Corrective Action Plans

Finding 539256 (2024-708)

Significant Deficiency 2024

WI

Student Financial Aid Reporting Subrecipient Monitoring

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enroll...

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enrollment accurately, completely, and in a timely manner for all instances that require reporting. OSFA and RO will review and update internal procedures to ensure that the date that a student is unofficially withdrawn is communicated and reported consistently between the National Student Loan Data System (NSLDS) and the National Student Clearinghouse (NSC) as appropriate. Prior to the LAB’s review, UW-Madison discovered and corrected issues relating to program enrollment status in NSC and NSLDS. As of November 2024, updates were made for all retroactive instances using appropriate conferral dates and accurate “G - Graduated” statuses. The long-term solution includes the creation of a “Graduates Only Enrollment” file which includes all students who have been reported as enrolled, not withdrawn in a given term and who have earned their degree in each of UW-Madison’s three degree conferral dates. This enrollment file will trigger an enrollment status update that occurs outside of the automatic NSC process. UW-Madison has updated procedures and now uses the NSC extract process to comply with the NSLDS and NSC reporting procedures for program-level enrollment status effective dates. For the beginning of the Fall 2025 term, UW-Madison will update procedures and extract logic from the student information system to ensure accuracy in the reporting of program begin dates. In the meantime, the RO team has reviewed, tested, and updated the process to ensure previously inaccurate program begin dates are corrected. Anticipated Completion Date: September 30, 2025 Person responsible for corrective action: Beth Warner Registrar Office – Division of Enrollment Mangement beth.warner@wisc.edu

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Finding 539255 (2024-707)

None 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Planned Corrective Action: We agree with the finding as to the handling of an inadvertent overpayment, defined as a disbursement inadvertently made to a student after the student ceased attendance but prior to the date of the institution’s determination that the student withdrew, and the requirement...

Planned Corrective Action: We agree with the finding as to the handling of an inadvertent overpayment, defined as a disbursement inadvertently made to a student after the student ceased attendance but prior to the date of the institution’s determination that the student withdrew, and the requirement that they be included in a Return of Title IV Aid calculation as aid that could have been disbursed rather than aid that was disbursed. Furthermore if the inadvertent overpayment could not have been made as a late disbursement under federal regulations, the entire amount of the overpayment must be returned. As of the date below and moving forward when a Title IV aid recipient officially withdraws and when a Title IV aid recipient withdraws without notification (an unofficial withdrawal as was the case with the finding), the date of disbursement for each aid type will be reviewed in relation to the date of the student’s ceasing attendance. This will determine how each aid type is treated within the calculation in line with policy addressed in the paragraph above. Appropriate action as to each aid type will be taken at the time of processing the Return of Title IV Aid calculation. Anticipated Completion Date: March 15, 2025 Person responsible for corrective action: Name, Title: William Trippett, Financial Aid Director Email address: trippetw@uww.edu

View Audit 349896 Questioned Costs: $1

Finding 539254 (2024-706)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Item One: Establishing Attendance 1. The Registrar’s Office will inform the Financial Aid and Scholarships Office of approved retroactive withdrawals. 2. Financial Aid and Scholarships office staff have been added to the academic calendar group, so we are aware of changes as they are made. 3. Provos...

Item One: Establishing Attendance 1. The Registrar’s Office will inform the Financial Aid and Scholarships Office of approved retroactive withdrawals. 2. Financial Aid and Scholarships office staff have been added to the academic calendar group, so we are aware of changes as they are made. 3. Provost and College Deans are now ensuring 100% completion of attendance rosters from faculty. 4. We will look more closely at students with withdrawal dates in the first week of the term to ensure they established attendance. 5. We will investigate more automated ways to monitor both establishing attendance as well as retroactive changes. Item Two: Calculation of Days in the Term We have implemented a semesterly meeting, including multiple people, to review the calendar together to determine the number of days in the term. Anticipated Completion Date: Item One: Establishing Attendance 1. Completed February 2025 2. Completed February 2025 3. Completed September 2024 4. In Progress a. Written policies completed February 2025. b. The next time this practice will be done is June 2025. 5. In Progress a. Determine current options and implement if there are automated ways to monitor by September 2025. Item Two: Calculation of Days in the Term Complete. First meeting held 2/12/2025 Person responsible for corrective action: Melissa Haberman Director, Financial Aid and Scholarships University of Wisconsin - Platteville Platteville, Wisconsin habermanm@uwplatt.edu

View Audit 349896 Questioned Costs: $1

Finding 539253 (2024-705)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Planned Corrective Action: Module R2T4 date determination corrective action: Updated module R2T4 procedures to assist in determination of dates to be included in the R2T4 calculation. Complete recalculation for impacted 23-24 audit students, and review others in similar programs for updates by Revie...

