Corrective Action Plans

Finding 523032 (2024-005)

Significant Deficiency 2024

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Performing training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with aud...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Performing training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the current year required Surplus Cash deposit of $10,079 immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

View Audit 342295

Finding 523030 (2024-003)

Significant Deficiency 2024

Brook View Gardens, Inc. 042-Hd087

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Recommendation: Procedures should be implemented to ensure a timeline with documentation of required deposit to the Residual Receipts account based on prior year audited financial statements surplus cash calculation. We also recommend the surplus cash amount of $36,710 calculated at June 30, 2024 be...

Recommendation: Procedures should be implemented to ensure a timeline with documentation of required deposit to the Residual Receipts account based on prior year audited financial statements surplus cash calculation. We also recommend the surplus cash amount of $36,710 calculated at June 30, 2024 be deposited immediately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will implement a documented timeline to ensure proper and timely deposit of surplus cash to the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

View Audit 342295

Finding 523028 (2024-002)

Significant Deficiency 2024

Brook View Gardens, Inc. 042-Hd087

OH

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Reserve for Replacement Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with ...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Reserve for Replacement Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately and adjust future deposits to correct amount. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

View Audit 342295

Finding 523026 (2024-002)

Significant Deficiency 2024

Bridge Point Senior Village, Inc. 042-Ee259

OH

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. We also recommend the amount of $564 be deposited imm...

Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. We also recommend the amount of $564 be deposited immediately into the Replacement for Reserve Account. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

View Audit 342294

Finding 523024 (2024-002)

Significant Deficiency 2024

Mater Academy of Nevada

NV

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be ...

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2025

View Audit 342290

Finding 522810 (2024-002)

None 2024

Bear River Association of Governments

UT

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Bear River Association of Governments will enter into general depository agreements with their financial institutions and will maintain copies of said agreements in their internal HUD files.

View Audit 342184

Finding 522789 (2024-001)

Significant Deficiency 2024

Bay Mills Community College

MI

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

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Bay Mills Community College Single Audit report for the year ended June 30, 2024, and corrective actions to be completed. 2024-001 – Status Change Reporting Issues. Au...

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Bay Mills Community College Single Audit report for the year ended June 30, 2024, and corrective actions to be completed. 2024-001 – Status Change Reporting Issues. Auditor Description of Condition and Effect. During our testing of the Pell Grant program, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Of the forty tested, nine were out of compliance based on the criteria outlined in the Department of Education's Code of Federal Regulations at 34 CFR 690.83(b)(2). As a result of this condition, the NSLDS system may not be updated with correct student information, which may cause subsequent awarding issues or loan repayment discrepancies. Auditor Recommendation. We recommend that the College establish a withdrawal policy to improve the accuracy of status change reporting. We also recommend enhanced processes for reviewing and verifying the accuracy of data submissions to NSLDS. Corrective Action. The College has implemented an Administrative Withdrawal Policy, approved by the Board of Regents on November 15, 2024. This policy will enhance the identification and reporting of students who cease attending classes. Additionally, the College will receive a Roster Response file from the National Student Clearinghouse, containing the full dataset sent to NSLDS, which will be reviewed for accuracy. Responsible Person. Katie Corbiere, Director of Financial Aid. Anticipated Completion Date. June 30, 2025

View Audit 342163

Finding 522752 (2024-002)

Significant Deficiency 2024

Mary Hall Freedom Village, Inc.

GA

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Significant Deficiency § 200.303

As per the Organization's policies and procedures on invoice approval, the Fiscal Director has assumed the responsibility of ensuring that all invoices are approved by the department head and himself before payment is initiated

View Audit 342131

Finding 522751 (2024-001)

Significant Deficiency 2024

The Housing Authority of the City of Auburn, Alabama

AL

Questioned Costs HUD Housing Programs Eligibility

A. Finding Finding 2024-001: Moving to Work Resident Files - Eligibility- Rent Calculations & HAP Disbursements Noncompliance & Significant Deficiency -ALN #14.881 B. Condition & Cause Twenty (20) HCV tenant-based resident files and twenty (20) HCV project-based resident files were reviewed for a t...

