Corrective Action Plans

Finding 382908 (2023-002)

Significant Deficiency 2023

OR

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding as it was identified and rectified during an internal audit earlier this year. Effective Fall 2023 a new process is in place that incorporates all Title IV funding into the current stale-dated refund check process. The Bursar and the Student Financial aid office will closely monitor aging checks and reissue or return funds to the Department of Education. Names of the contact persons responsible for corrective action: Stephanie Hanigan and Karinda Decker Planned completion date for corrective action plan: Completed

View Audit 296487 Questioned Costs: $1

Finding 382907 (2023-001)

Significant Deficiency 2023

Southern Oregon University

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure ...

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Action taken in response to finding: The Student Records Specialist will increase monitoring of Clearinghouse data. SOU will also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Issues that are identified will be communicated to the Director of Financial Aid and University Registrar for reconciliation. Name(s) of the contact person(s) responsible for corrective action: Karinda Decker and Matt Stillman Planned completion date for corrective action plan: Immediately

View Audit 296487

Finding 382902 (2023-005)

Significant Deficiency 2023

Municipality of Arroyo

PR

Equipment & Real Property Management Significant Deficiency

Financial Statements Findings – Finding Reference 2023-004.

View Audit 296466

Finding 382874 (2023-002)

Significant Deficiency 2023

Pennsylvania Institute of Technology and Subsidiaries

PA

Student Financial Aid Reporting Significant Deficiency

Finding 2023-002 – Enrollment Reporting – Significant Deficiency ALN Number: 84.063; 84.268 Federal Award Identification Number: P063P220616; P268K230616 Recommendation: It is recommended that the College have someone independent of the preparer review the NSLDS roster file to check the effective da...

Finding 2023-002 – Enrollment Reporting – Significant Deficiency ALN Number: 84.063; 84.268 Federal Award Identification Number: P063P220616; P268K230616 Recommendation: It is recommended that the College have someone independent of the preparer review the NSLDS roster file to check the effective date of change in status is in agreement with the College's records. Action Taken: Academic Records Office personnel were re-trained. Also, a report has been written to be run after the Student Status Confirmation Report (SSCR) procedure is run in the student financial aid system, that flags when a “Last Date of Attendance (LDA)” and NSLDS Withdrawal Date differ. Those cases can be troubleshooted and fixed, the SSCR rerun, and that updated file uploaded.

View Audit 296451

Finding 382825 (2023-001)

Significant Deficiency 2023

Delta Sigma Theta Sorority Inc.

DC

Procurement, Suspension & Debarment Reporting Significant Deficiency

The Board approved a new Credit Card Policy of the Sorority in May 2021. Credit cards are an integral part of the mix of instruments available for managing payment relationships with vendors. At present, the Sorority maintains six (6) sponsored credit cards and we recognize and acknowledge that a m...

The Board approved a new Credit Card Policy of the Sorority in May 2021. Credit cards are an integral part of the mix of instruments available for managing payment relationships with vendors. At present, the Sorority maintains six (6) sponsored credit cards and we recognize and acknowledge that a material risk of exposure is present. While Delta Sigma Theta has a formal credit card policy in place, it has not been consistently following to ensure that assets of the organization are safeguarded. We are implementing a number of new processes and procedures to ensure that future credut card expenditures are documented with the following: 1. Valid business purpose; 2. Vendor receipts included as documentation and support, and; 3. Evidence of proper approval. This will ensure tht the credit card expenses are properly accounted for and reconciled within the general ledger. To achieve the stated objectives, the finance and accounting department has begun implementing a number of internal controls. Payment processes and procedures are being developed for transactions beginning January 1, 2024. They are as follows: 1. Develop a Credit Card Expense Request document that must be completed by those requesting expenditures that includes and discusses the business prupose of the expense. 2. Continuous training with those charged with making purchases with credit cards and those completing reports on the how to utilize the reports developed, how to properly code items to the general ledger and the documentation needed to substantiate the request. 3. New hirings, including new CFO and Director, that started in 2023. Restructuring the team to include higher level accounting staff that have greater education and experience with GAAP accounting. 4. Enforcement by management of its formal credit card policy throughout the year. 5. Monthly reconciliations that highlight compliance and allows for timely enforcement and correction of non-compliance.