Planned Corrective Action: Module R2T4 date determination corrective action: Updated module R2T4 procedures to assist in determination of dates to be included in the R2T4 calculation. Complete recalculation for impacted 23-24 audit students, and review others in similar programs for updates by Review withdrawals in terms/programs taught in modules for 24-25 for accuracy in determining correct end dates and charges used in determining withdrawal. Withdrawal Timing Updated R2T4 procedures to include quick review of timing of the disbursement of funds versus the students recorded withdrawal date. Anticipated Completion Date: March 2025 Person responsible for corrective action: Kristina Klemens Director of Scholarships and Financial Aid Name Title Jamie Thomas Financial Aid Business Analyst-Operations and Compliance Name Title Financial Aid/Enrollment Management Division or Unit (if applicable) Kristina Klemens: klemens@uwp.edu Email address Jamie Thomas: thomsonj@uwp.edu Email address

View Audit 349896 Questioned Costs: $1

Finding 539252 (2024-704)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Student Financial Aid Subrecipient Monitoring

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although i...

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although it has procedures in place to review course participation for enrolled courses at the time of withdrawal and when students are assigned failing grades. For Fall Semester 2024: Existing procedures: 1. Official withdrawals: Students officially withdrawing from the University must complete an electronic form which collects instructor verification of course participation. The Financial Aid office receives this form once it has been processed by the Registrar’s office. Students reported as not having participated in courses have their financial aid adjusted prior to calculating a return to Title IV funds. 2. Unofficial withdrawals: Instructors assigning failing grades to students must report student’s course participation or non-participation and, if available, a last date of course participation. Following the grading deadline, a report listing all students who never participated in classes is run and students found to have failed courses due to non-participation have their financial aid adjusted prior to calculating a return to Title IV funds. Additional procedure instituted: 3. Learning management system review: Students who withdraw (officially or unofficially) and who dropped courses prior to withdrawing had their dropped courses reviewed in the Learning Management System (LMS). Students who submitted assignments as recorded in the system were determined to have begun participation in the course. Students who submitted no assignments were determined to not have participated in the course and financial aid was adjusted prior to calculating a return to Title IV funds. For Spring Semester 2025: Existing procedures: 1. Procedures 1,2, and 3 from Fall Semester 2024 continue to be employed for Spring semester 2025. Additional procedures: 2. Expanding the LMS review to Pell grant students with dropped courses: Students with disbursed Pell Grants who drop courses after the Pell grant census date now have these courses reviewed to determine if the student began attendance before dropping the course, using the same procedure as #3 above.Instructor course participation verification: After the 3rd week of classes for Spring 2025, UWRiver Fall requested that instructors report students who had not begun participation in their courses. This report is currently being reviewed and students with Pell grants will be evaluated to determine if an adjustment to the student’s enrollment intensity is needed to ensure that the disbursed Pell grant is accurate. Student who have begun participation in no enrolled courses will be reviewed for possible return of all Title IV funds. Future additional corrective actions: 1. UW-River Falls will pursue making course participation verification by instructors during the first month of the semester an administrative policy and develop formal procedures for surveying instructors and reporting students found to not have begun participation in a course or courses to the Financial Aid office for adjustments to their disbursed Title IV aid. 2. UW-River Falls will pursue adding an instructor course participation step to the course drop form currently in use by the Registrar’s office. Anticipated Completion Date: Interim actions were implemented in September 2024 and February 2025. Permanent action expected by Spring 2026. Person(s) responsible for corrective action: Cindy Holbrook, Executive Director of Enrollment Management Cindy.Holbrook@uwrf.edu 715-425-3500 Robert Bode, Director of Financial Aid and Military/Veterans Resource Center Robert.Bode@uwrf.edu 715-425-3141 Kelly Browning, University Registrar Kelly.Browning@uwrf.edu 715-425-3342 Responsible Unit Division of Enrollment Mangagement

View Audit 349896 Questioned Costs: $1

Finding 539251 (2024-703)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) reviewed the return of fund calculations cited in Finding 2024-703 and returned funds as appropriate. OSFA will review internal procedures to ensure accuracy and timely completion of the return of funds process. As a proa...

