Corrective Action Plans

Finding 529424 (2024-004)

Significant Deficiency 2024

AK

Subrecipient Monitoring

One subrecipient was not monitored appropriately, increasing the risk of noncompliance with grant requirements. Corrective Actions: 1. Standardized Subrecipient Monitoring Procedures: o Develop a formal subrecipient monitoring policy to ensure all subrecipients are reviewed. o Target Completion: Pol...

One subrecipient was not monitored appropriately, increasing the risk of noncompliance with grant requirements. Corrective Actions: 1. Standardized Subrecipient Monitoring Procedures: o Develop a formal subrecipient monitoring policy to ensure all subrecipients are reviewed. o Target Completion: Policy finalized within the end of Fiscal Year 2025. 2. Require Annual Audit Reports from All Subrecipients: o CSS will require all subrecipients to submit annual audit reports to identify any compliance risks. o Target Completion: First audit report request within next fiscal quarter. 3. Designated Subrecipient Compliance Director: o Assign a compliance director within the State Refugee Designee team at CSS to oversee and track subrecipient monitoring, ensuring all required reviews are conducted. o Target Completion: Role assigned within the end of Fiscal Year 2025. Responsible Staff: State Refugee Coordinator in conjunction with Senior Director of Grants and Chief Financial Officer

View Audit 347428

Finding 529422 (2024-002)

Material Weakness 2024

Catholic Social Services, Inc.

AK

Subrecipient Monitoring Reporting

Corrective Actions: 1. Automated Tracking System for Reporting Deadlines: o Enhance a compliance tracking system (Sage Intacct) to record reporting deadlines. o Assign a compliance director (Senior Director of Grants) to review and confirm each FFATA filing monthly. o Target completion date: Within ...

Corrective Actions: 1. Automated Tracking System for Reporting Deadlines: o Enhance a compliance tracking system (Sage Intacct) to record reporting deadlines. o Assign a compliance director (Senior Director of Grants) to review and confirm each FFATA filing monthly. o Target completion date: Within three months. 2. Staff Training on FFATA Compliance: o Conduct or Solicit training sessions for grant managers and finance staff on federal subaward reporting requirements. o Develop a written guide outlining responsibilities for FFATA compliance. o Target completion date: By the end of Fiscal Year 2025. 3. Internal Audit & Oversight Process: o Establish a quarterly compliance review to ensure all subawards are properly documented and reported. o Designate a compliance officer or senior grant staff member to review FFATA reports before submission. o Target completion date: First review to occur within the next fiscal quarter. Responsible Staff: Senior Director of Grants in conjunction with Chief Financial Officer

View Audit 347428

Finding 529403 (2024-002)

None 2024

University of California

CA

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

2024-002 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.06...

2024-002 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Financial Aid Counselors (FAC) can manually award students on the spot and verbally inform students to go online and accept/decline their awards. When this happens, an email may not go out to students. Starting with the 2025-26 financial aid award cycle, we will create a routine in the Banner Financial Aid system that will review student’s email log (RUAMAIL) and if an official email notification is not logged, the system will automatically send one to ensure that every student who is awarded Title IV aid will receive an email notification advising them to review and accept/decline their financial aid award offer. Title IV aid will not disburse until this requirement is met keeping the institution in compliance. To obtain a student’s voluntary consent to participate in electronic actions for the Electronic Signatures in Global and National Commerce Act (“E-Sign Act”), Information Technology Solutions (ITS) will investigate and implement one of the following options: • Reinstate the consent to participate in electronic transactions in R’Web annually and ensure that it captures the history of the acceptance of the Terms of Service (TOS) that will include the date students accepted the TOS. • Present the TOS to students upon logging into Central Authentication Services (CAS) annually and ensure that it captures the history of the acceptance of the TOS that will include the date students accepted the TOS. • Present the TOS to students as a hold annually on Banner that they must acknowledge to clear. Banner records this action on SOAHOLD. The student TOS will be presented to students for acceptance during the first time accessing University systems, depending on the option implemented, and will display it annually during the annual anniversary of the original acceptance. ITS will begin evaluation of the effort in Summer 2025 with a goal of implementing a solution in the 2025-26 academic year. For inquiries regarding the disbursement notifications, please contact Jose A. Aguilar at jose.aguilarjr@ucr.edu. For inquiries regarding the E-Sign Act, please contact Teri Eckman at teri.eckman@ucr.edu

View Audit 347386

Finding 529402 (2024-001)

None 2024

University of California

CA

Student Financial Aid Subrecipient Monitoring

2024-001 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable The Depart...