View Audit 296427

Finding 382748 (2023-002)

Significant Deficiency 2023

Municipality of Moca

PR

Reporting Significant Deficiency

Reportable Condition: See Condition 2023-002 Recommendation The Municipality must verify the expenses with the accounting system before submission of the reports and determine whether the information in the system is complete and accurate. Action Taken Before sending any report to be signed it ...

Reportable Condition: See Condition 2023-002 Recommendation The Municipality must verify the expenses with the accounting system before submission of the reports and determine whether the information in the system is complete and accurate. Action Taken Before sending any report to be signed it have to verified with the accounting system before submission and they must have the system report to had The Finance department approval for submission. We are going to made control that the report before approval had all the documents that match the report with the accounting records to be approved for submission.

View Audit 296354

Finding 382739 (2023-001)

Significant Deficiency 2023

District School Board of Pinellas County

FL

Subrecipient Monitoring Significant Deficiency

Planned Corrective Action - The district will review procedures in alignment with state and federal guidance. The district's FTE team will include the federal guidelines for documentation supporting student withdrawal and subsquent removal from the graduation cohort in their annual and ongoing trai...

Planned Corrective Action - The district will review procedures in alignment with state and federal guidance. The district's FTE team will include the federal guidelines for documentation supporting student withdrawal and subsquent removal from the graduation cohort in their annual and ongoing training with school-based staff responsible for this practivce. The district continuously adheres to the State of Florida documentation requirements and guidelines for inclusion for graduation cohorts. Anticipated Completion Date - 4/30/2024 Responsible Contact Person - Kevin W. Smith

View Audit 296328

Finding 382684 (2023-005)

Significant Deficiency 2023

Muncie Community Schools

IN

Internal Control / Segregation of Duties Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2023-005 – Title I Grants to Local Educational Agencies - Maintenance of Effort Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ex...

Finding 2023-005 – Title I Grants to Local Educational Agencies - Maintenance of Effort Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all expenses are recorded correctly and any capital items over the threshold are properly recorded to capital object codes. Anticipated Completion Date: March 2024

View Audit 296252

Finding 382651 (2023-001)

Significant Deficiency 2023

River Forest Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The Scho...

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The School Corporation did not have a proper system of oversight or review to ensure that all students on the direct certification match report were entered accurately into the point-of-sale system. We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the Eligibility compliance requirement Contact Person Responsible for Corrective Action: Nick Alessandri Contact Phone Number and Email Address: 219-962-7551 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: River Forest Community School Corporation is now part of the Community Eligibility Provision (CEP) and therefore the direct certification process will no longer take place. In the event that we are no longer CEP and begin the direct certification process, we will implement a process of internal controls that ensure proper oversight and review to ensure all students are entered accurately into our point-of-sale system. Anticipated Completion Date: July 1, 2023

View Audit 296243

Finding 382645 (2023-002)

Significant Deficiency 2023

San Joaquin Delta Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The Admissions & Records Department discovered that there was an error in our reporting. The issue is that the wrong field was being picked up by NSLDS because our report was not pulling the correct data field. This has been corrected by the District IT department. We also discovered that although w...

The Admissions & Records Department discovered that there was an error in our reporting. The issue is that the wrong field was being picked up by NSLDS because our report was not pulling the correct data field. This has been corrected by the District IT department. We also discovered that although we reported the correct data to the National Clearinghouse, it never transferred over to NSLDS. We will reach out to the Clearinghouse to ensure that this will not occur again. We also discovered that with one student enrollment issue, the college did not follow the correct process so that the report did not pick up the student enrollment. This has been resolved by providing staff with appropriate training. The director has and will continue to provide ongoing training.

View Audit 296241

Finding 382621 (2023-002)

Significant Deficiency 2023

Flagler College, Inc.

FL

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

Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks....

Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College’s Information Technology department will amend the written program and policy to include all necessary aspects of GLBA compliance and IT management and cybersecurity risk. Names of the contact person responsible for corrective action: Gwen Pechan Planned completion date for corrective action plan: March 31, 2024

View Audit 296201

Finding 382620 (2023-001)

Significant Deficiency 2023

Flagler College, Inc.

FL

Student Financial Aid Subrecipient Monitoring Reporting

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is complet...

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Registrar’s Office will collaborate with our Information Technology Department to identify and correct all students with erroneous program start dates. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions in collaboration with the Information Technology Department and Advising Office to ensure that the program-level enrollment effective dates are accurately reflected when a student submits a change of major. Names of the contact persons responsible for corrective action: Sheia Pleasant-Doine and Adam Doine Planned completion date for corrective action plan: May 3, 2024

View Audit 296201

Finding 382599 (2023-002)

Significant Deficiency 2023

Catholic Charities, Inc.

DE

Cash Management Reporting Significant Deficiency

Major Program: 93.568 - Low Income Home Energy Assistance (Grantor - Department of Health and Social Services) Condition: The 2023 program year heating funds reconciliation report was not completed and submitted to the State of Delaware in a timely manner. Corrective Action Plan: Charities DEAP prog...

Major Program: 93.568 - Low Income Home Energy Assistance (Grantor - Department of Health and Social Services) Condition: The 2023 program year heating funds reconciliation report was not completed and submitted to the State of Delaware in a timely manner. Corrective Action Plan: Charities DEAP program has revised and implemented reconciliation procedures to ensure the program year 2023 heating reconciliation benefit report is completed on April 6, 2024. The final reconciliation report for the 2023 heating benefit refund will be remitted to the State of Delaware Office of Community Services (OCS) in accordance with the established guidelines by April 14, 2024. Process of completion is performed manually: 1. The collection of delivered and non-delivered fuel vendors’ unexpended benefits reports has been obtained from the non-delivered vendors. Completed November 2023. 2. Inter-Agency households’ report of benefits returned to the State of Delaware OCS for the heating season 2023 by the county and by invoice number is in process of being manually completed. 3. The documents noted in procedures 1 and 2 must reconcile with the DEAP billing supervisor report of heating benefits issued - funded and refunded by the vendors. The agency finance unit reporting of paid benefits vs refunded benefits must be compared to the noted reports to verify all report totals equal. 4. The unused benefit report noting the total amount to be returned to the State OCS, is completed once the agency finance unit verification of totals reported in procedures 2 and 3 are accurate for the 2022-2023 heating reconciliation. The program year 2023 reconciliation report will be completed according to OCS’s format and submitted along with the check from the agency for the total amount of the refund. Contact Person Responsible for Corrective Action: Samantha Wallace, Interim Executive Director Anticipated Completion Date of Corrective Action: April 6, 2024

View Audit 296160

Finding 382598 (2023-001)

Significant Deficiency 2023

Catholic Charities, Inc.

DE

Cash Management Eligibility Significant Deficiency

Major Program: 10.558 - Child and Adult Care Food Program (Grantor - Department of Agriculture) Condition: We tested 18 provider files and identified two billing errors within the May 2022 claim submissions. For each instance of error, the number of meals served was incorrectly determined and submit...

Major Program: 10.558 - Child and Adult Care Food Program (Grantor - Department of Agriculture) Condition: We tested 18 provider files and identified two billing errors within the May 2022 claim submissions. For each instance of error, the number of meals served was incorrectly determined and submitted for reimbursement. Corrective Action Plan: Catholic Charities Program Manager, Joanne Varnes, conducted a training on December 19, 2023 with all staff involved in the CACFP that included income eligibility/enrollment categorization and meal count accuracy. Catholic Charities staff will review each income form/enrollment and double check that children’s reimbursement rate is properly categorized based on their family’s income. Staff members will review each claim before it is entered for reimbursement to ensure the claim is accurate. Program Manager, Joanne Varnes, will oversee this process and conduct case record reviews quarterly for all providers under Catholic Charities Sponsorship. Contact Person Responsible for Corrective Action: Samantha Wallace, Interim Executive Director Anticipated Completion Date of Corrective Action: Immediately

View Audit 296160

Finding 382584 (2023-007)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Beginning January 31, 2024, DDAP started having internal discussions to determine the most effective and efficient methodology to evaluate the internal controls of the SCAs' data being reported to DDAP during the federal grant period and in the PPRs. Steps currently being taken by DDAP include updat...

