Corrective Action Plans

Finding 372180 (2023-001)

Significant Deficiency 2023

OH

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management § 200.305

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expendit...

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, Accounts Payable will manually change the payment terms to 30 calendar days or less, to ensure compliance. Periodically, Accounts Payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable Offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by Accounts Payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and Principal Investigators (PIs) to highlight the need for prompt review and approval of Federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the university’s Fundamentals of Sponsored Administration training courses. Contact person responsible for corrective action: Accounts Payable: Erik Sager; Purchasing: Tom Guerin; Sponsored Research Services Accounting: John Ungruhe Anticipated Completion Date: Initial corrective action, including review of invoices, reminders and modifications to training, will be completed by 10/31/2023. Additional solutions to eliminate manual updates, if possible, will be completed within 12 months.

View Audit 293505

Finding 372171 (2023-002)

Significant Deficiency 2023

City of Walnut

CA

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

2023-002 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in ...

2023-002 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Views of Responsible Officials: The City will revise it’s policies and procedures to perform verification of suspension or debarment status for each vendor before the City enters into a covered transaction with the vendor. Name of Responsible Person: Karen Ogawa, Director of Finance Implementation Date: February 21, 2024

View Audit 293462

Finding 372126 (2023-003)

Significant Deficiency 2023

Independent School District No. 139

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties School Nutrition Programs

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.556 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment Requiremen...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.556 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal program. The District did not have sufficient controls in place within its child nutrition cluster federal program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Kerstin Quigley, Business Manager. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Business Manager and the Superintendent will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 293419

Finding 372115 (2023-002)

Significant Deficiency 2023

Houston Recovery Center, Lgc

TX

Cash Management Reporting Significant Deficiency

Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12...

Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12/31/24, U. S. Department of Health and Human Services:, Assistance Listing #93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Contract #5H79TI080624-03, Contract year: 09/30/21 – 09/29/22, Contract #5H79TI080624-04, Contract year: 09/30/22 – 09/29/23, Passed through the City of Houston Health Department, Contract #H79SP080300, Contract years: 11/01/21 – 10/31/22, 11/01/22 – 10/31/23 and 06/08/21 – 06/30/23, Assistance Listing #93.788, Opioid STR, Passed through the Texas Health and Human Services Commission, Contract #HHS000357900001, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23, Passed through the University of Texas Health Science Center, San Antonio, Contract #HHS000561800001, Contract year: 09/01/21 – 08/31/22, Assistance Listing #93.959, Block Grants for Prevention and Treatment of Substance Abuse, Passed through the Texas Health and Human Services Commission, Contract #HHS000130500019, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23. Condition and context: Houston Recovery Center is required to submit monthly reimbursement requests for five of its federal programs; one program requires reimbursement requests based on achievement of certain milestones rather than time. Out of a sample of 17 requests, we found six did not have evidence of review and approval as required by Houston Recovery Center’s policies and procedures. Recommendation: Training should be provided to ensure that policies and procedures regarding independent review and approval are followed. Planned corrective action: Houston Recovery Center will strengthen its internal control policies and procedures over independent review and approval of grant payment requests by shifting the primary review and approval process from the Chief Executive Officer (CEO) to the Chief Operating Officer (COO). The COO has full knowledge of allowable costs and has more availability than the CEO, which will make it easier to ensure that our policies and procedures are followed on a consistent basis. The CEO will continue in this role as backup to the COO to ensure immediate access for needed approval. We believe we have a strong system in place used by our accounting department to ensure all expenses underlying the grant payment requests are reviewed, checked for accuracy, and properly approved which further supports the reimbursement policies and procedures. Responsible officer: Leonard Kincaid, Executive Director. Estimated completion date: November 1, 2023.

View Audit 293417

Finding 372111 (2023-001)

Significant Deficiency 2023

Services and Advocacy for Gay, Lesbian, Bisexual, and Transgender Elders, Inc.

NY

Cash Management Allowable Costs / Cost Principles Significant Deficiency

Internal Control over Compliance- Cash Management Recommendation: Internal controls are designed to ensure an adequate review and approval process is in place before submission of any drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding...