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) reviewed the return of fund calculations cited in Finding 2024-703 and returned funds as appropriate. OSFA will review internal procedures to ensure accuracy and timely completion of the return of funds process. As a proactive measure, UW-Madison is establishing a new position focused on compliance and training within OSFA. This individual will oversee key compliance areas in Title IV administration, including R2T4 calculations and the unofficial withdrawal process. The new position will conduct quality assurance reviews at the end of each term to identify and address any weaknesses in the R2T4 and other administrative processes. Any concerns will be remedied within the required timeframe, and staff will receive training on the relevant policies and procedures. Additionally, two OSFA team members are registered to attend National Association of Student Financial Aid Administrators’ (NASFAA) online Return of Title IV Funds five-week course in April 2025. This training will inform any necessary updates to OSFA’s policies and procedures related to official and unofficial withdrawals. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Shane Maloney, Associate Director of Financial Aid Office of Student Financial Aid - Division of Enrollment Mangement shane.maloney@wisc.edu

View Audit 349896 Questioned Costs: $1

Finding 539230 (2024-303)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Wisconsin Department of Health Services Planned Corrective Action: This finding is a continuation of a prior year finding. The current finding does not include any new recommendations. The prior year finding continued into SFY 2023-24 because we didn’t receive the finding until the final quarter of ...

Wisconsin Department of Health Services Planned Corrective Action: This finding is a continuation of a prior year finding. The current finding does not include any new recommendations. The prior year finding continued into SFY 2023-24 because we didn’t receive the finding until the final quarter of SFY 2023-24, and the federal website would not accommodate the solution we implemented immediately upon receipt of the finding. DHS adjusted its corrective action plan and successfully submitted all the SFY 2023-24 awards to the federal website in July 2024. This represents timely reporting for obligations occurring in June 2024, though technically after the audit period. No further corrective actions are needed for this finding. Anticipated Completion Date: July 2024 Person responsible for corrective action: Vanessa Salata, Section Chief Expenditure Accounting, Bureau of Fiscal Services, Division of Enterprise Services vanessaa.salata@dhs.wisconsin.govRebuttal from the Wisconsin Legislative Audit Bureau In its corrective action plan on page 349, the Department of Health Services noted that it had adjusted its prior year corrective action plan and successfully submitted all the FY 2023-24 Social Services Block Grant (SSBG) awards to the federal website in July 2024. To assist the reader in understanding the corrective action plan, we offer the following clarification: The July 2024 submission was not timely for amounts awarded under SSBG that were obligated through agreements signed in fall 2023.

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Finding 539229 (2024-302)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.332

Wisconsin Department of Health Services Planned Corrective Action: After the SFY 2022-23 audit finding was received, DHS immediately began corrective actions. No new concerns were identified by LAB during their SFY 2023-24 audit. DHS corrected the assistance listing number (ALN) of TANF funds transf...

Wisconsin Department of Health Services Planned Corrective Action: After the SFY 2022-23 audit finding was received, DHS immediately began corrective actions. No new concerns were identified by LAB during their SFY 2023-24 audit. DHS corrected the assistance listing number (ALN) of TANF funds transferred to the SSBG on the DHS website (https://www.dhs.wisconsin.gov/gears/index.htm) for the calendar year 2023 and 2024 Basic County Allocation on March 20, 2024. DHS changed the ALN for TANF funds transferred to the SSBG on the calendar year 2025 Basic County Allocation contracts that started January 1, 2025. Anticipated Completion Date: January 1, 2025 Person responsible for corrective action: Rebecca Mogensen, Section Chief Managerial Accounting, Bureau of Fiscal Services, Division of Enterprise Services rebeccaj.mogensen@dhs.wisconsin.gov

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Finding 539228 (2024-201)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Reporting Significant Deficiency

Planned Corrective Action: The DCF Bureau of Finance will continue to review and improve the FFATA reporting process to ensure the reporting is accurate and timely. Anticipated Completion Date: The bureau will complete this work by June 30, 2026. Person responsible for corrective action: Rachelle Ar...