Beginning January 31, 2024, DDAP started having internal discussions to determine the most effective and efficient methodology to evaluate the internal controls of the SCAs' data being reported to DDAP during the federal grant period and in the PPRs. Steps currently being taken by DDAP include updating the SCAs' monitoring process for the next annual monitoring cycle for FY 2023-24. The goal is to have a sound methodology with formalized policies and procedures in place by April 2024 to ensure the data collected is sampled for accuracy going forward. To ensure accuracy of the information reported by the SCAs, which is included on the PPRs, DDAP will add verification of this data to the current SCA monitoring process. Specifically, the Project Officers who conduct SCA monitoring will: - Add a question to the SCA Pre-Submission packet: ‘How does your SCA track SOR-funded clients in order to accurately report them on the SOR Report?’ The SCA must specifically state how they are accounting for these clients and how they arrive at the data reported to DDAP. If DDAP determines the process is not acceptable, the SCA will be required to revise and resubmit. - During the virtual monitoring call, Project Officers will review the SCA’s written answer to the question, and ensure they have a full understanding of where the SCA keeps data on SOR-funded clients, and how they access this data to complete the SOR reports. - During the onsite monitoring visit, the Project Officers will take the most recently submitted SOR report and ask the SCA staff to duplicate the steps they used to arrive at the reported numbers. * If the SCA is able to demonstrate how clients are tracked and the steps used to determine the reported numbers produce results consistent with what was submitted in the report, the SCA’s submitted data will be considered verified. * If the SCA is unable to demonstrate how clients are tracked, and the steps used to determine the reported numbers do not produce results consistent with what was submitted in the report, the SCA will be required to implement a process by which they can accurately track this data and report client numbers. Any SCA required to implement a new client-tracking system will be required to submit backup documentation with their SOR reports, until such time as they are able to demonstrate to DDAP that they are accurately tracking clients and can demonstrate the steps used to determine their reported numbers. - This review process and results will be added to the Monitoring Report sent to the SCA at the end of the monitoring cycle, to reflect the SCA’s compliance status. Anticipated Completion Date: 09/30/2024 Contact Names: Susan Duff, Chief, Program Monitoring Division; Autumn Croasmun, Project Director for State Opioid Response III Grant; Tia Roebuck, Director, Division of Budget and Procurement

View Audit 296143 Questioned Costs: $1

Finding 382567 (2023-013)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Reporting Subrecipient Monitoring Significant Deficiency

1. Upon receiving the annual 4th quarter ACF-196R from the Bureau of Financial Management, the Office of Income Maintenance (OIM) Bureau of Policy (BOP) replies with a confirmation receipt and a reminder to send any future revisions of the report with an email priority of important. 2. OIM, BOP up...

1. Upon receiving the annual 4th quarter ACF-196R from the Bureau of Financial Management, the Office of Income Maintenance (OIM) Bureau of Policy (BOP) replies with a confirmation receipt and a reminder to send any future revisions of the report with an email priority of important. 2. OIM, BOP updated the roles in the On-line Data Collections (OLDC) Grant Solutions portal. 3. OIM, BOP set up OLDC Grant Solutions to generate an email notification for any new submissions, revised submissions, or any previous submissions that are withdrawn. 4. OLDC Grant Solutions notifications received between the months of January and March will receive priority to ensure any necessary amendments to the TANF Annual report (ACF-204) are properly submitted by the March 31 deadline. Anticipated Completion Dates: 1 - 11/30/2024; 2, 3 - Completed; 4 - March 2024 Contact Name: Adam Riggs, Director, Division of Family Assistance, OIM, BOP

View Audit 296143

Finding 382556 (2023-016)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking

Office of Medical Assistance Programs’ Bureau of Data and Claims Management (BDCM) is currently negotiating an amendment to the PROMISe contract with Gainwell Technologies. The amendment will modify the NCCI performance requirement to include a statement equivalent to “Only a state Medicaid agency h...

