Corrective Action Plans

Finding 386522 (2023-002)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corre...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

View Audit 298830 Questioned Costs: $1

Finding 386517 (2023-001)

Significant Deficiency 2023

Howard County

MD

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

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was ...

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was focused on effectively managing the COVID funding during that time to help keep residents safely housed; therefore, the monitoring tasks for HOME-assisted TBRA were not completed as required. The Department is creating additional Standard Operating Procedures (SOPs) to ensure all steps are being taken to meet monitoring requirements, even if current personnel changes so the process can continue effectively and on time. Action taken in response to finding: The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). 1. Completion of a HOME/HOME-ARP Training Plan 2. Completion of a HOME/HOME-ARP Monitoring Completion Plan 3. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 4. Completion of an SOP for current and future continuity of function Regarding HOME-ARP funds: the rental units must comply with the same requirements as HOME per 24 CFR 92.251 for (a) new construction, (b)rehabilitation projects, (c)(1) and (2) acquisition of standard housing, (e) manufactured housing, and (f) on-going property condition standards. 1. These requirements are being added to the HOME/HOME-ARP Reports, as part of the Monitoring Completion Plan 2. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 3. Completion of an SOP for current and future continuity of function Name of contact person (s) responsible for the corrective action plan: Kim Zanti, Division Chief, Community Planning and Grants

View Audit 298820

Finding 386496 (2023-032)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the ALA staff recommendations. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386464 (2023-010)

Significant Deficiency 2023

State of Arkansas

AR

Subrecipient Monitoring Student Financial Aid Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: We agree with the auditor’s finding and recommendations, and the following corrective action will be taken to improve the situation: • The Director of Computing Services will oversee the review subsections of 16 CFR 314 to ensure complian...

Views of Responsible Officials and Planned Corrective Action: We agree with the auditor’s finding and recommendations, and the following corrective action will be taken to improve the situation: • The Director of Computing Services will oversee the review subsections of 16 CFR 314 to ensure compliance with requirements. o Perform a more thorough GLBA Risk Assessment, which will be used to improve the institution’s security policy and posture. This is outlined in 16 CFR 314(b). o Improve safeguards and more frequent testing to improve system security and threat transparency will be added, including email security and log file monitoring, in addition to other controls as outlined in 16 CFR 314(c) and (d). Several quotes have been acquired and are in the process of being reviewed. o Conduct a review of policies and training, as outlined in 16 CFR 314(e), and mitigate deficiencies in awareness training and policies. o Improve documentation around third-party service providers to ensure compliance with 16 CFR 314(f). o All response plans are to be reviewed and improved as needed because of the Risk Assessment and other monitoring activities to ensure appropriate activities are included and tested at regular intervals. o The institution will develop a compliance document to record efforts according to each section of 16 CFR 314, including those areas that are already compliant. It is the goal of SEARK College to remain in a state of continuous improvement and in compliance with required regulations. The Director of Computing Services will work with the Senior Leadership Team to ensure that appropriate resources are made available, and that activities occur in a timely manner. Anticipated Completion Date: The indicated reviews and assessments are already in progress, with a goal of June 30, 2024, to have fully integrated the stated improvements into our systems and procedures. Contact Person: Name: JoAnn Dupra Title: Director of Computing Services Agency: Southeast Arkansas College Address: 1900 Hazel St City, State, Zip: Pine Bluff, AR 71603 Phone Number: (870) 543-5993 Email Address: jdupra@seark.edu

View Audit 298801

Finding 386459 (2023-009)

Significant Deficiency 2023

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR...

