Corrective Action Plans

Finding 376125 (2023-055)

Significant Deficiency 2023

VA

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: The vendor started the security audit in September 2023 and completed in December 2023. The report was sent to DMAS in February 2024. Next steps- The report needs to be reviewed and the Contract Administ...

Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: The vendor started the security audit in September 2023 and completed in December 2023. The report was sent to DMAS in February 2024. Next steps- The report needs to be reviewed and the Contract Administrator will work with the vendor to ensure Plan of Action and Milestones (POAMs) are completed to address the risks and control gaps. The Contract Administrator will monitor the vendor to ensure the vendor meets to terms of the contract and submits a security audit every two years. Estimated Completion Date: 6/30/2024

View Audit 295106

Finding 376123 (2023-051)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties § 200.303

Responsible Contact Person(s): David Clark, Information Security Officer Corrective Action Planned: The Information Security Unit has documented a process for the types of changes that trigger a security impact analysis (SIA) as well as a request form for a security impact review. Part of the SIA pr...

Responsible Contact Person(s): David Clark, Information Security Officer Corrective Action Planned: The Information Security Unit has documented a process for the types of changes that trigger a security impact analysis (SIA) as well as a request form for a security impact review. Part of the SIA process will be to determine if pre-implementation testing is required. The Information Security Unit will retain documentation in accordance with the Configuration Management Policy. Once the processes are further defined, the Information Security Unit will update the Configuration Management Policy & Procedures. Estimated Completion Date: 3/31/2024

View Audit 295106

Finding 376120 (2023-049)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties § 200.303

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Fede...

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 6/30/2024

View Audit 295106

Finding 376117 (2023-043)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Melinda Raines, Director of Human Resources Karen Holt, Human Resources Business Process Consultant Corrective Action Planned: An agency-wide work group will be estab...

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Melinda Raines, Director of Human Resources Karen Holt, Human Resources Business Process Consultant Corrective Action Planned: An agency-wide work group will be established to determine the exact processes need to implement the controls necessary to address this finding. HR and ISRM have identified the need for new reporting and interfaces to regain compliance. DSS had deployed DOA human capital management system and an internal system that will need to have interfaces developed. Estimated Completion Date: 6/30/2024

View Audit 295106

Finding 376114 (2023-036)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs HUD Housing Programs Significant Deficiency § 200.303

Responsible Contact Person(s): Mike Jones, Chief Information Officer Steve Hanoka, Chief Information Security Officer Corrective Action Planned: The 2023 Annual Access Review for the claims processing system through secure web application surveys began in the 4th Quarter 2023. Three separate surve...

Responsible Contact Person(s): Mike Jones, Chief Information Officer Steve Hanoka, Chief Information Security Officer Corrective Action Planned: The 2023 Annual Access Review for the claims processing system through secure web application surveys began in the 4th Quarter 2023. Three separate surveys were sent to perform access review for DSS, Contractor and DMAS Internal access review. • DSS annual review sent on November 9, 2023 and ended on November 20, 2023 • Contractor review sent on November 30, 2023 and ended on December 15, 2023 • DMAS review sent on December 15, 2023 and ended on January 13, 2024 All 3 surveys requested managers to review their employees access and confirm if it was required or if the access should be revoked. Survey results are available to perform follow up actions. DMAS Security is currently reviewing the survey results and revoking access where requested. Estimated Completion Date: 6/30/2024

View Audit 295106

Finding 376111 (2023-035)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Eligibility HUD Housing Programs § 200.303

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Steve McCauley, Assistant Division Director Corrective Action Planned: DSS will perform an annual access review of user accounts for the case management system. Estim...

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Steve McCauley, Assistant Division Director Corrective Action Planned: DSS will perform an annual access review of user accounts for the case management system. Estimated Completion Date: 12/31/2024

View Audit 295106

Finding 376108 (2023-034)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Internal Control / Segregation of Duties Questioned Costs Eligibility § 200.303

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Kavansa Gardner, Information Technology Manager Corrective Action Planned: DSS will perform and document a conflicting access review for the case management system to identify the combinations of roles that could pose separat...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Kavansa Gardner, Information Technology Manager Corrective Action Planned: DSS will perform and document a conflicting access review for the case management system to identify the combinations of roles that could pose separation of duties conflicts and ensure compensating controls are in place to mitigate risks arising from those conflicts. Additionally, DSS will work with a vendor to update the role-based security access documentation to reflect all system changes from prior case management system related releases when there are proposed changes to the roles matrix. Estimated Completion Date: 12/31/2024

View Audit 295106

Finding 376080 (2023-022)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Subrecipient Monitoring Significant Deficiency § 200.303

Responsible Contact Person(s): Diane Carnohan, Chief Information Security Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virg...

