Corrective Action Plans

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subrecipients for grant number 202-NS-BX-K004 by June 30, 2026. The desk reviews will be performed
subrecipients for grant number 202-NS-BX-K004 by June 30, 2026. The desk reviews will be performed
virtually and will include a risk assessment and review of project performances and outcomes.
virtually and will include a risk assessment and review of project performances and outcomes.
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services s...
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.
Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring...
Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring that Title I funding was fully restored and not negatively impacted. Preventive Measure to Avoid Recurrence: Budget Code Verification Process • Fiscal Services has implemented an additional review step for all extra duty or abnormal pay requests. Before processing, HR and Payroll staff must verify the program code against the employee’s funding source in the financial system. Responsible Parties: • Director of Fiscal Services – Oversight of corrective action and monitoring. • Payroll Supervisor & HR Coordinator – Verification of funding sources before processing extra pay. • Site Administrators – Correct budget coding on memoranda. Completion Date: • Immediate correction was made prior to FY 2024-25 year-end close (August 19, 2025).
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant ...
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant is received, the School District will print the grant documents and review them with the necessary employees to ensure they are aware of the allowable and unallowable costs. Additionally, all invoices will be reviewed by the Food Service Director prior to being submitted to the business office for payment. Responsible Party(ies): • Food Service Head Cook Anticipated Completion Date: December 31, 2025
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are t...
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff).  If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that the applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027.
The Food Service Director will coordinate a check procedure to review monthly meal counts before submitting reimbursement from Michigan Department of Education. Contact person responsible for corrective action: Jenny Patton, Food Service Director, Anticipated Completion Date: 12/31/2025
The Food Service Director will coordinate a check procedure to review monthly meal counts before submitting reimbursement from Michigan Department of Education. Contact person responsible for corrective action: Jenny Patton, Food Service Director, Anticipated Completion Date: 12/31/2025
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not al...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not all dining locations had their final meal counts completed before the meal claim was submitted. The persons responsible for the corrective action are Aaron Burnett, the Food Service Director and Emily Kearney, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Pr...
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Program 84.038 - Federal Perkins Loan Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their informationsharing practices to their customers and to safeguard sensitive data (16 CFR 314). institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with few that 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution's written information security program must address the implementation ofthe minimum safeguards identified in 16 CFR 314.4(c)(l) through (8) including: assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16CFR 314.4(d)). Condition/Context: Under a college's Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: Not applicable. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The Corporation's students' personal information could be vulnerable. Recommendation: We recommend the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Corrective Action Plan: Corrective Action Planned: To ensure continued GLBA compliance the Corporation contracted with FRSecure to develop a risk assessment and roadmap which did a system scan for issues, an assessor interviewed staff including IT, HR, Finance Leaders and others to learn more about the current state of overall security program. Compliance with GLBA was part of their review. FRSecure issued an assessment 'Roadmap Plan' for the department to review and the Corporation will implement the results as feasible. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Anticipated Completion Date: June 30, 2026
Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award y...
Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award year end: September 30, 2024 Recommendation: The School District should create a process for gathering all requirements for special reporting under Uniform Guidance and the School District should prepare and submit the necessary special reports. Action taken: The Finance Director has created a process for gathering all requirements for special reporting under Uniform Guidance and for preparing and submitting the necessary special reports. Responsible Person and Anticipated Completion Date: Finance Director, January 2026. If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse b...
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse between monitoring visits for CACFP compliance. At least two of the three reviews must be unannounced. If a violation occurs during the visit, the sponsor must follow up with the facilities noted as having problems, and the follow-up visit must be conducted no less than one week after the initial finding, and the visit must be documented. Kansas City Public Schools did not perform the required three site visits per year within a six-month timeframe for five of the samples, and the supporting documentation provided for all six samples did not contain the total of participants in attendance during the meal service and the total number of meals claimed during the five consecutive days. Corrective Actions Taken or Planned: The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that all three required visits are accurately documented using the DHSS Site Visit Report by June 30, 2026: a. Training: Child Nutrition Services (CNS) will review and provide training to all supervisors and department leaders on DHSS Sponsor Review requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance b. SOP: CNS will utilize a central repository [CNSReporting@kcpublicschools.org] to streamline and time-stamp audit submissions. The original copy will be stored in a designated binder, and a digital copy will be retained in the CNS shared drive. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance c. Monitoring: C CNS leaders, as designated by the Officer of Nutrition & Compliance, will conduct Supper audits during SY 2025–2026 in September, December, and March. Snack audits will be conducted in November, February, and April. Additional audits will be scheduled as necessary to ensure compliance with program requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance d. Reporting: As part of progress monitoring, at the end of each monitoring month, each applicable site will be reviewed to confirm completion & accuracy of a Sponsor Review. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance
Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented proce...
Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.
Finding Summary - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Responsible Individual - Terry Baesler, Superintendent Corrective Action Plan - The District will maintain ...
Finding Summary - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Responsible Individual - Terry Baesler, Superintendent Corrective Action Plan - The District will maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring procedures were being performed. Anticipated Completion Date - 6/30/2026
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it shoul...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it should have been. There is a chance that the claim was done for the correct amount, but the supporting documentation shows that the District claimed less than they were allowed to. The District is going to ensure that all totals are subtotaled correctly in the future and double checked before the claim request is made. The persons responsible for the corrective action are Jack Ledford, the Food Service Director and Katrina Bontekoe, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that funds requested for meal reimbursements agree to total meals served.
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Co...
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Completion Date – The District intends to work towards resolving this finding for the following year.
Pathways executive management team will provide at least quarterly trainings on any changes in state of federal funding guidance and ensure implementation of this guidance is clear through regular contact with state and federal agencies.
Pathways executive management team will provide at least quarterly trainings on any changes in state of federal funding guidance and ensure implementation of this guidance is clear through regular contact with state and federal agencies.
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of E...
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.
Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the is...
Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the issue arises from configuration problems, system design limitations, or both. Planned Corrective Action and Responsible Officials • Procedure review and update. The Financial Aid Office will review and revise procedures to ensure accurate, timely, and complete reporting to COD, including pre-submission and post-submission checks. • System-to-COD file analysis with Anthology. In partnership with Anthology's support and managed services teams, the College will: o o o Analyze how COD reporting files are created within Anthology. Identify why certain student data elements are not being transmitted correctly. Implement configuration changes or other system-level fixes to ensure accurate and complete reporting. • Enhanced manual validation until issues are resolved. If the file creation process is determined to be working "as designed" but still does not meet regulatory expectations, Financial Aid staff will perform manual review and correction of COD files prior to submission, and will monitor error and rejection reports from COD for follow-up. As with Finding 2025-001, the Vice President for Student Affairs and the Director of Financial Aid share responsibility for ensuring these corrective actions are implemented and sustained commencing on the date set forth above.
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were ...
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were duplicated. The duplication was caused by human error during an internal staff transition within the Family and Community Engagement (FACE) department. This led the new manager to incorrectly report employee home visit logs twice. The FACE team will add internal controls during staff transitions to ensure documentation is not duplicated. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: January 1, 2026
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Pla...
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Planned Corrective Action: The District applied for reimbursement of potentially eligible COVID expenditures in 2022. Per an April 5, 2022 FEMA memo “FEMA Continues Funding to Support the Safe Operations of Schools”, school districts could apply for reimbursement for ESSER funded expenditures, and then upon approval of application shift the funds to general fund. “Schools and school districts may utilize FEMA Public Assistance to receive full reimbursement for costs for the purposes above. Schools and districts may also use Elementary and Secondary School Emergency Relief (ESSER) funding from the U.S. Department of Education as a way to provide the up-front cost for the above health and safety measures, and later seek reimbursement through the FEMA Public Assistance process. For example, a local education agency (LEA) may use ESSER funds for costs that may ultimately be covered by FEMA; however, once it receives funds from FEMA for those costs, it must reimburse the ESSER grant account.” FEMA provided District award notification for COVID testing in December 2024 and January 2025, by this time the ESSER grant had closed on September 30, 2024 and the final expenditure reports for ESSER had been submitted to MDE in November 2024. Therefore the District could not complete the allowable general fund swaps. The District notified Michigan Department of Education and Michigan State Police of the timing issue. Upon request from MI State Police, the District provided documentation that available general funds were available to conduct the swaps if the FEMA approval had been received in a timely manner. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: Requested documentation was submitted to Michigan State Police on November 7, 2025
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time...
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time and effort.
The Superintendent will thoroughly review and approve quarterly 'historical expenditure reports" and supporting documentation on a regular basis prior to electronic submissions. Reviews will encompass a search for adjustments and duplicate classifications, and a determination of reasonable vendors, ...
The Superintendent will thoroughly review and approve quarterly 'historical expenditure reports" and supporting documentation on a regular basis prior to electronic submissions. Reviews will encompass a search for adjustments and duplicate classifications, and a determination of reasonable vendors, expense descriptions, budget to actual comparisons, and dates. Corresponding documents will be manually signed and dated to indicate approval.
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