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR 314 elements and financial aid data. As with our 2021 Risk Assessment, our plan will be reviewed and accepted by our Chancellor. We intend to have the Risk Assessment updated and reviewed by June 30, 2024. We will also coordinate the risks identified with the extensive list of controls and policies that currently protect student’s financial aid information. These include: Acceptable Use Policy_V7_3.pdf Antivirus and Malware Policy_V2_1.pdf Cloud Services Policy_V1_2.pdf Confluence Screenshots Of Contact Information For Critical Systems (1).pdf Data Classification Policy_V1_2.pdf Data Encryption Policy_V7_1.pdf Data Management Use Protection Policy_V7_2.pdf Data Protection Policy_V7_2 Data Protection Policy_V7_2.pdf Disaster Recovery Business Continuity System Recovery Prioritization List_V1_2.pdf Disaster Recovery Procedure_V1_5.pdf Drive Data Deletion Policy_V7_2.pdf E-Learning Policies_V7_1.pdf Email and Digital Communication Policy_V8_2.pdf Email and Digital Communication Policy_V8_2.pdf Employee Data Deletion Policy_V7_2.pdf Encryption of Sensitive Data on Transmission Policy_V7_2.pdf Faculty Senate Legislation Reference_V6.1.pdf Firewall Blacklist and Whitelist Policy_V7_2.pdf Firewall Management Procedure_V7_2.pdf GLBA Risk assessment.docx Incident Response and Forensic Analysis Procedures_V7_5.pdf IT Employee Departure Procedures_V7_2.pdf IT Security Awareness and Competencies Policy_V1_5.pdf IT Services System Administration Privileged Access Management Policy_V7_2.pdf IT System Backup Procedures_V7_2.pdf IT System Patching Process_V7_3.pdf Lab / Classroom Administrative Rights Exception Request_V6_1.pdf Local Firewall Procedures for Workstations and Mobile Devices_V7_2.pdf Log Review Policy_V2_1.pdf Mobile Device Security - Remote Email Destruction Process_V1_1.pdf Mobile Device Security Policy_V2_1.pdf Multi-factor Authentication - Information Technology Services - UA Little Rock.pdf Network Patching Process_V1_1.pdf PCI Compliance _ Training Policy_V7_2.pdf Physical Security Policy_V1_3.pdf Retention of Records Policies_V7_2.pdf Security and Incident Response Team Policy_V1_3.pdf Security and IT System Access Policy_V1_2.pdf Student Account Deletion Policy_V7_2.pdf System Log Requirements_V8_2.pdf UALR Change Management Policy 2.2.pdf Vendor Remote Access Policy_V1_1.pdf Vulnerability Scan Policy_V7_2.pdf Wireless Network Guest Security Policy_V1_1.pdf Wireless Security Policy_V1_2.pdf Workstation Administrative Rights Exception Request_V6_1.pdf Anticipated Completion Date: June 30, 2024 Contact Person: Name: Gerald J. Ganz, Jr. Title: Vice Chancellor for Finance & Administration Agency: University of Arkansas at Little Rock Address: 2801 S. University Avenue City, State, Zip: Little Rock, AR, 72204 Phone Number: 501-916-5622 Email Address: GJGanz@ualr.edu

View Audit 298801

Finding 386455 (2023-005)

Significant Deficiency 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the controls the ALA staff recommended. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386447 (2023-002)

Material Weakness 2023

Franklin County Medical Center, A Component Unit of Franklin Countyid

ID

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Corrective action planned: Utilize a CPA experienced with federal award to review and ensure compliance with grant proposals and activities. Anticipated completion date: April 30, 2024 Contact person responsible for corrective action: Jalen Tollefson, Grant Director

View Audit 298791 Questioned Costs: $1

Finding 386440 (2023-004)

Significant Deficiency 2023

T.a. Lawson State Community College

AL

Subrecipient Monitoring Reporting Significant Deficiency § 200.328

Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024

View Audit 298782

Finding 386431 (2023-003)

Significant Deficiency 2023

Elkhart and St. Joseph Counties Head Start Consortium

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports h...

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports have a documented, formal review of the reports before they are submitted to ensure the information submitted is accurate Anticipated Completion Date: April 2024

View Audit 298777

Finding 386404 (2023-001)

Significant Deficiency 2023

Municipality of San German

PR

Reporting Significant Deficiency

The Municipality of San Germán always issues the audit reports on time, the exception was on June 30, 2022 because this year the disaster of Hurricane Fiona passed for Puerto Rico. This complicated all the situation for the Municipality. For this year, the report will be filed on time.