Internal Control over Compliance- Cash Management Recommendation: Internal controls are designed to ensure an adequate review and approval process is in place before submission of any drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: Management has implemented appropriate controls to ensure drawdowns are reviewed and approved by staff familiar with the purpose and operations of the contracts before requests are processed in the payment management system. Name of the contact person responsible for corrective action: David Rivera-Garcia, Executive Vice President/CFO Planned completion date for corrective action plan: June 2024

View Audit 293410

Finding 372110 (2023-001)

Significant Deficiency 2023

Ada County Housing Authority

ID

Significant Deficiency Program Income Internal Control / Segregation of Duties § 200.303

Federal Award Findings and Questioned Costs Reference Number: 2023‐001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Financial Assistance Listing: 14.267 Finding Summary: Program Income Significant Deficiency in Internal Control...

Federal Award Findings and Questioned Costs Reference Number: 2023‐001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Financial Assistance Listing: 14.267 Finding Summary: Program Income Significant Deficiency in Internal Control over Compliance Contact: Jillian Patterson, Deputy Director 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: There was not a documented review by a separate individual outside of the preparer of the program income calculations. The Housing Authority had a review process in place over program income calculations. However, the review process was not documented. Corrective Action Plan: It is important to note that while we do have a process in place for program income calculations, we recognize that it was not adequately documented. To remedy this and ensure compliance with federal regulations, we have developed the following corrective action plan: Implementation of Controls Configure Yardi Voyager PHA software to enforce controls and workflows that ensure consistency and documentation of the review process. This may include setting up automated notifications for review assignments, establishing approval hierarchies, and creating standardized templates for documentation. Designation of Reviewer Utilize Yardi Voyager PHA software to assign designated reviewers for program income calculations, ensuring separation from the preparer. The software will facilitate clear identification of reviewers, their roles, and responsibilities within the review process. Documentation of Review Process Utilize Yardi Voyager PHA software to streamline and document the review process for program income calculations. The software will be configured to include a dedicated workflow specifically for documenting and tracking reviews conducted by separate individuals outside of the preparer. Periodic Monitoring and Evaluation Utilize the reporting and analytics features to monitor and evaluate the effectiveness of the review process. Generate regular reports to assess compliance with established procedures and identify any areas for improvement. Ongoing Compliance Monitoring Utilize Yardi Voyager PHA software to conduct ongoing compliance monitoring of internal controls and processes related to program income calculations. Set up automated alerts and notifications to flag any potential non‐compliance issues for timely resolution. By leveraging the capabilities of Yardi Voyager PHA software, the Housing Authority will enhance its ability to document, track, and monitor the review process for program income calculations, thereby strengthening internal controls and ensuring compliance with 2 CFR 200.303(a).

View Audit 293405

Finding 372081 (2023-002)

Significant Deficiency 2023

University of the Pacific

CA

Reporting Student Financial Aid Significant Deficiency

Pacific understands finding #2023-002 and we agree that the University will enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement. Finding #2023-001 Action: The University notes that in the fall of 2022, there were students wh...

Pacific understands finding #2023-002 and we agree that the University will enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement. Finding #2023-001 Action: The University notes that in the fall of 2022, there were students whose Pell Grant disbursements were not reported within the 15-day requirement to the Common Origination and Disbursement (COD)system. A Banner system issue allowed the origination of the Pell Grant to be sent to COD, however the disbursements were not. There was no indication this was occurring. To prevent future instances of late Pell Grant reporting, we will take the following action, effective February 6, 2024: • Adding an internal reconciliation component to the 10 day Pell Grant processing reminder • Reconciliation will be completed by the Assistant Director of Financial Aid, Operations of Analytics • Reconciliation will be reviewed and approved by Senior Assistant Director of Financial Aid, Operations and Analytics or Director of Financial Aid, Operations and Analytics Person(s) responsible: Aquila Galgon | Assistant Vice President of Financial Aid and Enrollment Strategy

View Audit 293358

Finding 372080 (2023-001)

Significant Deficiency 2023

University of the Pacific

CA

Reporting Significant Deficiency Internal Control / Segregation of Duties

Pacific understands finding #2023-001 and although the University failed to post the HEERF quarterly reports on its website by the required dates, the reports have been posted and will remain available for any interested parties to view through June 30, 2025. Finding #2023-001 Action: The university...