Responsible Contact Person(s): Diane Carnohan, Chief Information Security Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 12/31/2024

View Audit 295106

Finding 376077 (2023-015)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Subrecipient Monitoring Significant Deficiency § 200.303

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Fede...

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 12/31/2024

View Audit 295106

Finding 376074 (2023-014)

Significant Deficiency 2023

Commonwealth of Virginia

VA

Questioned Costs Subrecipient Monitoring Significant Deficiency § 200.303

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Kevin Platea, Chief Information Officer Corrective Action Planned: To improve the governance structure of the agency, ISRM Division Leadership is working with a vendo...

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Kevin Platea, Chief Information Officer Corrective Action Planned: To improve the governance structure of the agency, ISRM Division Leadership is working with a vendor to address the division’s responsibility around defining and communicating the Security and Risk Management program. The goal is to educate the agency System Owners, Data Owners, System Administrators, System User, and Data Custodians as to their roles and responsibilities in managing risk associated with agency data and systems. The Division of ISRM will deliver System Owner training to the Agency Executive Team in April in support of the Commonwealth’s requirement that System Owner’s manage risks associated with their systems. This training will also highlight the importance of Configuration Management and Software and Service Acquisition. The Division of ISRM will also construct and offer training on Configuration Management and Software and Service Acquisition to whichever resources the Agency identifies to own such related processes. The training will be ready to be provided no later than August 1, 2023. Estimated Completion Date: 12/31/2023

View Audit 295106

Finding 376043 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of York

SC

HUD Housing Programs Significant Deficiency Special Tests & Provisions

2023-002 Special Tests and Provisions – Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-0...

2023-002 Special Tests and Provisions – Income Targeting Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-002 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition The Authority did not have adequate controls over income targeting to assure that the Authority is in compliance with this requirement. During our testing, we noted that tenants with incomes that were extremely low accounted for approximately 70% of new admissions during the fiscal year, which is below the minimum required percentage of 75%. Recommendation We recommend the Authority assure that at least 75% of new admissions be in the extremely low-income bracket. This should be monitored throughout the year. The Authority can also select applicants on the waiting list who are extremely low income by bypassing others on the list that don’t meet the requirement and documenting that the person was selected ahead of others to be able to meet the requirement Action Taken: We concur with this finding. We will closely monitor new admissions and focus on applicants on the waiting list who meet the criteria as extremely low income so that the 75% requirement is met. Our lease rate has been decreasing due to a decrease in availability in our area. We have been issuing vouchers every month and have little to no wait on our waiting list. We are also accepting applications every week. We have been unable to exclude persons due to the extremely low-income bracket requirement because we are trying to increase the overall utilization in our voucher program. We have submitted a request to HUD to allow an exception to the income targeting rule and are currently awaiting a response. Effective Date: February 29, 2024 Contact Information Jenny Hammond, Executive Director Housing Authority of the City of York 221 California Street York, SC 29745 (803) 684-7359

View Audit 295068

Finding 376042 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of York

SC

HUD Housing Programs Eligibility Significant Deficiency

Finding No. 2023-001 Eligibility – Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001...

Finding No. 2023-001 Eligibility – Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition Out of a total tenant population of approximately 194 vouchers, 20 files were selected for testing. Exceptions were noted as follows: • 1 file where a math error on zero-income calculation resulted in an increase in HAP rent from $709 to $712. • 1 file where a math error on zero-income calculation resulted in a decrease in HAP rent from $961 to $912. • 1 file where social security income was calculated using 2022 amounts despite move-in date in February 2023. As a result, HAP rent decreased from $561 to $546. • 1 file where social security income was calculated using 2022 amounts despite annual re-exam in February 2023. As a result, HAP rent decreased from $709 to $687. In addition to the above, during our new admissions testing (5 tested out of 44 new admissions) we noted the following: • 1 file that did not contain a signed lease agreement. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken We concur with this finding and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented.