Planned Corrective Action: The DCF Bureau of Finance will continue to review and improve the FFATA reporting process to ensure the reporting is accurate and timely. Anticipated Completion Date: The bureau will complete this work by June 30, 2026. Person responsible for corrective action: Rachelle Armstrong, Director Bureau of Finance Rachelle.Armstrong@wisconsin.gov

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Finding 539227 (2024-200)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Planned Corrective Action: The DCF Bureau of Working Families (BWF) will review the Work Verification Plan, make updates as necessary, and submit it to the U.S. Department of Health and Human Services for approval. BWF will resume monitoring and documentation of the work participation information in...

Planned Corrective Action: The DCF Bureau of Working Families (BWF) will review the Work Verification Plan, make updates as necessary, and submit it to the U.S. Department of Health and Human Services for approval. BWF will resume monitoring and documentation of the work participation information in accordance with the approved Work Verification Plan. Anticipated Completion Date: The bureau will complete this work by June 30, 2025. Persons responsible for corrective action: Patara Horn, Director Bureau of Working Families Pataras.Horn@wisconsin.gov Rachelle Armstrong, Director Bureau of Finance Rachelle.Armstrong@wisconsin.gov

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Finding 539222 (2024-306)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring § 200.332

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH) will continue to utilize risk assessments to inform a written monitoring plan for the Health Disparities grant. The monitoring plan will include a description of the subrecipient monitoring in refe...

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH) will continue to utilize risk assessments to inform a written monitoring plan for the Health Disparities grant. The monitoring plan will include a description of the subrecipient monitoring in reference to the risk level of the subrecipient. DPH will develop templates and procedures for completing and documenting desk reviews of subrecipient invoices. DPH will also use the Internal Controls Checklist to create a standard of assessing and documenting the reliance that can be placed on review of subrecipient single audit reports. DPH will develop and provide training on monitoring plans to staff with responsibilities for subrecipient monitoring activities. Finally, DPH will utilize the Internal Controls Checklist to implement management oversight to ensure monitoring is being completed and documented. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

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Finding 539218 (2024-307)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring § 200.332

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH), Office of Preparedness and Emergency Health Care will finalize its review of the tracking spreadsheet, document all conclusions, and work with the correct federal agency to complete any necessary ...

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH), Office of Preparedness and Emergency Health Care will finalize its review of the tracking spreadsheet, document all conclusions, and work with the correct federal agency to complete any necessary next steps. DPH will complete risk assessments for the three local and seven tribal public health agencies and adjust subrecipient monitoring appropriately. DPH will continue to utilize risk assessments to inform a written monitoring plan for the Public Health Emergency Response grant. The monitoring plan will include a description of the subrecipient monitoring in reference to the risk level of the subrecipient. DPH will develop templates and procedures for completing and documenting desk reviews of subrecipient invoices. DPH will also use the Internal Controls Checklist to create a standard of assessing and documenting the reliance that can be placed on review of subrecipient single audit reports. DPH will develop and provide training on monitoring plans to staff with responsibilities for subrecipient monitoring activities. Finally, DPH will utilize the Internal Controls Checklist to implement management oversight to ensure monitoring is being completed and documented. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

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Finding 539214 (2024-305)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring § 200.332

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH) will continue to utilize risk assessments to inform a written monitoring plan for the ELC grant. The monitoring plan will include a description of the subrecipient monitoring in reference to the ri...

Wisconsin Department of Health Services Planned Corrective Action: The Division of Public Health (DPH) will continue to utilize risk assessments to inform a written monitoring plan for the ELC grant. The monitoring plan will include a description of the subrecipient monitoring in reference to the risk level of the subrecipient. DPH will develop templates and procedures for completing and documenting desk reviews of subrecipient invoices. DPH will also use the Internal Controls Checklist to create a standard of assessing and documenting the reliance that can be placed on review of subrecipient single audit reports. DPH will develop and provide training on monitoring plans to staff with responsibilities for subrecipient monitoring activities. Finally, DPH will utilize the Internal Controls Checklist to implement management oversight to ensure monitoring is being completed and documented.Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

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Finding 539210 (2024-309)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Reporting Significant Deficiency

Wisconsin Department of Health Services Planned Corrective Action: DHS agrees with the recommendation to continue efforts to implement the reporting improvements started after the prior year audit. As stated by LAB, updates have been made to the Federal Funding Accountability and Transparency Act (F...

