Corrective Action Plans

Finding 390195 (2023-002)

Significant Deficiency 2023

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

Finding 389982 (2023-001)

Significant Deficiency 2023

Washington Adventist University

MD

Questioned Costs Student Financial Aid Special Tests & Provisions

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process ...

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.

View Audit 300889 Questioned Costs: $1

Finding 389946 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Miami Beach

FL

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

Recommendation: The Authority should designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently ha...

Recommendation: The Authority should designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently has a Quality Control Coordinator who is designated to review samples of tenant files to ensure compliance. The HACMB has reviewed its Quality Control process for areas of improvement; (1) The Quality Control Coordinator will increase the number of file samples that are undergoing the Quality Control process. (2) The Quality Control Coordinator will hold bimonthly reviews with the specialists to ensure the same standard processes are being followed and to focus on retaining the supporting document in the files. The Section 8 staff will be notified of the appropriate action to take regarding any finding in the files. Name(s) of the contact person(s) responsible for corrective action: Suzie Millien Director of Section 8-HCV Planned completion date for corrective action plan: 3/31/2024.

View Audit 300848

Finding 389943 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Miami Beach

FL

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Recommendation: The Authority should designate an individual to review tenant files to ensure that the income reported on the HUD-50058 is supported with proper calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response t...

Recommendation: The Authority should designate an individual to review tenant files to ensure that the income reported on the HUD-50058 is supported with proper calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently has a Quality Control Coordinator who is designated to review samples of tenant files to ensure compliance. The HACMB has reviewed its Quality Control process for areas of improvement; (1) The Quality Control Coordinator will increase the number of file samples that are undergoing the Quality Control process. (2) The Quality Control Coordinator will hold bimonthly reviews with the specialists to ensure the same standard processes are being followed and to focus on each targeted area that needs assistance the most. The Section 8 staff will be notified of the appropriate action to take regarding any finding in the files. Name(s) of the contact person(s) responsible for corrective action: Suzie Millien, Director of Section 8-HCV. Planned completion date for corrective action plan: 3/31/2024.

View Audit 300848 Questioned Costs: $1

Finding 389899 (2023-003)

Significant Deficiency 2023

Wide Ruins Community School

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2023‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: : Aurelia Tapaha, Business Manager/Human Resources Manager; Parthenia Tom, Payroll Technician Anticipated Completion Date: July 2024 Planned Corrective Action:...

Finding Number: 2023‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: : Aurelia Tapaha, Business Manager/Human Resources Manager; Parthenia Tom, Payroll Technician Anticipated Completion Date: July 2024 Planned Corrective Action: The School will conduct background investigations as soon as consent is signed by applicant or employee. Prioritization of background completion will be done in accordance with personnel policies and procedures.

View Audit 300789

Finding 389891 (2023-002)

Significant Deficiency 2023

Pennsylvania College of Art & Design

PA

Significant Deficiency

Finding_ 2023-002 Recommendation: The college should take action steps to bring all regulated elements of the information security programs into compliance and documenting such procedures. Corrective Action: The college will facilitate both internal and external measures to comply with the standards...

Finding_ 2023-002 Recommendation: The college should take action steps to bring all regulated elements of the information security programs into compliance and documenting such procedures. Corrective Action: The college will facilitate both internal and external measures to comply with the standards to safeguard customer and student information. Person Responsible for Corrective Action: Michael Molla, President Anticipated Completion Date for Corrective Action: The Corrective Action will be immediately addressed with both internal and external resources deployed to achieve required compliance with safeguarding information and data security. These measures will be implemented prior to the June 30,2024 year end.

View Audit 300776

Finding 389879 (2023-003)

Significant Deficiency 2023

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible ...

2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible for ensuring student enrollment status for changes in enrollment are correct. Melissa White, Director of Financial Aid, is responsible for uploading the enrollment status reports to clearinghouse. Corrective Action Planned During the audit, it was noted that Tusculum reported student enrollment status at changes in enrollment incorrectly. The Registrar and the Director of Financial Aid will work in conjecture to determine why the report that is pulled to upload to clearinghouse is not pulling accurate student enrollment status changes in enrollment. Once the error is identified and fixed, financial aid will pull the report and check to ensure everything is pulling correctly. Then, each month as the report is pulled, a random sampling of students will be pulled out of the report to be checked against the enrollment records to ensure that the report continues to pull correctly. Anticipated Completion Date The Registrar and Director of Financial Aid still needs to identify where the error is occurring. It is the goal to have this issue resolved before the end of the spring 2024 semester.