View Audit 295068

Finding 376036 (2023-002)

Significant Deficiency 2023

Grand Rapids Community College

MI

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

Condition: The College did not have a control in place to ensure all returns of Title IV refunds were reviewed. As a result, certain student Title IV refund calculations were not correctly calculated and returned.. Planned Corrective Action: • GRCC updated its R2T4 procedure document to highlight t...

Condition: The College did not have a control in place to ensure all returns of Title IV refunds were reviewed. As a result, certain student Title IV refund calculations were not correctly calculated and returned.. Planned Corrective Action: • GRCC updated its R2T4 procedure document to highlight the steps needed to be taken so that bookstore charges are handled correctly in the R2T4 calculation. • GRCC provided updated training to the current employees who handle the R2T4 process. • GRCC reviewed all of the R2T4s in which students had bookstore charges. The results were as follows: oTotal number of students: -Fall -- 103 students reviewed; 61 corrections made -Winter -- 83 students reviewed; 5 corrections made o Total amount of adjustments: -Fall = $13,372 -Winter = $1,362 • GRCC reviewed all unofficial withdrawals during fiscal year 2023 adn matched them with R2T4's where required. Once correction was made for $558. This is the same error noted in teh finding. • During the 2023-2024 year (fiscal year 2024), GRCC is performing a 100% review of the R2T4s that have bookstore charges. While performing the review of the bookstore charges, we are reviewing the entire R2T4, not only whether bookstore charges are correctly included. By doing so, we can ensure that the entire process is performed accurately. • Additionally, GRCC will be conducting R2T4 training each semester by way of ensuring that staff who perform the calculations understand the process and the specific steps needed to complete the calculations. Contact person responsible for corrective action: David DeBoer, Executive Director of Financial Aid Anticipated Completion Date: 12/02/2023

View Audit 295065 Questioned Costs: $1

Finding 376021 (2023-002)

Significant Deficiency 2023

Readyct, Inc.

CT

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.414

2023-002 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review and follow the indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Explanation of disagreement with audit finding: ...

2023-002 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review and follow the indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of updating it’s calculation of indirect costs to be in compliance with the indirect cost rate guidance set out at 2 CFR section 200.414 within Uniform Guidance. Name of the contact person responsible for corrective action: Shannon Marimón Planned completion date for corrective action plan: February 29, 2024

View Audit 295043 Questioned Costs: $1

Finding 376019 (2023-001)

Significant Deficiency 2023

Readyct, Inc.

CT

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency § 200.318 § 200.326

2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreem...

2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of enhancing the federal procurement policy to include sections 200.318 through 200.326. Name of the contact person responsible for corrective action: Shannon Marimón Planned completion date for corrective action plan: February 29, 2024

View Audit 295043

Finding 376018 (2023-001)

Significant Deficiency 2023

Gwynedd Mercy University

PA

Student Financial Aid Reporting Significant Deficiency

Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forw...

Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported. In addition, the registrar has updated their process notes which are used each time they pull the report. Responsible Individual for Corrective Action: Registrar - Joanna Raudenbush Anticipated Completion Date: December 31, 2023

View Audit 295042

Finding 376000 (2023-001)

Significant Deficiency 2023

El Camino Community College District

CA

Questioned Costs Student Financial Aid Significant Deficiency

2023-001: Student Financial Aid Cluster - Return to Title V Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed R...

2023-001: Student Financial Aid Cluster - Return to Title V Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed Return to Title IV calculations are properly completed. Action taken in response to finding: The Financial Aid office is implementing the following steps to ensure all Return to Title IV calculations are properly completed: To improve our process, a Return of Funds Calculation report is in place to assist with monitoring the return of unearned aid the Department of Education within 45 days of determination. An additional staff member has been assigned to the Return of Title IV program. We now have two staff members processing Return to Title IV calculations and each will be required to complete R2T4 training on an annual basis. The first staff member is assigned with the review of Return to Title IV calculations, while the second will conduct a secondary review for any miscalculation or data entry error. Thus, each Return to Title IV calculation will be checked by two staff members for accuracy. We will have an additional staff member help with the return of funds to COD to meet the 45-day rule; this will be on the accounting side. Our final step includes management review of Return to Title IV calculations. These added redundancy review will confirm Return to Title IV calculations are accurate. Our Return to Title IV procedures have been updated to reflect these changes. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 2024