Pacific understands finding #2023-001 and although the University failed to post the HEERF quarterly reports on its website by the required dates, the reports have been posted and will remain available for any interested parties to view through June 30, 2025. Finding #2023-001 Action: The university notes that throughout the two years that HEERF was available it maintained an active application process which was published on its website through which students could submit applications to request funding. Thus, although the quarterly reports should have been made available, we do not believe that any students were harmed by their absence. The university’s HEERF allocation for students was fully expended as of June 30, 2023, thus no further corrective action is required to resolve this funding. Person(s) responsible: Aquila Galgon | Assistant Vice President of Financial Aid and Enrollment Strategy

View Audit 293358

Finding 372076 (2023-001)

Significant Deficiency 2023

Town of Boylston

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2024 ...

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2024 Contact: April Steward, Town Administrator

View Audit 293355

Finding 372054 (2023-001)

Significant Deficiency 2023

Central Methodist University

MO

Reporting Significant Deficiency

Description of Finding: The University publicly posted the required institutional reports for HEERF to their website using actual grants disbursed to student data, rather than disbursement only reimbursed by the G5 drawn downs during the quarters. No other issues were noted with the accuracy of th...

Description of Finding: The University publicly posted the required institutional reports for HEERF to their website using actual grants disbursed to student data, rather than disbursement only reimbursed by the G5 drawn downs during the quarters. No other issues were noted with the accuracy of the reports. Statement of Concurrence or Nonconcurrence: Management agrees the reports were incomplete due to lack of uncertainty with the HEERF reporting requirements and the disbursements made in the current accounting system. The previous year Finding for 2022 was noted to the institution after the 2023 quarter in question was over and resulted in a continuing comment. Corrective Action: Management will adjust reports noting the required quarterly reports on the website and only use quarterly funds received for providing all of the student report information for HEERF. Name of Contact Person: Julee Sherman, VP for Finance and Administration, Fayette MO 660-248-6203 Projection Completion Date: May 2024

View Audit 293308

Finding 372052 (2023-001)

Significant Deficiency 2023

Rim of the World Unified School District

CA

Reporting Significant Deficiency

The financial records that supported our ESSER annual report were provided and maintained in accordance with our records retention policy. The district utilizes sources such as CASBO's records retention manual in determining how long to maintain documentation. When completing the 2022 annual ESSER r...

The financial records that supported our ESSER annual report were provided and maintained in accordance with our records retention policy. The district utilizes sources such as CASBO's records retention manual in determining how long to maintain documentation. When completing the 2022 annual ESSER report for resource codes 3213 and 3214, incorrect values were entered. The District considered this a typo and will utilize this information when completing future reports to lessen the chance of a reoccurrence.

View Audit 293299

Finding 371995 (2023-006)

Significant Deficiency 2023

Garrett-Evangelical Theological Seminary

IL

Student Financial Aid Allowable Costs / Cost Principles Reporting

Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "wi...

Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "withdrawn" as there is no option to confer in December (institutional policy). The student status is updated to "graduated" and reported to Clearinghouse in May when students are conferred. Contact person responsible for corrective action: Vince McGlothin-Eller, Registrar Anticipated Completion Date: 05/31/2024

View Audit 293235

Finding 371990 (2023-007)

Significant Deficiency 2023

Garrett-Evangelical Theological Seminary

IL

Student Financial Aid Eligibility Subrecipient Monitoring

Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. ...

Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. The Satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the Registrar and Financial Aid Director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the Financial Aid Director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar financial aid account. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 06/01/2024

View Audit 293235

Finding 371988 (2023-001)

Significant Deficiency 2023

Adams County Housing Authority

PA

HUD Housing Programs Reporting Significant Deficiency

Adams County Housing Authority 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN February 28, 2024 Adams County Housing Authority respectfully submits the following corrective action plan f...

Adams County Housing Authority 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN February 28, 2024 Adams County Housing Authority respectfully submits the following corrective action plan for the year ended on June 30, 2023 Cognizant or Oversight Agency for Audit: Section 8 Housing Choice Vouchers, CFDA #14 .871 Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: July 1, 2022 -June 30, 2023 The finding from June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Financial Statement Audit: NONE Findings and Questioned Cost- Major Federal Award Programs Audit # 2023-001- Significant Deficiency- Housing Assistance Payments Section 8 Housing Choice Vouchers , CFDA #14.871 Recommendation We recommend that the Authority implement additional review procedures over the HAP contract and documentation prior to or soon after the file is finalized. View of responsible officials and planned corrective action We agree that this compliance requirement is listed in the compliance supplement. We will implement additional review procedures to capture any missing information or errors in the reporting. Additional training has been provided to the HCV Staff. If the PA Housing Finance Agency has any questions regarding this plan, please call Adams County Housing Authority Executive Director, Stephanie Mcllwee at (717) 334-1518 . Stephanie Mcllwee Executive Director