2024-001 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable The Department of Education provided verification relief for the 2021-22 and 2022-23 aid years by waiving certain verification requirements. If a record was selected for verification but was not verified, schools were to set the code to “S”. The routine was changed for those two years but was carried forward to the 2023-24 aid year. The automated routine has been corrected, and it is currently assigning the correct verification code based on the completion of the student financial aid verification. This correction has been implemented for the current 2024-25 award year cycle and is working properly for the 2024-25 award year cycle. Starting with the 2025-26 award year cycle, in April of 2025 we will add the review of the verification code assignment based on the completion of the student verification files to the already established annual new year roll in the Banner Financial Aid system. The routine will be reviewed and adjusted as needed and ensure that the routine is set up correctly for the 2025-26 award year. For inquiries regarding this finding, please contact Jose A. Aguilar at jose.aguilarjr@ucr.edu.

View Audit 347386

Finding 529399 (2024-003)

None 2024

University of California

CA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2024-003 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal S...

2024-003 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Campus One The Financial Aid and Scholarships (FAS) office will take action to allocate the appropriate staff resources, training, tools and management oversight to ensure timely processing of R2T4s, including the return of applicable funds to COD. We have identified 2 recently hired counseling staff who were trained by our Assistant Director of Compliance on R2T4 processing and provided regulatory and campus updates in the 2024-25 academic year. The staff will complete the initial R2T4 review and calculation on a weekly basis and started this work in February 2025. The FAS team will implement an updated tracking and monitoring mechanism that includes the date of withdrawal, the date the refund is processed, and the date the refund is submitted to the Department of Education. The Assistant Director of Compliance will identify potential delays and check in with staff on their weekly reports. This will allow for corrective action prior to the 45-day deadline. The FAS managers will make R2T4 processing a standing item in management meetings to identify any competing priorities that may contribute to compliance concerns. The report used to identify withdrawn students will be reviewed and revised, with FAS staff input, to create efficiencies for managing the work each week. Anticipated completion date of all adjustments is the end of July 2025, with iterations continuing for reports and the tracking mechanism as needed. For inquiries regarding this finding, please contact Silvia Marquez at semarquez@ucsd.edu. Campus Two While we note that no Return of Title IV Funds calculation errors occurred, the campus will institute improved tracking, reporting, and completion of the secondary review process within the 45-day funds return window. To assist in the review effort the campus has cross-trained multiple staff members to ensure enough personnel have the necessary skills, knowledge, and awareness to manage the review process effectively. Anticipated completion of implementation is May 2025. For inquiries regarding this finding, please contact Nancy Garcia at ngarcia@fas.ucla.edu.

View Audit 347386

Finding 529306 (2024-102)

Material Weakness 2024

The Academy of Tucson

AZ

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.306 § 200.308

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted it...

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

View Audit 347332 Questioned Costs: $1

Finding 529305 (2024-103)

Significant Deficiency 2024

The Academy of Tucson

AZ

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.300 § 200.306 § 200.308

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted it...

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

View Audit 347332

Finding 529300 (2024-004)

Material Weakness 2024

Scott County School District 1

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate, Material Weakness Summary of Finding: This was a repeat finding. An effective internal control system was not designed or implemented at th...

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate, Material Weakness Summary of Finding: This was a repeat finding. An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card High School Graduation Rate compliance requirement until the 2023/2024 school year. The School Corporation had not established internal controls for most of the audit period to ensure that the required documentation to remove a student from a cohort was confirmed and maintained with the withdrawal forms prior to removing the student from the cohort. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Starting in the 2023/2024 school year, the building principal now signs off on the supporting documentation that is being retained to support a student’s withdrawal from the cohort. Anticipated Completion Date: The anticipated completion date was the 2023/2024 school year.

View Audit 347331

Finding 529295 (2024-003)

Material Weakness 2024

Scott County School District 1

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll cle...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll clerks. Lack of an internal control. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Clerk will submit the reimbursement requests to the corporation Business Manager for review before the reimbursement is submitted to MAESSU for payment. Anticipated Completion Date: The anticipated completion date will be with the April reimbursement submission.

View Audit 347331

Finding 529261 (2024-001)

Significant Deficiency 2024

Finger Lakes Community College

NY

Student Financial Aid Subrecipient Monitoring

SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management...

SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. As part of this process, the College should then review the current policies and procedures at least annually to determine if any updates should be made. Corrective Action Plan: The College agrees with the finding and as of March 2025 the College has contracted with an outside third party to perform an formal risk assessment. Once the risk assessment has been performed the College will work on ensuring the appropriate safeguards are in place and remediation plans identified. Additionally policies continue to be reviewed and updated through the governance process at the College. FLCC Responsible Party: Jason Tack, VP of Finance and Administration, jason.tack@flcc.edu, 585-785-1208. Audit finding will be corrected by 8/31/2025.

View Audit 347304

Finding 529257 (2024-001)

Significant Deficiency 2024

Pennsylvania Association of Regional Food Banks

PA

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and C...

Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and Cause: There were three instances out of 40 distributions tested where this signoff was not completed. Due to the hectic environment at the lead agencies during food distribution day, oversights have occurred when obtaining the required client signoff. Statement of Concurrence or Nonconcurrence: PARF management has reviewed the 2024-001 finding and concurs with the recommendations as stated. Corrective Action: PARF has an extensive training process in place for lead agencies, in relation to grant award compliance requirements, which includes the provision of training manuals and monthly phone calls to review matters. In addition, PARF provides updates to the lead agencies as new or amended requirements are enacted. Further, PARF does periodic reviews of the lead agencies and completes the biennial review Form 502035 CSFP Management Evaluation. PARF will continue to reiterate the required signoff process with the lead agencies during phone calls, training session and reviews. In addition for FY 2025 PARF will be conducting a mandatory webinar to ensure all the lead agencies are understanding the procedure and why it is important for 100 percent accuracies -https://docs.google.com/presentation/d/1YZgcq7SY4DmvhYrKZE8sp-NDhpuzn827PZDZ0xAKDw/edit?usp=sharing

View Audit 347284

Finding 529234 (2024-002)

Significant Deficiency 2024

Behavioral Health Initiatives, Inc.

TN

Subrecipient Monitoring Reporting Significant Deficiency

Management will develop procedures to ensure that reports are submitted timely and any new filing deadlines will be documented and met without exception.

View Audit 347253

Finding 529233 (2024-001)

Significant Deficiency 2024

Behavioral Health Initiatives, Inc.

TN

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management will develop additional controls to ensure that bank reconciliations are prepared timely and perform second review as per current internal control policy.

View Audit 347253

Finding 529230 (2024-004)

Material Weakness 2024

Daleville Community Schools

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Nu...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER III amounts reported for the reports covering the FY22 time period ($22,163 and $409,347, respectively) did not agree to the underlying expenditure records ($3,796 and $404,347 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II amount reported for the reports covering the FY23 time period ($131,439) did not agree to the underlying expenditure records ($153,216) for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the FY23 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Dr. David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The correction will be on the next annual report when it is due.

View Audit 347248

Finding 529221 (2024-002)

Material Weakness 2024

Elwood Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.303

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the reporting compliance requirements. The School Corporation was not formally reviewing the ESSER reports being submitted by comparing the underlying expenditure detail to the amounts reported for each grant for the reporting period. Context: The School Corporation was required to submit six Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. Crowe noted the following reporting errors for the Year 3 reports (July 1, 2021 through June 30, 2022). The ESSER If amount reported on the Year 3 report ($585,040) did not agree to the underlying expenditure records ($581,468). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Crowe noted the ESSER Ill amount reported on the Year 3 report ($0) did not agree to the underlying expenditure records ($351,831). Crowe noted the following reporting error for the Year 4 reports (July 1, 2022 through June 30, 2023). The ESSER Ill amount reported on the Year 4 report ($1,062,765) did not agree to the underlying expenditure records ($1,054,618). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure the amounts reported in the annual data reports agree to the underlying support and detail from the internal records. A formal review process will be implemented. Person responsible for implementation and projected implementation date: The Corporation's Treasurer and Superintendent will be responsible for implementing the corrective action, which will be implemented immediately.

View Audit 347212

Finding 529206 (2024-002)

Significant Deficiency 2024

City of Independence, Missouri

MO

Procurement, Suspension & Debarment Subrecipient Monitoring

On contracts and purchase orders where the City is utilizing Federal funds – we will add a clause to contracts and require a certification on purchase orders for suspension and debarment. This will require the vendor to certify that they are not debarred, suspended, or otherwise excluded from or in...