A. Finding Finding 2024-001: Moving to Work Resident Files - Eligibility- Rent Calculations & HAP Disbursements Noncompliance & Significant Deficiency -ALN #14.881 B. Condition & Cause Twenty (20) HCV tenant-based resident files and twenty (20) HCV project-based resident files were reviewed for a total of forty (40) Moving to Work resident files reviewed. In the TBV file review, one (1) instance of a resident's income being miscalculated on HUD form 50058 was noted. The Authority understated the resident's income which resulted in a lower rent charge amount than expected. Also in the TBV file review, one (I) instance of the Authority issuing a double payment of HAP funding to a landlord was noted. The total amount of the overpayment was $2,006 which has since been requested back from the property owner. C. Background Information Due to organizational restructuring, the HCV Manager moved to the Multi-family Housing department and the new HCV Manager was an internal promotion from within the HCV Department leaving a vacancy in the PBV Caseworker position. In addition, the TBV Caseworker resigned in November 2023 and was replaced by a new staff member in December 2023. The HCV application/in-take position also had turnover during the fiscal year, resulting in a relatively inexperienced HCV staff for a significant portion of the fiscal year. Due to the new staff, HCV has devoted significant resources to train new staff and implement internal control measures to minimize non-compliance and reduce errors; however, the process is still ongoing and will be continually evaluated and adjusted to ensure compliance with HUD's regulatory requirements. D. Controls to Correct the Deficiency In an effort to correct the finding noted above, the Auburn Housing Authority (AHA) has implemented and/or will implement the following by FYE2025: a. HCV Manager will perform a comprehensive audit of tenant files for existing tenants to identify any additional deficiencies and assess the need for staff training. b. HCV Manager will perform monthly file reviews on all recertifications completed during FYE2025 to identify rent calculation errors and compliance issues and assess the need for staff training. c. During FYE2025, the Chief Operating Officer (COO) will perform quality controls by randomly selecting departmental files for review. d. To eliminate HAP Disbursement Errors, monthly HAP Requests will be prepared by the Caseworker and reviewed by the IICV Manager and COO prior to submission to the Chief Executive Officer (CEO) for final review and approval. e. Other internal control measures to eliminate future audit findings. E. Person Responsible: Sharon N. Tolbert, CEO F. Anticipated Completion Date: June 30, 2025

View Audit 342124 Questioned Costs: $1

Finding 522695 (2024-001)

Significant Deficiency 2024

South Carolina Regional Housing Authority No. 3

SC

HUD Housing Programs Eligibility Significant Deficiency

Finding 2024-001 – Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility- Noncompliance & Significant Deficiency Corrective Action Plan: We are using the recommendations provided by the auditor's and are changing our file check list so that the EIV report will be i...

Finding 2024-001 – Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility- Noncompliance & Significant Deficiency Corrective Action Plan: We are using the recommendations provided by the auditor's and are changing our file check list so that the EIV report will be included in all the necessary check list. Also, the HA staff will use hierarchy for documentation in order of priority for participants for the HCV program. • Up-front income verification (UIV) using HUD EJV system • Up-front income verification (UIV) using a non-HUD system • Written third-party verification provided by applicant or participant • Written third-party verification form • Oral third-party verification • Self-certification Person Responsible: Doris Jamison and Janie Robinson Anticipated Completion Date: June 30, 2025

View Audit 342050

Finding 522688 (2024-002)

Significant Deficiency 2024

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 AND 10.555 2024-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...

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 AND 10.555 2024-002 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, 2025. 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 342024

Finding 522671 (2024-002)

Significant Deficiency 2024

Berkeley Housing Authority

CA

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Wi...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Williams, Executive Director, will be responsible to implement this corrective action by June 30, 2025.

View Audit 341981

Finding 522670 (2024-001)

Significant Deficiency 2024

Berkeley Housing Authority

CA

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Wi...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Williams, Executive Director, will be responsible to implement this corrective action by June 30, 2025.

View Audit 341981

Finding 522666 (2024-001)

Significant Deficiency 2024

The Dowling Park Apartments, Inc.

FL

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development The Dowling Park Apartments, Inc. HUD Project No. 063-11059 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 through June 30, 2024 The findings from the schedule of findings and que...

U.S. Department of Housing and Urban Development The Dowling Park Apartments, Inc. HUD Project No. 063-11059 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 through June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Housing and Urban Development 2024-001 Section 223(d) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects – Assistance Listing No. 14.155 Recommendation: Recommend Project Management reviews its internal control policies over the recording of transactions to ensure that all transactions are used for their intended purpose. Explanation of disagreement with audit finding: There was no disagreement with the audit finding. Action taken in response to finding: Management agreed that funds were erroneously used for HUD related operational expenditures and were replenished to the reserve account when the error was discovered by accounting staff. Procedures were changed to include all accounting personnel in communications regarding reserve funded projects. The contact person responsible for corrective action: Michael Willis, CFO of Advent Christian Village Planned completion date for corrective action plan: August 2024 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Michael Willis, at (386)-658-5450.