View Audit 293233

Finding 371933 (2023-001)

Significant Deficiency 2023

Saint Joseph's Tower, INC

IN

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157)  Section 8 Housing Assistance Payments Program (ALN# 14.195) Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in, move out, and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024

View Audit 293201

Finding 371928 (2023-001)

Significant Deficiency 2023

East Detroit Area Non-Profit Housing Corporation

MI

Allowable Costs / Cost Principles Eligibility HUD Housing Programs

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of a sample of 6 tenant files, it was noted: 1. Two out of six instances where an EIV was not run for a tenant file within 90 days of move in; 2. One out of six instances where the incorrect tenant income was used to calculate the tenant assistance payment; 3. One out of six instances where a tenant moved out and the requested overages were not adjusted for the correct time period; In addition, procedures were not in place to document the applicants, admissions, and removals to and from the tenant waitlist. Effect. As a result of this condition, certain tenant files did not contain all required supporting documentation. In addition, employees did not follow HUD guideline procedures, and/or did not properly calculate the tenant subsidy in HUD Form 50059. While there were no significant differences in the amount of subsidies allowed compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. A tenant waitlist will be created and maintained. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024

View Audit 293198

Finding 371927 (2023-001)

Significant Deficiency 2023

Highland Area Non-Profit Housing Corporation

MI

Special Tests & Provisions Allowable Costs / Cost Principles HUD Housing Programs

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Deve...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Development Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of 12 monthly payments on the Project's HUD insured mortgage payable, that are due each fiscal year, 1 payment was late, resulting in a late fee. Effect. As a result of this condition, the mortgage was not paid on time. While there was ultimately payment of the delinquent monthly balance, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001 and has developed the following plan. Mortgage invoices are now sent to two accounts payable employees, as well as a monitored inbox, to ensure timely processing. Contact Person Responsible for This Corrective Action: David DeFrain Anticipated completion date: July 17, 2023

View Audit 293195

Finding 371926 (2023-001)

Significant Deficiency 2023

Orion Area Not-for Profit Housing Corporation

MI

Special Tests & Provisions Allowable Costs / Cost Principles HUD Housing Programs

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Deve...

March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Development Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of 12 monthly payments on the Project's HUD insured mortgage payable, that are due each fiscal year, 1 payment was late, resulting in a late fee. Effect. As a result of this condition, the mortgage was not paid on time. While there was ultimately payment of the delinquent monthly balance, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001 and has developed the following plan. Mortgage invoices are now sent to two accounts payable employees, as well as a monitored inbox, to ensure timely processing. Contact Person Responsible for This Corrective Action: David DeFrain Anticipated completion date: July 17, 2023

View Audit 293194

Finding 371921 (2023-007)

Significant Deficiency 2023

City of Albuquerque

NM

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking § 200.320

The City agrees with the finding. Over the past several years, the City has developed a significant number of guidance documents and trainings in the area of federal procurement. All of the guidance documents for Central Purchasing are housed in the Purchasing SharePoint site. The guidance and train...

The City agrees with the finding. Over the past several years, the City has developed a significant number of guidance documents and trainings in the area of federal procurement. All of the guidance documents for Central Purchasing are housed in the Purchasing SharePoint site. The guidance and training have in the past been directed at the members of the Purchasing Liaison User Group, but given the continued findings, the City intends to reach out to a much broader group to ensure compliance, including Directors, Deputy Directors, and program representatives. This will be complete by June 30, 2024.

View Audit 293176

Finding 371615 (2023-001)

Significant Deficiency 2023

Claremont Unified School District

CA

Eligibility HUD Housing Programs School Nutrition Programs

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutritio...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023

View Audit 293142

Finding 371412 (2023-001)

Significant Deficiency 2023

Independent School District No. 622

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 AND U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS ST...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 AND U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires Independent School District No. 622 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. The District did not have sufficient controls in place within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – The District’s Interim Director of Finance, Josh Anderson. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Interim Director of Finance, Josh Anderson, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 293089

Finding 371398 (2023-001)

Significant Deficiency 2023

The Foodbank of Monmouth and Ocean Counties, Inc. Dba: Fulfill

NJ

Reporting Significant Deficiency Internal Control / Segregation of Duties

SIGNIFICANT DEFICIENCY 2023-001 Internal Control over Compliance (Reporting) Recommendation: Management put processes in place to ensure timely preparation and review of required performance reports in accordance with the terms of the state grant award. Explanation of disagreement with audit findi...

