internal controls will be enhanced to ensure notification verification compliance. Upon notification to customers, the Billing and Financial Analytics Program Coordinator will oversee the immediate archiving of all confirmations of emails sent to customers using an external service provider. Once complete, the Billing and Financial Analytics Program Coordinator will notify the Program Manager, who will in turn, perform a secondary review of all notifications against the verification documentation to ensure accuracy. At this point, a third level of approval will be added, as the Public Utilities Customer Support Deputy Director will provide a final level review. Once complete, these documents will be saved for a minimum of five years, per the City of San Diego’s retention policy. Implementation Date: 03/28/2023 Contact: Tracy Morales Interim Deputy Director

View Audit 300999

Finding 390058 (2023-001)

Significant Deficiency 2023

Williams Unified School District No. 2

AZ

Reporting Significant Deficiency

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: March 25, 2024 Planned Corrective Action: The District will monitor and ensure amounts expended a...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: March 25, 2024 Planned Corrective Action: The District will monitor and ensure amounts expended and reported from the ESSER I, II, & III grants agree to the District's accounting records. The Business Manager and Federal Programs Director will work hand in hand to ensure expended funds are reported accurately.

View Audit 300917

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