View Audit 298745

Finding 386390 (2023-001)

Significant Deficiency 2023

Gleaners Food Bank of Indiana, INC

IN

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

U.S. Department of Agriculture 2023 - 003 Food Distribution Cluster – Assistance Listing No. 10.568, 10.569 Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Explanation of disagreement with audit finding: There i...

U.S. Department of Agriculture 2023 - 003 Food Distribution Cluster – Assistance Listing No. 10.568, 10.569 Recommendation: We recommend that Gleaners review its process and procedures to ensure all control sign-offs are maintained on receipts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the process and procedures with department manager and new staff. Management will follow up quarterly to verify the process is completed accordingly. Names of the contact persons responsible for corrective action: Tiffany Stead and Joseph Slater Planned completion date for corrective action plan: 10/1/2023.

View Audit 298731

Finding 386386 (2023-001)

Significant Deficiency 2023

Fairleigh Dickinson University

NJ

Student Financial Aid Special Tests & Provisions Reporting

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Stude...

Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Student Clearinghouse. To avoid any oversight in the future, the Office of Enrollment Services will enhance the edit report process and frequency. Effective immediately, the edit report will be generated every thirty days by the Compliance Officers to ensure all manual updates to a prior graduation are captured within the sixty-day requirement.

View Audit 298712

Finding 386309 (2023-005)

Significant Deficiency 2023

Marymount University

VA

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response ...

Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marymount University experienced high turnover in the Office of Financial Aid from the Director down to the counselor position in the 22-23 academic year. In that transition, Attain partners was contracted in late 2022 as interim staffing. For the one student in the finding that was found to have received a grade level 3 loan instead of level 2 based on the number of credits completed, research found that a rule setting in Ellucian Colleague caused the student to be auto-packaged at level 3 and it was accepted and disbursed in COD (Common Origination & Disbursement). Moving forward, Attain Partners will work with Marymount IT to update any rule settings to catch this issue and provide the Marymount Financial Aid office with internal controls that will catch any issues for the current aid year. Management notes that this issue arose due to a software programming error tied to an updated rule setting in Ellucian Colleague. Moving forward staff in Financial Aid will work in tandem with colleagues in Information Technology to review all updated rule setting in order to catch and address potential miscalculations. Name(s) of the contact person(s) responsible for corrective action: Meghan Sutton, Interim Director of Financial Aid, 703.284.1532 Planned completion date for corrective action plan: May 2024

View Audit 298705 Questioned Costs: $1

Finding 386305 (2023-004)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal...

Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds will be processed weekly allowing enough time to correct any errors before the end of the 14 day period. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: March 2024

View Audit 298705

Finding 386304 (2023-003)

Significant Deficiency 2023

Marymount University

VA

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

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were a result of data entry or date errors. Moving forward the Registrar's Office will have a second staff member review files prior to submission to ensure the accuracy of the submission to the National Student Clearinghouse. The Registrar's Office will notify Financial Aid of NSC submission dates so the FA team can verify accuracy in NSLDS. Name(s) of the contact person(s) responsible for corrective action: Dr. Meghan Arias, University Registrar, 703-284-1526 Planned completion date for corrective action plan: 3/24/24 - date of next file submission

View Audit 298705

Finding 386303 (2023-002)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement wi...

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Acquired Isora GRC, a software tool to facilitate and document compliance with GLBA requirements and the corresponding NIST 800-171 information security framework. Management has also created an Enterprise Risk Management Committee which will incorporate compliance with GLBA as a top priority. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan by June 1, 2024, including decision regarding use of a third party or in-house resources to perform the risk assessment. Completion of 90% of action plan items within one year.

View Audit 298705

Finding 386302 (2023-002)

Significant Deficiency 2023

Calaveras County Water District

CA

Subrecipient Monitoring Period of Performance Reporting § 200.344

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to th...