Office of Medical Assistance Programs’ Bureau of Data and Claims Management (BDCM) is currently negotiating an amendment to the PROMISe contract with Gainwell Technologies. The amendment will modify the NCCI performance requirement to include a statement equivalent to “Only a state Medicaid agency has the discretion to release additional information for selected individual edits or limited ranges of edits from the files posted on the secure RISSNET portal.” Anticipated Completion Date: 06/30/2024 Contact Name: Toni Hoffecker, Dir., Div. of Systems, Monitoring and Oversight, BDCM

View Audit 296143

Finding 382529 (2023-019)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

L&I: A request has been made to RSA for the correction of the report. A correction will be made by OB-OCO once the report is open. To avoid typographical errors in the future, the CFO and the Division Chief of Budget and Admin will review the report after submission by OB-OCO to ensure the submissio...

L&I: A request has been made to RSA for the correction of the report. A correction will be made by OB-OCO once the report is open. To avoid typographical errors in the future, the CFO and the Division Chief of Budget and Admin will review the report after submission by OB-OCO to ensure the submission is correct. Anticipated Completion Date: 04/15/2024 Contact Name: Zulqarnain Nasir, Chief Financial Officer, OVR, L&I OB-OCO: • General Accounting revised our procedures to include having both the reviewer and preparer match the PDF output to the final Excel spreadsheet. • General Accounting discussed this finding and procedure change with the applicable staff on February 28, 2024 and February 29, 2024. • OVR has requested that the USDE unlock the RSA-17 Report for editing. General Accounting will submit a revised RSA-17 report to USDE once the report is unlocked. Anticipated Completion Date: 04/15/2024 Contact Names: Carson Buck, Commw. Accountant Manager; Kathleen Bolick, Accountant 3

View Audit 296143

Finding 382528 (2023-018)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.309 § 200.461

The final report for the grant H126A210056 has already been submitted to the RSA. No changes can be made to the RSA report at this point. A reconciliation process has been introduced which will eliminate period of performance (POP) violations for the current/future grants. Currently, OVR is using th...

The final report for the grant H126A210056 has already been submitted to the RSA. No changes can be made to the RSA report at this point. A reconciliation process has been introduced which will eliminate period of performance (POP) violations for the current/future grants. Currently, OVR is using this method to ensure correction of POP violations for the current VR grants (if any). Adjusting entries to correct the POP violation in SAP will be posted by 04/15/2024 subject to the approval of OB-OCO to open the closed internal orders of the grant. Anticipated Completion Date: 04/15/2024 Contact Name: Zulqarnain Nasir, Chief Financial Officer, OVR

View Audit 296143 Questioned Costs: $1

Finding 382527 (2023-017)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Internal Control / Segregation of Duties Significant Deficiency

1. The role was removed from the users’ profiles after the audit period, once the auditors pointed out the issue. 2. Update the user access request form to clarify the circumstances under which privileged roles may be assigned to application users. 3. Evaluate if there is a need for a new role; and...

1. The role was removed from the users’ profiles after the audit period, once the auditors pointed out the issue. 2. Update the user access request form to clarify the circumstances under which privileged roles may be assigned to application users. 3. Evaluate if there is a need for a new role; and if there is not an existing role to accomplish existing job duties, then we can look to create new privileged roles that allow administrators to assign the lowest level of permission required. 4. The program area will perform quarterly periodic access reviews of privileged (admin) role users to include an assessment of the appropriateness of role assignments. 5. The program area will conduct a review of all OVR staff user roles to include an assessment of the appropriateness of role assignments on an annual basis. Anticipated Completion Dates: 1 - Completed; 2 - 06/30/2024; 3, 4, 5 - Ongoing Contact Name: William McLean Jr., Chief, Workforce Development and Information Division, OA-OIT

View Audit 296143

Finding 382521 (2023-020)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Reporting Significant Deficiency

PEMA Capital Project Reporting: The PEMA Emergency Medical Services Recovery SLFRF Project (87374A) was reported to the federal government with $0 for capital expenditures because all recipients were beneficiaries. The SLFRF federal guidance states the following: 11. Subrecipient Monitoring. SLFRF...