View Audit 295017

Finding 375941 (2023-002)

Significant Deficiency 2023

Corban University

OR

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: (Corban will proceed with the documentation of information security program policies and practices. Additionally, with the expansion of Corban’s partnership with third party partners, it will more than adequately address all matters...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: (Corban will proceed with the documentation of information security program policies and practices. Additionally, with the expansion of Corban’s partnership with third party partners, it will more than adequately address all matters of Gramm-Leach-Bliley Act (GLBA) Compliance, especially training, and reduce the potential for unintended exposure of information. Person Responsible for Corrective Action Plan: Tom Cornman, Senior Vice President & Provost Anticipated Date of Completion: April 30, 2024

View Audit 294999

Finding 375935 (2023-001)

Significant Deficiency 2023

Downey Unified School District

CA

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

The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with...

The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with the new student database management software system (Campus Café). The new student database management software system together with National Student Clearinghouse will help to prevent human errors and omissions from occurring when reporting National Student Loan Data System (NSLDS) data. While the district purchased the new system in November of 2022, the school did not begin using the new system(s) until August of 2023 because the switch had to be implemented at the beginning of the fiscal year. Implementation is a several month process and all DAS employees have been receiving extensive training (ongoing) to be proficient and comfortable with the new system(s). We have ongoing weekly training for all DAS staff as we continue to fully implement the new student database management software system.

View Audit 294996

Finding 375888 (2023-001)

Significant Deficiency 2023

City of Haverhill

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 10...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the 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—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

View Audit 294969

Finding 375803 (2023-004)

Significant Deficiency 2023

Eastern Wyoming College

WY

Questioned Costs Subrecipient Monitoring Significant Deficiency

Corrective actions: As a result of a cyber-event in 2021 and a program review conducted by the U.S. Department of Education, EWC initiated a comprehensive assessment of information technology and security to ensure compliance with the Gramm-Leach-Bliley Act (GLBA) and industry protocols. EWC hired a...

Corrective actions: As a result of a cyber-event in 2021 and a program review conducted by the U.S. Department of Education, EWC initiated a comprehensive assessment of information technology and security to ensure compliance with the Gramm-Leach-Bliley Act (GLBA) and industry protocols. EWC hired an educational law firm, Parker & Poe and Associates, to evaluate and prepare policies in accordance with legal requirements. These policies, Board Policies 7.0 through 7.5 (as renumbered), have been reviewed within the College administration and presented to the Board of Trustees for first reading in October 2023. EWC anticipates the final approval and adoption will occur on December 12, 2023. Additionally, EWC foresees finalizing supporting administrative regulations on or before December 31, 2023. The policies and regulations are designed to ensure a comprehensive information security plan and GLBA compliance while meeting the requirements of the U.S. Department of Education. Anticipated completion dates: December 12, 2023 (Policies) and December 31, 2023 (Regulations) Contact person: Vice President Administrative Services - Patrick Korell

View Audit 294893

Finding 375802 (2023-003)

Significant Deficiency 2023

Eastern Wyoming College

WY

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Corrective actions: In September 2023, EWC Financial Aid implemented a permanent fix utilizing the Colleague Process Handler, which automates disbursement notifications. The automated disbursement process is set to run weekly and ensures time sensitive acknowledgement to aid recipients. Completion d...

Corrective actions: In September 2023, EWC Financial Aid implemented a permanent fix utilizing the Colleague Process Handler, which automates disbursement notifications. The automated disbursement process is set to run weekly and ensures time sensitive acknowledgement to aid recipients. Completion date: September 2023 Contact person: Director of Financial Aid - Rebecca McAllister

View Audit 294893

Finding 375801 (2023-002)

Significant Deficiency 2023

Eastern Wyoming College

WY

Student Financial Aid Reporting Significant Deficiency

Corrective actions: EWC Financial Aid actively addressed the issue of awards not showing in the Common Origination and Disbursement (COD) system. EWC has implemented a new process utilizing the Colleague Transfer Monitoring system to ensure NSLDS accepts the NSC enrollment information. In the event ...