SIGNIFICANT DEFICIENCY 2023-001 Internal Control over Compliance (Reporting) Recommendation: Management put processes in place to ensure timely preparation and review of required performance reports in accordance with the terms of the state grant award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: This was the only performance report that was not submitted timely (it was due October 2022) before a grant tracking system was deployed in December 2022. A grant management team comprised of key staff from each department (Development, Finance, Operations, and Programs) meet twice monthly to consider new grants and to review and track the progress of awarded grants. The team maintains a master list of restricted grants and each restricted grant is assigned a grant number that is recorded with associated revenue and expense transactions in the General Ledger. Department and Program codes have also been deployed, and depending on the restriction, these can be assigned to each grant to identify eligible expenses that can be subsequently assigned as grants are released. Name of the contact person responsible for corrective action: Andre Solomon, Vice President of Finance and Administration Planned completion date for corrective action plan: Completed

View Audit 293028

Finding 371396 (2023-001)

Significant Deficiency 2023

Brenau University

GA

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 6 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the University re...

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 6 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the University review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal Requirements. Persons Responsible for Corrective Action: Liz Force, University Registrar & Director of Records; Pam Barrett, Associate Vice President & Director of Financial Aid Planned Corrective Action: Brenau University contracts with the National Student Clearinghouse (NSC) to perform routine enrollment reporting required by Title IV Federal Student Aid regulations. The University's student information system contains a program designed to compile enrollment data for transmission to NSC in accordance with specifications provided by the National Student Loan Data System (NSLDS). We conducted a detailed review of the November 2022 NSLDS Reporting Guide and engaged the University's student information system vendor, who reviewed the current software logic and installed the modifications necessary to become compliant in this area. Anticipated Completion Date: November 7, 2023

View Audit 293023

Finding 371328 (2023-001)

Significant Deficiency 2023

Aleutian Pribilof Islands Association, Inc.

AK

Eligibility Significant Deficiency Internal Control / Segregation of Duties

We propose to implement the following actions to ensure this doesn’t happen again. a. Audit existing patient records and patient registrations to identify missing documentation. We will start with the oldest patient files that likely started off with paper charts prior to being on the centralized e...

We propose to implement the following actions to ensure this doesn’t happen again. a. Audit existing patient records and patient registrations to identify missing documentation. We will start with the oldest patient files that likely started off with paper charts prior to being on the centralized electronic health record system. We will audit for: proof of IHS benefits, official identification card or other proof of identification, as well as reviewing 3rd party payor sources. For any missing items, we will be sure to request those from the patients and/or parents, if a minor child. b. Monthly - double check new registrations and have our central registration perform audits on those for completion. c. Perform immediate training with the registration and front desk team; stressing the importance of documentation. Send registration lead and primary care administrator to the Alaska Native Tribal Health Consortium ‘s Alaska Statewide Tribal Business Office Conference for Billing and Coding and Outreach and Enrollment April 2-5, 2024. Adopt any missing best practices. d. Adopt signage for patients necessary to understand that if they don’t submit the required documentation, they will be expected to pay for services provided. e. Adopt monthly registration and scheduling meetings with the front desk team to ensure the above tasks are coming along and address any known issues with acquiring documentation. f. Transfer supervision of front desk employees from the Medical Director to the newly hired, Primary Care Services Administrator. Thank you for giving us the opportunity to address and correct this important issue and improve our processes. It’s always our intent to comply with our federal programs.

View Audit 292998

Finding 371253 (2023-006)

Significant Deficiency 2023

Mount Mercy University

IA

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations. Explanation of disagreement with audit finding: There is no...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University review its policies to ensure they follow Department of Education regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All 3 students were over-awarded due to outside scholarship funds they received. We did revise our policy to properly reflect the federal regulations for awarding outside scholarship funds against a student’s cost of attendance. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

View Audit 292961 Questioned Costs: $1

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