View Audit 300763

Finding 389858 (2023-002)

Significant Deficiency 2023

Sunnycrest Village Project LLC

SD

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing: #14.134 Finding Summary: Testing performed by the auditors relating to testing of property, operations, and distributions detected one instance...

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing: #14.134 Finding Summary: Testing performed by the auditors relating to testing of property, operations, and distributions detected one instance where a disbursement of Project funds was not supported with a detailed receipt. Responsible Individuals: Sue Lund, Administrator Corrective Action Plan: The Project will implement new form for invoice approval completion which includes ensuring proper documentation is obtained and retained before disbursement of funds occurs. Anticipated Completion Date: May 31, 2024

View Audit 300735 Questioned Costs: $1

Finding 389854 (2023-002)

Significant Deficiency 2023

Barrett Foundation

NM

Special Tests & Provisions Significant Deficiency

Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Special Tests and Provisions July I, 2022 to June 30, 2023 Condition: During our audit, we noted that Barrett Foundation had one of three tenants sampled who d...

Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Special Tests and Provisions July I, 2022 to June 30, 2023 Condition: During our audit, we noted that Barrett Foundation had one of three tenants sampled who did not have evidence that the rent reasonableness form was reviewed or approved. Criteria: Barrett Foundation has a policy that its process over the rent reasonableness requirement is for one employee to fill out a rent reasonableness form and the supervisor to review and approve it before any rent payments are made on behalf of the client. Effect: Barrett Foundation did not have evidence that it followed its policy over the rent reasonableness requirement. Questioned Costs: None Cause: Barrett Foundation did not file the signed version of the rent reasonableness form and only had the unsigned version to show for the audit. This was due to turnover and certain documents not being filed correctly. Auditors' Recommendation: We recommend that Barrett Foundation ensure that all signed documents are scanned into the Foundation's server to show evidence that all policies and procedures were followed. Management's Response: In FY23, Barrett Foundation experienced significant staffing shortages which resulted is Rent Reasonableness forms not being reviewed or signed. During FY24, Barrett Foundation audited all case files to address incomplete documentation. We also updated our standard operating procedures to indicate that rent reasonableness forms are completed annually as well as when a participant enters the programs, moves to a different unit, if there is a rent increase and that supervisors review and sign the form. Additionally, supervisors will begin conducting monthly random audits of client files to ensure that all required documentation is completed.

View Audit 300728

Finding 389851 (2023-001)

Significant Deficiency 2023

Barrett Foundation

NM

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

FINDING NUMBER I: 2023-001-Compliancc over Matching-(Significant Deficiency) Federal Program Information: Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Matching July 1, 2022 to June 30, 2023 Condition: Dur...

FINDING NUMBER I: 2023-001-Compliancc over Matching-(Significant Deficiency) Federal Program Information: Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Matching July 1, 2022 to June 30, 2023 Condition: During our audit, we noted that Barrett Foundation only matched 7 .34% of the total applicable expenses for the year which was less than the required 25%. Criteria: Barrett Foundation must match all applicable grant funds, with no less than 25 percent of cash or in-kind contributions from other sources (24 CFR section 578.73(a)). Effect: Barrett Foundation under matched the required amount for the Continuum of Care program. Questioned Costs: None Cause: Barrett Foundation did not establish a sufficient system of internal control to ensure that they were in compliance with the required match for the fiscal year. Auditors' Recommendation: We recommend that Barrett Foundation establish a system of internal controls to ensure that they provide at least 25% of both cash and in-kind contributions for all applicable programs under the Continuum of Care program. Management's Response: In FY23, Barrett Foundation transitioned from in-house financial services to an outside accounting firm. The transition allowed Barrett Foundation to create an internal structure to meet the needs of new programs. We recognize that while progress has been made, some issues continue to need attention. We arc working diligently with our community partners to meet their matching requirements and expect to not experience this issue in FY24. Additionally, we arc currently updating Barrett Foundation's Finance Policies in which we arc establishing policies to address contracts that require match.

View Audit 300728

Finding 389810 (2023-002)

Significant Deficiency 2023

The Cleveland Play House

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.302 § 200.403 § 200.430

Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are stan...

Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are standard practice in our organization were not being completed. In addition, the filing of certain documentation to support expenditures was not being done consistently. The Director of Finance position was not filled until November 2022. As a result, documentation of allowable expenditures is being addressed for the fiscal 2023 audit. In addition to turnover, the organization transitioned to a new general ledger system with a new chart of accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certain data pertaining to the federal programs was not being captured. Management has informed all staff of the requirements to track federal programs within the general ledger accounts. Anticipated Completion Date: September 30, 2024 Responsible Contact Person: Erica Tkachyk, Director of Finance

View Audit 300711 Questioned Costs: $1

Finding 389809 (2023-001)

Significant Deficiency 2023

City of Naples Airport Authority

FL

Cash Management Matching / Level of Effort / Earmarking Significant Deficiency § 200.306

Views of responsible officials and planned corrective action: The Authority acknowledges that this error occurred. When we identified this issue, we contacted the grantor agency for guidance. They explained how to submit a refund and acknowledged that since the grant was still open, we had the ab...

Views of responsible officials and planned corrective action: The Authority acknowledges that this error occurred. When we identified this issue, we contacted the grantor agency for guidance. They explained how to submit a refund and acknowledged that since the grant was still open, we had the ability to correct an incorrect draw. This refund has been processed and the Authority has put additional internal controls in place to ensure the proper match is calculated for each grant draw in the future. Additionally, upon final grant closeout, all the numbers are verified and reconciled back to the grant agreement, including the match.

View Audit 300702

Finding 389780 (2023-003)

Significant Deficiency 2023

Antioch College Corporation

OH

Significant Deficiency

Finding 2023-003 - Significant Deficiency - Gramm-Leach Bliley Act (GLBA) - Student Information Security Condition Found The College did not implement the GLBA policy. Corrective Action Plan The College will create and adopt the GLBA policy under the leadership of the new Director of Financial Aid. ...

Finding 2023-003 - Significant Deficiency - Gramm-Leach Bliley Act (GLBA) - Student Information Security Condition Found The College did not implement the GLBA policy. Corrective Action Plan The College will create and adopt the GLBA policy under the leadership of the new Director of Financial Aid. The Director of Financial Aid will monitor new and updated regulations, such as the GLBA policy, to ensure future compliance. Responsible Person for Corrective Action Plan Alina Olson, Director of Financial Aid

View Audit 300675

Finding 389776 (2023-002)

Significant Deficiency 2023

Options Charter School

IN

Procurement, Suspension & Debarment Significant Deficiency § 200.318

Recommendation: We recommend that the School review their Procurement policy and ensure that all missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ...

Recommendation: We recommend that the School review their Procurement policy and ensure that all missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Options Schools, Inc. will update the Procurement policy to include federal requirements. Name(s) of the contact person(s) responsible for corrective action: Jack Colwell Planned completion date for corrective action plan: July 1, 2023 If the U.S. Department of Education has questions regarding this plan, please call Jack Colwell, CFO at 463-238-1414. 18077 River Road, Suite 106 I Noblesville, IN 46062 I phone: 317.565.4350 www.optionsschools.

View Audit 300666

Finding 389765 (2023-002)

Significant Deficiency 2023

Homeward Bound of Western North Carolina, Inc.

NC

Cash Management Significant Deficiency

Name of Contact Person: Suzy Johnson, Director of Finance & Operations Corrective Action: All grant billing projection sheets will be completed on a monthly basis and given to the appropriate program director for review and approval before any grant draws are initiated. Completion Date: On or by ...

Name of Contact Person: Suzy Johnson, Director of Finance & Operations Corrective Action: All grant billing projection sheets will be completed on a monthly basis and given to the appropriate program director for review and approval before any grant draws are initiated. Completion Date: On or by June 30, 2024

View Audit 300656

Finding 389740 (2023-004)

Significant Deficiency 2023

City of Waltham, Massachusetts

MA

Equipment & Real Property Management Procurement, Suspension & Debarment Significant Deficiency § 200.313

DEA Asset Forfeitures – Assistance Listing No. 16.922 Recommendation: Procedures should be updated to ensure all assets purchased with federal funds go through a physical inventory count every 2 years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. A...

DEA Asset Forfeitures – Assistance Listing No. 16.922 Recommendation: Procedures should be updated to ensure all assets purchased with federal funds go through a physical inventory count every 2 years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Waltham Police Department Policy Chapter 17 – Fiscal Management – has been updated/amended adding a stand-alone paragraph mandating a physical annual audit of any assets purchased with federal funding. Name(s) of the contact person(s) responsible for corrective action: Deputy Police Chief Steven R. Champeon Planned completion date for corrective action plan: On or about April 5, 2024, the policy should be finalized and distributed department wide.

View Audit 300631

Corrective Action Plans

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