Wisconsin Department of Health Services Planned Corrective Action: DHS agrees with the recommendation to continue efforts to implement the reporting improvements started after the prior year audit. As stated by LAB, updates have been made to the Federal Funding Accountability and Transparency Act (FFATA) reporting process and procedures since the prior audit, and they were implemented in the final quarter of SFY 2023-24. Unfortunately, at the time we received the prior year finding, much of SFY 2023-24 was complete, so we had little time to improve FY 2023- 24 reporting. Since the prior audit, all reporting has been accomplished in a timely manner, provided the Federal Award Identification Number (FAIN) was made available by the federal government in a timely manner. For many awards, including Substance Abuse Block Grant, this doesn’t become available for up to 10 months after the period of performance begins, making timely reporting of the subawards impossible. DHS is struggling to meet the extensive audit requirements of FFATA reporting, while also ensuring it adds value to the public. For example: The contract signed date is not captured in STAR and can’t be pulled by query. Manual intervention is required to locate the subaward signed date. • Though the description field is required, it is not displayed publicly in the subawards search results page under the FAIN. In this way, the field may not add value to the public, so DHS uses it to describe the award in ways that are administratively purposeful. • DHS must be informed of subawards by DCF and UW to report them. Reasonably, DHS relies on language in the interagency grant agreement to communicate with these agencies. This communication did not happen in all instances. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Vanessa Paulsen, Section Chief Expenditure Accounting, Bureau of Fiscal Services, Division of Enterprise Services vanessa.paulsen@dhs.wisconsin.gov

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Finding 539206 (2024-801)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring § 200.332

Planned Corrective Action: DNR has developed formal subrecipient monitoring policies and procedures for GLRI recipients and implemented this corrective action in June 2024 for the FY 2024-25 awards. Furthermore, DNR will perform risk assessments for existing subrecipients for ongoing projects under ...

Planned Corrective Action: DNR has developed formal subrecipient monitoring policies and procedures for GLRI recipients and implemented this corrective action in June 2024 for the FY 2024-25 awards. Furthermore, DNR will perform risk assessments for existing subrecipients for ongoing projects under open grants as of February 17, 2025, to ensure appropriate monitoring. Anticipated Completion Date: 6/1/25 Person responsible for corrective action: Name, Title: Wade Strickland, Director Division or Unit (if applicable): Office of Great Waters, Division of Environmental Management Email address: Wade.strickland@wisconsin.gov

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Finding 539204 (2024-101)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Reporting Significant Deficiency

Planned Corrective Action: The Wisconsin Department of Administration (DOA) is committed to accountability and transparency in federal award administration, as is the objective of Federal Funding Accountability and Transparency Act (FFATA) reporting under 2 CFR s. 170. Accordingly, in March 2024, in...

Planned Corrective Action: The Wisconsin Department of Administration (DOA) is committed to accountability and transparency in federal award administration, as is the objective of Federal Funding Accountability and Transparency Act (FFATA) reporting under 2 CFR s. 170. Accordingly, in March 2024, in response to the auditor’s finding and recommendations, DOA inquired to the Office of Management and Budget (OMB) for clarification on the requirements for reporting subaward modifications in the FFATA Subaward Reporting System (FSRS). OMB’s response indicated that DOA should “use the total amount after adjusted,” which was DOA’s practice at the time and thus, was maintained. In February 2025, DOA became aware of U. S. General Services Administration (GSA) knowledge base article titled, “Five tips for accurate FFATA* subaward reporting”, published at the Federal Service Desk (fsd.gov). The article states, “When you modify a subaward, update the original report with the new information. If you modify the amount, replace the original amount with the new amount.” In response to that guidance, DOA updated its guidance to state agencies effective March 2025. DOA’s updated guidance also incorporated changes resulting from GSA’s February 27, 2025, announcement that FSRS.gov would be retired on March 6, 2025, and subaward reporting transitioned to SAM.gov effective March 8, 2025. State agencies were provided training regarding the updated guidance on March 6, 2025. Anticipated Completion Date: March 31, 2025 Person responsible for corrective action: Dustin Trickle, Executive Policy & Budget Manager State Budget Office Division of Executive Budget & Finance dustin.trickle1@wisconsin.gov

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Finding 539180 (2024-308)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring § 200.332

Wisconsin Department of Health Services Planned Corrective Action: DHS will ensure that risk assessments are completed annually for each income maintenance consortia receiving federal funding under the Supplemental Nutrition Assistance Program. Our subrecipient monitoring approach will be documented...