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to the pass-through agency within 90 days of the end of the period of performance so the pass-through agency could prepare the closeout reporting within 120 days of the end of the period of performance. Criteria: The Notice of Funding Opportunity indicates: “In addition, pass-through entities are responsible for closing out their subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials within 90 calendar days of the period of performance end date. When a subrecipient completes all closeout requirements, pass-through entities must promptly complete all closeout actions for subawards in time for the recipient to submit all necessary documentation and information to FEMA during the closeout of the prime award.” Cause: The District’s staff were waiting for a requested extension for the period of performance from the pass-through agency and assumed the closeout reporting would not be necessary. Effect: The District is not in compliance with the terms and conditions of the federal award. Recommendation: We understand the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Views of Responsible Officials and Planned Corrective Actions: As indicated in the recommendation, the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Furthermore, on March 22, 2024, the District heard from the pass-through agency that FEMA received the requested extension, and it is in the queue for final approval and signature. The corrective action has been completed.

View Audit 298704

Finding 386290 (2023-002)

Significant Deficiency 2023

University of Maine System

ME

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328 § 200.329

Higher Education Emergency Relief Funds – Assistance Listing No. 84.425 Recommendation: We recommend the University review their reporting procedures to ensure reports are being uploaded and submitted timely. University of Maine at Farmington Condition: During our testing of 11 quarterly reports, ...

Higher Education Emergency Relief Funds – Assistance Listing No. 84.425 Recommendation: We recommend the University review their reporting procedures to ensure reports are being uploaded and submitted timely. University of Maine at Farmington Condition: During our testing of 11 quarterly reports, it was noted that University of Maine at Farmington (UMF) had two reports of two sampled that were not submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The upcoming reporting requirements have been added to the calendar and invoicing spreadsheet of UMF’s Director of Finance. Additionally, due dates and requirements are noted by both UMF’s Chief Business Officer (CBO) and its Vice President for Student Affairs and Enrollment Management. The CBO will continue to perform a final review prior to submission. Name(s) of the contact person(s) responsible for corrective action: Kathleen Falco, Director of Finance for the University of Maine at Farmington Planned completion date for corrective action plan: Completed

View Audit 298686

Finding 386285 (2023-001)

Significant Deficiency 2023

University of Maine System

ME

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Data System (NSLDS) within the appropriate timeframe ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Data System (NSLDS) within the appropriate timeframe as required by regulations. University of Maine Condition: During our testing of 40 students, we noted that seven of the 17 University of Maine (UM) students tested had changes in enrollment status that were not reported in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will update its protocols for post-term reporting to the National Student Clearinghouse (NSC) each academic term to ensure students who have applied for graduation, and are pending final eligibility review, are assigned a withdrawn status until such time their degree(s) are conferred or they are reported as enrolled in a future term. Guidance received from the NSC School Operations team has been forwarded to UMS:IT, and steps to identify (or develop) and deploy the necessary reports are underway. The first round of updated reporting protocols are planned to take place in May 2024, for Spring 2024 graduation applicants. Name(s) of the contact person(s) responsible for corrective action: W. Sam Carrell, Registrar for the University of Maine Connie Smith, Director of Financial Aid for the University of Maine Planned completion date for corrective action plan: May 2024

View Audit 298686

Finding 386242 (2023-001)

Significant Deficiency 2023

Lansing Housing Commission

MI

HUD Housing Programs Eligibility Significant Deficiency

Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan...

Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan to audit internally 100 percent of all tenant files in our Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. The plan includes updating and automating files, identifying recurring compliance issues, and expanding formal training and specific training from the consultant. In addition, an additional level of review will be put in place to assist in catching any inconsistencies. The Commission has added additional employees to the LIPH program, which include an operations manager and a staff person. These additional resources will be incorporated into our overall plan to increase our compliance controls. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666

Finding 386240 (2023-002)

Significant Deficiency 2023

Lansing Housing Commission

MI

HUD Housing Programs Eligibility Significant Deficiency

Condition: For a sample of tenants, a recertification was not completed properly, resulting in an incorrect calculation of housing assistance payments to be received. Planned Corrective Action: The Commission acknowledges the incorrect subsidy calculations and has issued refunds to the tenants in th...