PEMA Capital Project Reporting: The PEMA Emergency Medical Services Recovery SLFRF Project (87374A) was reported to the federal government with $0 for capital expenditures because all recipients were beneficiaries. The SLFRF federal guidance states the following: 11. Subrecipient Monitoring. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass-through entities. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F. U.S. Treasury, Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds, Version 5.14, December 14, 2023, Pages 12-13. (This is the current version) Additionally, the U.S. Treasury states in their Quarterly Reporting User Guide Frequently Asked Questions (page 165 of the current edition): 1.20. Who are beneficiaries and are recipients required to report for them? The terms and conditions of federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance, including audit pursuant to the Single Audit Act and 2 CFR Part 200, Subpart F or subrecipient reporting requirements. OB-GBO interpreted this to mean that reporting was not necessary, but we are seeking clarification from U.S. Treasury. Meanwhile, we will collaborate with PEMA to review grant materials and address capital expenditure questions by July 31, 2024. Capital Project In Excess Of $10M: The Quarter 1 2023 Project and Expenditure Report submitted by the Commonwealth of Pennsylvania did not capture the DCNR State Parks and Outdoor Recreation Grants Program (87360B) as a capital project in excess of $10M. The federal reporting portal inaccurately recorded the submission, and unfortunately, we cannot verify if this was due to a technical issue (there have been several instances we found where information we entered into the portal was reported differently in the U.S. Treasury generated report summary and had to be corrected by the U.S. Treasury after submission) or human error since access to older reports is blocked, nor does the abridged PDF version of the submission from the U.S. Treasury portal contain that specific information. While the error was noted in the Quarter 1 2023 report, it had been corrected in the Quarter 2 report. Currently, there is no further action we can take regarding the Quarter 1 2023 report. We consider this issue resolved. Capital Project Justification Did Not Include All Required Elements: The DCNR State Parks and Outdoor Recreation Grants Program (87360B) has been reported as a capital project. OB-GBO acknowledges that the capital project justification did not include all the required elements below: (i) Describe the harm or need to be addressed; (ii) Explain why a capital expenditure is appropriate; and (iii) Compare the proposed capital expenditure to at least two alternative capital expenditures and demonstrate why the proposed capital expenditure is superior. OB-GBO plans to collaborate with DCNR to ensure future reports include all necessary elements by July 31, 2024. Anticipated Completion Date: 07/31/2024 Contact Names: Michael Wood, Bureau Director, Bureau of Performance, Revenue, and Program Analysis, OB-GBO; Colleen Kling, Division Manager, Division of Programs and Performance, OB-GBO; Samantha Lockhart, Executive Budget Specialist, OB-GBO; Evelyn Madenford, Volunteer Loan Program Administrator, Office of State Fire Commissioner, PEMA; Mark Hansford, Division Manager, Division of Community and Conservation, DCNR

View Audit 296143

Finding 382515 (2023-008)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties

PDE agrees with the portion of the finding pertaining to the lack of required signature on an expenditure report. To address this error, PDE will retrain staff and update “Tool Tips” in PEARS so that it is clearer for field advisers. PDE disagrees with two of the conditions of the finding, as stat...

PDE agrees with the portion of the finding pertaining to the lack of required signature on an expenditure report. To address this error, PDE will retrain staff and update “Tool Tips” in PEARS so that it is clearer for field advisers. PDE disagrees with two of the conditions of the finding, as stated by the auditors. First, regulation 7 CFR 226.6 (o), cited and summarized by the auditors as requiring PDE to resolve and close reviews within a specific timeline, does not include this requirement in the text. The regulation requires that subrecipients resolve any issues with a timeframe specified in their corrective action. Second, the first bulleted condition, states that “these reviews did not include any complex findings that would have required more time to close.” PDE procedure for closing reviews states that “any exception must be communicated and approved by the Supervisor…” The procedure does not qualify or limit these exceptions to “complex findings.” Accordingly, PDE will continue to follow its procedures as written. Anticipated Completion Date: 06/30/2024 Contact Names: Vonda Ramp, Chief, Div. of Food & Nutr., Bur. of Bdgt. & Fiscal Management; Clayton Carroll, Audit Coord., Bur. of Bdgt. & Fiscal Management