Wisconsin Department of Health Services Planned Corrective Action: DHS will ensure that risk assessments are completed annually for each income maintenance consortia receiving federal funding under the Supplemental Nutrition Assistance Program. Our subrecipient monitoring approach will be documented in a written monitoring plan, to include maintaining appropriate documentation. We do note that the subrecipients in question are County Income Maintenance Consortia, which are generally considered low risk. Anticipated Completion Date: January 1, 2026Person responsible for corrective action: Dave Varana, Director Bureau of Fiscal Accountability and Management, Division of Medicaid Services dave2.varana@dhs.wisconsin.gov

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Finding 539173 (2024-400)

Material Weakness 2024

State of Wisconsin

WI

School Nutrition Programs Subrecipient Monitoring Material Weakness

Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) starting in fiscal year 2025. The internal processes established to ensure proper report...

Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) starting in fiscal year 2025. The internal processes established to ensure proper reporting of subaward information did not include payments made for Child Nutrition Cluster grants, as the Department did not believe the FFATA requirement applied to these awards. Upon notification that DPI is required to include these awards, the written policies and procedures are being updated to include processes to identify which subawards and subrecipients have exceeded $30,000 and complete the monthly FFATA reporting as required. Anticipated Completion Date: Person responsible for corrective action: Michael Brendel, Assistant Director School Financial Services Team Division of Finance and Management Department of Public Instruction michael.brendel@dpi.wi.go

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Finding 539172 (2024-712)

Significant Deficiency 2024

State of Wisconsin

WI

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.510

The Universities of Wisconsin (UW) will revise and strengthen documented procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include additional steps to accurately identify grant activity between UW universities and grant activity between UW universities and other state...

The Universities of Wisconsin (UW) will revise and strengthen documented procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include additional steps to accurately identify grant activity between UW universities and grant activity between UW universities and other state agencies. Additionally, documented procedures to accurately identify the grant reporting cluster will be revised. Additional training and guidance will be provided to UW university and administration stakeholders on revised documented procedures as a critical part of the improvement in the SEFA reporting process. Anticipated Completion Date: November 2025 Person responsible for corrective action: Josh Smith Senior Associate Vice President for Finance Universities of Wisconsin josh.smith@wisconsin.edu

View Audit 349896

Finding 539171 (2024-702)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring

Planned Corrective Action Research and Sponsored Programs staff will continue to work with USDA and FSRS helpdesk specialists on the report upload issue. However, beginning March 2025, FSRS will be retired and future subaward reporting will transition to SAM.gov. Until the new system is live, RSP st...

Planned Corrective Action Research and Sponsored Programs staff will continue to work with USDA and FSRS helpdesk specialists on the report upload issue. However, beginning March 2025, FSRS will be retired and future subaward reporting will transition to SAM.gov. Until the new system is live, RSP staff will continue to use the FSRS to submit financial reports and immediately provide notice to the USDA grant specialist of submission errors. The Integrated Award Environment (IAE) of the General Services Administration will provide training in advance of the new system going live. RSP staff will be required to participate in the IAE training. After the activation of the new reporting system, RSP will create new work procedures aligned to the new submittal requirements and provide additional in-house training to reporting specialists. Anticipated Completion Date: Anticipated Completion Date is August 30, 2025 Person responsible for corrective action: Angie Johnson, Assistant Director of Research and Financial Services Research and Sponsored Programs (RSP) angie.johnson@rsp.wisc.edu

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Finding 539170 (2024-701)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Planned Corrective Action To assist research and program managers in managing subrecipient monitoring requirements for sponsored awards, RSP will review current procedures to ensure they are up-to-date and provide training to staff as required. Additionally, RSP will generate a report of subrecipien...