View Audit 341951 Questioned Costs: $1

Finding 522650 (2024-001)

Significant Deficiency 2024

Flathead Valley Community College

MT

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding: 2024-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A232416, Po33A232416, R063P232851, P268K242851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed...

Finding: 2024-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A232416, Po33A232416, R063P232851, P268K242851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed to initiate the notification process timely across 265 out of the 984 students (27%). The issue was discovered internally and corrected by the College, notifying those students during the fiscal year, however it was outside of the 30-day requirement. Corrective Action: The process has been reviewed and updated to correct this issue.  A task was implemented in PowerFAIDS that is assigned to the Student Financial Aid Director, and disbursement notifications will be emailed weekly.  If the email fails, a printed letter will be sent to the address on file.  A report was created and will be checked monthly to ensure all students have received notices. At this point, if the College determines someone did not receive the notification, the notification can be sent then and be in the 30-day regulation Responsible Individual: Crystal Morris, Director, Financial Aid Anticipated Completion Date: January 2025

View Audit 341896

Finding 522616 (2024-005)

Material Weakness 2024

Raymond #14 School District

WI

Cash Management Reporting Significant Deficiency

Corrective Action Plan: The District will monitor expenditures related to Federal grants in order to appropriately record these expenditures. The District will compare recorded expenditures to grant claims prior to claim submission to ensure that the claims match the accounting records. Anticipate...

Corrective Action Plan: The District will monitor expenditures related to Federal grants in order to appropriately record these expenditures. The District will compare recorded expenditures to grant claims prior to claim submission to ensure that the claims match the accounting records. Anticipated Corrective Action Plan Completion Date: 6/30/2025 Contact Information: For additional information regarding this finding, please contact Patti Hoppus, District Bookkeeper at 262-835-2929.

View Audit 341853

Finding 522612 (2024-004)

Significant Deficiency 2024

Oklahoma State University

OK

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.308

OSU OKC and OSU Tulsa: The key personnel listed on the GAN will be responsible for completing the post-award training. Key personnel will also reconcile their federal grant budget on a monthly basis and a copy will be submitted to the Office of Institutional Grants and Compliance. The Director of ...

OSU OKC and OSU Tulsa: The key personnel listed on the GAN will be responsible for completing the post-award training. Key personnel will also reconcile their federal grant budget on a monthly basis and a copy will be submitted to the Office of Institutional Grants and Compliance. The Director of Grants and Compliance will verify the purchases using the approved grant budget. Signed time and effort reports will also be submitted to the grants office at this time. OSU IT: A new PI will be appointed to the grant and ensure accurate reporting of time and effort. OSU IT will also implement a comprehensive training program for PI and grant-related staff, establish a monitoring system to ensure ongoing compliance, and designate a compliance officer to oversee this process. Will also implement a digital tracking system to streamline the reporting process and reduce the risk of errors.

View Audit 341848

Finding 522609 (2024-003)

Significant Deficiency 2024

Oklahoma State University

OK

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

OSU CHS will have a second person verify the data entered into NSLDS and document that it has been verified.

View Audit 341848

Finding 522608 (2024-002)

Significant Deficiency 2024

Oklahoma State University

OK

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

OSU OKC Financial Aid and Registrar worked together in December 2023 to develop a timeline for updating SOATBRK in Banner. This Banner screen records the number of days in a break that is used for the R2T4 calculation. In addition, the Registrar will reach out to Financial Aid at the time they are...

OSU OKC Financial Aid and Registrar worked together in December 2023 to develop a timeline for updating SOATBRK in Banner. This Banner screen records the number of days in a break that is used for the R2T4 calculation. In addition, the Registrar will reach out to Financial Aid at the time they are building terms for the next academic year. This will serve as a backup to ensure the process is not missed.

View Audit 341848 Questioned Costs: $1

Finding 522597 (2024-003)

Significant Deficiency 2024

Pershing County, Nevada

NV

Reporting Significant Deficiency

Finding 2024-003 Finding Summary: Current obligation information was not reported correctly to the federal awarding agency Responsible Individual: Lacey Donaldson, Clerk-Treasurer Corrective Action Plan: Internal controls will be put in place to ensure Project and Expenditure Reports were pr...