Condition: For a sample of tenants, a recertification was not completed properly, resulting in an incorrect calculation of housing assistance payments to be received. Planned Corrective Action: The Commission acknowledges the incorrect subsidy calculations and has issued refunds to the tenants in the amount of underpayment of subsidy. The Commission has also adjusted future funding requests for the overpayment of subsidy. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666

Finding 386223 (2023-001)

Significant Deficiency 2023

Rockingham Nutrition and Meals on Wheels Program

NH

Subrecipient Monitoring Reporting Significant Deficiency § 200.328 § 200.329

Audit Finding Reference: 2023-001 Improve Controls Over Reporting Planned Corrective Action: 1. Request a list from DHHS of definitions of income types by program in the Quarterly Reports. Ensure that this list provides clarity on how to report income that is not explicitly tied to a single progr...

Audit Finding Reference: 2023-001 Improve Controls Over Reporting Planned Corrective Action: 1. Request a list from DHHS of definitions of income types by program in the Quarterly Reports. Ensure that this list provides clarity on how to report income that is not explicitly tied to a single program. 2. Review AFY23 and AFY24-to-date reports against these criteria (once received), and re-submit any reports which may need to be modified to comply with the guidance. 3. Going forward, the Quarterly Reports will be generated differently. The Client Services Manager will prepare actuals by program for number of clients and units. The Director of Administration will prepare actuals by program for income and expense. The Executive Director will compile the final report, which will not be submitted until both the Client Services Manager and Director of Administration have both checked the reports and electronically signed them. In the absence of specific guidance from DHHS to the contrary, any non-program-specific income will be allocated to programs by share of service units delivered. Planned Implementation Date of Corrective Action: 1. 3/29/24. 2. 6/30/24. 3. 4/15/24. Person Responsible for Corrective Action: Tim Diaz, Executive Director

View Audit 298652

Finding 386208 (2023-001)

Significant Deficiency 2023

Lincoln County Board of Education

GA

Subrecipient Monitoring Reporting Special Tests & Provisions § 200.303

FA 2023-001 Strengthen Controls over Wage Rate Requirements Compliance Requirement: Special Tests and Provisions Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Departmen...

FA 2023-001 Strengthen Controls over Wage Rate Requirements Compliance Requirement: Special Tests and Provisions Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year: 2021) Questioned Costs: None Identified Prior Year Finding: Not Applicable Description: A review of construction-related expenditures charged to the Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating to ensure that Wage Rage Requirements were followed properly. Corrective Action Plans: The School District will review and update the current procedures to ensure that the Wage Rate requirements are met. Estimated Completion Date: June 30, 2024 Contact Person: Dr. Samuel P. Light, Superintendent Telephone: (706) 359-3742 Email: slight@lcboe.us

View Audit 298629

Finding 386207 (2023-002)

Significant Deficiency 2023

City of Worcester, Massachusetts

MA

Reporting Significant Deficiency Internal Control / Segregation of Duties

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Head Start Program – Assistance Listing Number 93.600 Recommendation: We recommend procedures be implemented to file all required reports timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Head Start Program – Assistance Listing Number 93.600 Recommendation: We recommend procedures be implemented to file all required reports timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program management has begun the process of strengthening procedures to timelier file all reports. Name(s) of the contact person(s) responsible for corrective action: Program management. Planned completion date for corrective action plan: As soon as possible.

View Audit 298624

Finding 386191 (2023-004)

Significant Deficiency 2023

Wyandanch Union Free School District

NY

Special Tests & Provisions Reporting Significant Deficiency

The District agrees with the finding. The District's Registration and Attendance apparatus is undergoing a "makeover" as we speak under the guidance of the Superintendent of Schools such that this will not be a finding going forward.

View Audit 298617

Corrective Action Plans

Filters