Planned Corrective Action To assist research and program managers in managing subrecipient monitoring requirements for sponsored awards, RSP will review current procedures to ensure they are up-to-date and provide training to staff as required. Additionally, RSP will generate a report of subrecipients that have met the threshold of federal expenditures in which a single audit is required. These reports will assist RSP staff in verifying compliance with single audit requirements by flagging subrecipients without a single audit on file, supporting the current procedure that prevents the issuance of new subaward agreements and modifications to active subawards. RSP has communicated to the subrecipient in question that their fiscal year 2024 single audit is required and that RSP will pause any issuance of subaward agreements and/or modifications until receipt and approval of their audit report. Anticipated Completion Date: Anticipated Completion Date is August 30, 2025 Person responsible for corrective action: Angie Johnson, Assistant Director of Research and Financial Services Research and Sponsored Programs (RSP) angie.johnson@rsp.wisc.edu

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Finding 539169 (2024-713)

Material Weakness 2024

State of Wisconsin

WI

Cash Management Subrecipient Monitoring § 200.305

Planned Corrective Action: To complywith federal cash management requirements, Research and Sponsored Programs (RSP) will develop a responsive cash management policy and procedures to implement the policy for subrecipient agreements. The policy and subsequent procedure will specify the circumstance ...

Planned Corrective Action: To complywith federal cash management requirements, Research and Sponsored Programs (RSP) will develop a responsive cash management policy and procedures to implement the policy for subrecipient agreements. The policy and subsequent procedure will specify the circumstance and requisites a cash advance may be suitable. A standard cost reimbursable agreement will be otherwise executed. RSP will evaluate subrecipientsthat request agreements with advance paymentto determine whetherto issue an agreement with advance payment. Thisincludes determining whetherthe Subrecipient has a need for an advance payment as well asthe amount of advance payment needed. Forsubrecipientsthat RSP determinesto issue a subagreement with an advance payment, RSPwill issue agreementsthatincorporate 2 CFR 200.305(b)(1)(2)- federal payment requirements and include, as applicable, interest-bearing accountrequirements. RSP staffwill be trained on the new procedures and additionsto subrecipient agreements. Anticipated Completion Date: October 30, 2025 Person responsible for corrective action: Angie Johnson, Assistant Director of Research Financial Services Research and Sponsored Programs Angie.johnson@rsp.wisc.edu

View Audit 349896

Finding 539164 (2024-005)

Significant Deficiency 2024

Felician University

NJ

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Procurement and Suspension & Debarment Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement – Assistance Listing No. 84.031C Recommendation: We recommend the University document and implement policies and procedures that are align...

Procurement and Suspension & Debarment Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement – Assistance Listing No. 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Guidance for procurement and suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has documented and implemented policies and procedures that are aligned with Uniform Guidance for procurement and suspension and debarment to ensure the University is following requirements. Appropriate staff have been notified, and management will monitor this regularly throughout the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Shalini Patel, Controller Planned completion date for corrective action plan: July 1, 2025.

View Audit 349884 Questioned Costs: $1

Finding 539151 (2024-006)

Material Weakness 2024

Worker Education & Resource Center INC

CA

Questioned Costs Subrecipient Monitoring § 200.1 § 200.332 § 200.414 § 200.501

The Organization will update its subrecipient monitoring policies to ensure all required elements as defined in 2 CFR § 200.332 (a)(1) are included in subrecipient agreements, Additionally, a checklist will be established to perform a risk assessment process to evaluate subrecipient risk prior to co...

The Organization will update its subrecipient monitoring policies to ensure all required elements as defined in 2 CFR § 200.332 (a)(1) are included in subrecipient agreements, Additionally, a checklist will be established to perform a risk assessment process to evaluate subrecipient risk prior to contract execution and annually thereafter and to verify each subrecipient’s that meets the audit threshold and if required has a current Single Audit on file or is otherwise in compliance.

View Audit 349874 Questioned Costs: $1

Finding 539150 (2024-005)

Significant Deficiency 2024

Worker Education & Resource Center INC

CA

Questioned Costs Eligibility Subrecipient Monitoring

During the period being audited internal controls for program participants documents were not reviewed by the former Executive Director. The new Executive Director has implemented a check and balance procedure that requires the Case Manager, Program Manager, and Executive Director to review and sign...

During the period being audited internal controls for program participants documents were not reviewed by the former Executive Director. The new Executive Director has implemented a check and balance procedure that requires the Case Manager, Program Manager, and Executive Director to review and sign off on participant application forms and to be documented on the participants application before the participant can move forward in the program.

View Audit 349874 Questioned Costs: $1

Corrective Action Plans

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