Corrective actions: EWC Financial Aid actively addressed the issue of awards not showing in the Common Origination and Disbursement (COD) system. EWC has implemented a new process utilizing the Colleague Transfer Monitoring system to ensure NSLDS accepts the NSC enrollment information. In the event that EWC’s HCM2 status prevents automatic reporting, EWC Financial Aid will update NSLDS monthly. Completion date: October 2023 Contact person: Financial Aid Director - Rebecca McAllister ________ Student with reported program length: EWC has set internal controls to ensure the proper settings within Colleague are selected, including setting years as a default instead of months. EWC Financial Aid and EWC Academic Services will review and evaluate each program and ensure that the proper default is selected to ensure accurate program reporting. Anticipated completion date: December 2023 Contact people: Financial Aid Director - Rebecca McAllister and Admin. Specialist - Lynn Wamboldt _________ Students with a program date from Colleague that did not match NSLDS: The Colleague student-information system will be updated to define the parameter of start date as the first day of each semester. This software patch will ensure Colleague matches the reporting parameters utilized by NSLDS. Anticipated completion date: January 2024 Contact people: Data Analyst - Xi Feng and CIO -Tyler Vasko

View Audit 294893

Finding 375720 (2023-001)

Significant Deficiency 2023

State Center Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 speciali...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 specialist in financial aid will review student accounts that require R2T4 calculations on a weekly basis. The students will be posted to the shared database between Financial Aid and the Business Office. The dedicated weekly time will expedite the calculation process. The Business Office, as part of the updated process will continue to treat the R2T4 award adjustments as a priority. In addition to the existing process of end of month reconciliation and return of funds, a mid-month returning of funds was added and implemented. The dedicated weekly timeline to calculate, as well as the added mid-month return of funds, will ensure that we meet the required return of funds within the 45-day window. The offices will meet to review this updated process and make any additional changes should they be necessary to maintain compliance. Calculations - To ensure compliance with calculations processed timely, we will relieve the R2T4 specialist of other responsibilities so he can dedicate 100% of his time to calculate within the required timeframe. In addition, there will be additional staff assisting with calculations because the institution closes for a 10- day period which impacts the 30-day timeframe. This will ensure that all calculations are done. Implementation Date: 11/15/2023

View Audit 294788

Finding 375713 (2023-001)

Material Weakness 2023

Housing Authority of the County of Santa Cruz

CA

Questioned Costs HUD Housing Programs Eligibility

The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Develo...

The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Catalog Numbers: 14.871 and 14.879 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers Program - No Mainstream Vouchers Program - Yes Material Weaknesses in Internal Control over Compliance for Eligibility for the Mainstream Vouchers Program Significant Deficiency in Internal Control over Compliance for Eligibility Section 8 Housing Choice Vouchers Program Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 5,295 units. Of a sample size of seventy-one (71) tenant files, the following was noted: • HUD 9886 Form was missing in 1 file • Annual HUD 50058 recertification form and related verification of income and assets was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: • Mainstream Vouchers $19,830 • Section 8 Housing Choice Vouchers Program $1,875 Cause: There is a significant deficiency in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Section 8 Housing Choice Vouchers Program. There is a material weakness in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Mainstream Vouchers Program. The Authority has not properly maintained tenant files in compliance with program requirements following the expiration of HUD waivers. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. The Mainstream Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced a large backlog of reexaminations along with higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management developed and implemented a plan to rapidly work through the backlog, and has made significant progress to bring the program into compliance. The audit resulted in one missing consent form (HUD 9886), and one re-examination (HUD 50058), which is noted as missing. While the consent form had expired and a new consent form was required during the audit period, the income information collected for the household was collected while the consent form was still valid. With regards to the re-examination noted as missing, this re-examination was performed late, having been completed just six days after the end of the audit period. The re-examination was initiated on time, and the delay in completing the re-examination was caused by the program participant’s delay in providing the required documents. Additionally, the Authority has been selected for participation in the Moving to Work program ('MTW'). Alternative re-examination schedules, including biennial re-examinations, are an approved MTW activity allowable through the MTW Operations Notice. The Authority has received HUD approval of a waiver that allows the use of an alternate re-examination schedule effective July 1, 2023. This re-examination schedule is in effect currently and will be in effect for the entire duration of the subsequent audit period. Based on the transition to biennial and triennial re-examinations, the Authority has already come into compliance with timely recertifications. Further, the Authority management is in the process of implementing enhanced Quality Control procedures, with staff to conduct ongoing internal audits over the course of the year. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Aaron Pomeroy, Finance Director at 831-454-5908.

View Audit 294774 Questioned Costs: $1

Corrective Action Plans

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