View Audit 296143 Questioned Costs: $1

Finding 382502 (2023-005)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Eligibility

PDA, Bureau of Food Assistance (BFA) has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. BFA, in coordination with our contractor, Hunger-Free Pennsylvania, has developed a mechanism to track the reviews of all 16 lead subrecipient agencies f...

PDA, Bureau of Food Assistance (BFA) has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. BFA, in coordination with our contractor, Hunger-Free Pennsylvania, has developed a mechanism to track the reviews of all 16 lead subrecipient agencies for the Commodity Supplemental Food Program (CSFP). This tracking mechanism will help to ensure that CSFP monitoring reviews are scheduled and completed in a timely manner, in accordance with federal regulations pertaining to CSFP. 2. BFA has scheduled a comprehensive monitoring review of Food Helpers (formerly known as Greater Washington County Food Bank). The review is scheduled to begin March 2024, and should be completed no later than April 30, 2024. Anticipated Completion Dates: 1 - Completed; 2 - 04/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

View Audit 296143 Questioned Costs: $1

Finding 382486 (2023-004)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Reporting School Nutrition Programs Special Tests & Provisions

PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods ...

PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods to ensure any errors are identified and corrected when reconciling the Bureau of Food Assistance’s (BFA’s) Commodity Inventory Report: 1. The finding noted in the audit with regards to the Commodity Inventory Report has been corrected and no known issues remain. 2. BFA will cross-train an additional staff member (the NSLP Specialist) on the process of completing the monthly Commodity Inventory Report. This staff member will then serve as a back-up to the Processing Specialist and will be able to complete a monthly review of the completed Commodity Inventory Report to ensure accuracy. 3. In the event that the numbers in BFA’s Monthly Commodity Inventory Report don’t balance, the Processing Specialist will consult with the Technical Specialist managing PA Meals, who can assist with a technical review of the raw numbers. 4. Sent an email communication to select commodity processors and brokers reiterating the process for submitting Monthly Processing Reports (MPRs) to BFA and reminding them of their responsibility to provide prompt responses should questions arise. Anticipated Completion Dates: 1, 3, 4 - Completed; 2 - 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

View Audit 296143

Finding 382359 (2023-001)

Significant Deficiency 2023

Trinity College Dba Trinity University (washington, Dc)

DC

Student Financial Aid Significant Deficiency

Trinity University Corrective Action Plan June 30, 2023 Department of Education Trinity University respectfully submits that following corrective action plan for the year ended June 30, 2023. Brown Edwards 3906 Electric Road Roanoke, VA 24018 Audit Period: June 30, 2023 2023-001 Treatment of Title I...

Trinity University Corrective Action Plan June 30, 2023 Department of Education Trinity University respectfully submits that following corrective action plan for the year ended June 30, 2023. Brown Edwards 3906 Electric Road Roanoke, VA 24018 Audit Period: June 30, 2023 2023-001 Treatment of Title IV Funds when a Student Withdraws (Significant Deficiency), Department of Education, SFA Cluster Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: Nine of seventeen students selected for withdraw testing for the 2022-2023 academic year required a return of funds to the Department of Education. Calculation of R2T4 forms for two students were not completed when they were in fact due a refund. Action Taken: The University is modifying the withdrawal procedure to provide more specific rules and instructions related to R2T4 requirements and timeliness. A shared document has been created in order to identity and monitor students who have withdrawn and are due a refund to ensure that refunds are made in a timely manner. Responsible Party: Cathy Geier Contact Information: Vice President of Enrollment Services Office Phone: (202) 884-9545 Email Address: geierc@trinitydc.edu Expected date of correction: January 12, 2024

View Audit 296036

Corrective Action Plans

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