Finding 2024-003 Finding Summary: Current obligation information was not reported correctly to the federal awarding agency Responsible Individual: Lacey Donaldson, Clerk-Treasurer Corrective Action Plan: Internal controls will be put in place to ensure Project and Expenditure Reports were prepared in accordance with governing requirements. Anticipated Date of Correction Action Plan: Correction will be made on the next annual report due in April of 2025.

View Audit 341826

Finding 522588 (2024-001)

Significant Deficiency 2024

Housing for Rockdale Elders, Inc.

MA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Management agrees with the finding and is in the process of revising internal controls to address this issue.

View Audit 341811 Questioned Costs: $1

Finding 522542 (2024-002)

Significant Deficiency 2024

Capital Area Food Bank, Inc.,

DC

Questioned Costs Eligibility Subrecipient Monitoring

Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible c...

Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible community partner organization was able to order approximately 100 pounds of TEFAP food from CAFB’s website. CSFP – We noted that for one out of 40 individual participants sampled for CSFP, one participant’s original enrollment documents supporting eligibility was missing. The organization did have the participant’s re-enrollment documents for the subsequent fiscal year. This is related to a person being eligible to receive food. Views of Responsible Officials and Planned Corrective Actions: The Organization's investigation into the root causes of the two incidents revealed clerical errors. For the TEFAP incident, a mistake in the partner organization's profile allowed access to USDA food via our online ordering portal. Regarding the CSFP participant, the initial eligibility documents were misplaced, but subsequent reauthorization documents were available. The Organization’s planned corrective actions with respect to the two instances include the following: TEFAP partner eligibility:  Review and enhance existing procedures for establishing partner organization profiles; and  Establish a periodic reconciliation of partner organization’s authorized to access TEFAP commodities in the online ordering portal with a listing of authorized TEFAP partners CSFP eligibility:  Review and enhance existing procedures for filing individual eligibility documents; and  Continued internal reviews by the Organization’s compliance department covering the filing of individual eligibility documents Anticipated Completion Date: March 2025

View Audit 341804 Questioned Costs: $1

Finding 522423 (2024-001)

Significant Deficiency 2024

Albuquerque Housing Authority

NM

HUD Housing Programs Significant Deficiency

2024-001-(2023-004) MISSING REQUIRED DOCUMENTATION FROM PUBLIC HOUSING FILES (SIGNIFICANT DEFICINCY) AHA has implemented a training program for staff and is hiring a new position Compliance technical review. Responsible Party: Anticipated Completion Date: Finance Director February 2025

View Audit 341712

Finding 522420 (2024-001)

None 2024

Food for Kids, Inc.

TX

Subrecipient Monitoring Cash Management Significant Deficiency

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Oper...

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Operation will make monitoring visit assignments for the month. Step 2: Each Compliance Officer is to submit the monitoring form to the Director of Operation no later than the last day of the month the visit was due to be performed. Step 3: The Director of Operation will follow up with each Compliance Officer to ensure forms were received, review the form, and enter the date the visit was completed into the data base to ensure visits are made as TDA requires. Step 4: The Executive Director will review the final report of all visits conducted for the month to sensure forms are accounted for. Step 5: The Director of Operation and the Office Clerk will perform random binder checks to see if forms are filed correctly. Step 6: The Director of Operation will oversee the labiling and thinning process of forms and binders before sending boxes to storage. This will ensure stored files can be easily located. The Executive Director has final responsibility for the implementation and maintenance of this procedure.

View Audit 341706

Finding 522353 (2024-002)

Significant Deficiency 2024

Catskill Central School District

NY

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

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84....

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84.425D) ARP Summer Enrichment (Assistance Listing# 84.425U) ARP Comprehensive After School (Assistance Listing# 84.425U) ARP ESSER III (Assistance Listing# 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria - Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. ( d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context - We haphazardly sampled five COVID-19 - Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor's review prior to payment. Cause - Management override of established controls. Effect - Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs - None. The improper payment was subsequently adjusted out of expenditures. Recommendation - We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action - The Business Office will review and adhere to all cash disbursements procedures and protocols. Completion Date - Effective immediately. Respectfully Submitted, Dr. Brett Miller, Assistant Supt. for Business

View Audit 341608

Corrective Action Plans

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