On contracts and purchase orders where the City is utilizing Federal funds – we will add a clause to contracts and require a certification on purchase orders for suspension and debarment. This will require the vendor to certify that they are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.

View Audit 347195

Finding 529199 (2024-002)

Significant Deficiency 2024

Humboldt County Resource Conservation District

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.318 § 200.327

The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Dir...

The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Directors

View Audit 347185

Finding 529198 (2024-001)

Significant Deficiency 2024

Humboldt County Resource Conservation District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Form AD-1048 has been completed for all contactors that are being used in regards to the grant. Procedures have be put to place to ensure that any new contractor used by the District has the necessary forms filled out as subject to the grants terms.

View Audit 347185

Finding 529197 (2024-001)

Significant Deficiency 2024

Jewish Family Service

MI

Subrecipient Monitoring Reporting

Finding: For sub-awards subject to the Transparency Act, the awarding entity must enter the award information in agreement with the award contract to the FSRS portal. Management was unaware of the requirement for award information to be input into the FSRS portal for a sub-award that was subject to ...

Finding: For sub-awards subject to the Transparency Act, the awarding entity must enter the award information in agreement with the award contract to the FSRS portal. Management was unaware of the requirement for award information to be input into the FSRS portal for a sub-award that was subject to the Transparency Act. Corrective Action: 1. Review and ensure policies are up to date and comply with the federal awards that are subject to the Funding Accountability and Transparency Act. 2. For new federal awards, identify whether the award is subject to the Federal Funding Accountability and Transparency Act and develop a task list to ensure the reporting requirement is fulfilled timely. 3. Designate the reporting responsibility with respect to FFATA reporting to the accounting manager with oversight from the Controller and CFOO. 4. Establish periodic meetings between programs, compliance and finance to report on the FFATA compliance when applicable.

View Audit 347183

Finding 529187 (2024-005)

Significant Deficiency 2024

Oregon Food Bank, Inc.

OR

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.317 § 200.327

OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Correc...

OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Corrective Action Plan: Oregon Food Bank finalized and implemented a procurement policy and a specific procurement policy for purchases made with federal funds, aligned with federal procurement standards and effective October 2024. Internal controls will be established to ensure adherence to the policy, and procedures will require retaining documentation of the procurement process to demonstrate compliance. These improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date is June 30, 2026.

View Audit 347167

Finding 529182 (2024-004)

Significant Deficiency 2024

Oregon Food Bank, Inc.

OR

Questioned Costs Reporting Subrecipient Monitoring § 200.414

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nut...

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nutrition Incentive Program OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will assess requirements and establish procedures and internal controls to ensure the consistent application, billing, and reporting of indirect cost rates across all federal awards. This will include collaborating with grant writing staff during the pre-application and pre-award phases to centralize grant preparation and ensure indirect rates are accurately applied in grant proposals and budgets. Multiple dedicated review steps in the grant lifecycle will be developed to both ensure accuracy of the rates charged and address any changes from the Federal Government. Existing strengths, tools, and capacity will be reviewed to support this process, including alignment with subrecipient indirect cost practices. Training will be provided to individuals responsible for these controls to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date is June 30, 2026.

View Audit 347167 Questioned Costs: $1

Finding 529128 (2024-002)

Significant Deficiency 2024

Department of Housing of the Commonwealth of Puerto Rico

PR

Reporting Subrecipient Monitoring Significant Deficiency

VIEWS OF RESPONSIBLE OFFICIALS The designated officer of the CDBG-DR/MIT Program to perform this task resigned suddenly. We recruited and trained a new officer, but during the transition process some First-Tier Sub awardee contracts were not reported in the Subaward Reporting System (FSRS) in a time...

VIEWS OF RESPONSIBLE OFFICIALS The designated officer of the CDBG-DR/MIT Program to perform this task resigned suddenly. We recruited and trained a new officer, but during the transition process some First-Tier Sub awardee contracts were not reported in the Subaward Reporting System (FSRS) in a timely manner. To prevent this condition in the future, we have trained more than one officer for this task, and have placed a level of supervision to fully comply with this obligation. IMPLEMENTATION DATE Already implemented RESPONSIBLE PERSON Félix Hernández Cabán Director of Disaster Recovery CDBG-DR Program Finance & Monitoring Division

View Audit 347065

Finding 529125 (2024-001)

Material Weakness 2024

Knox Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identif...

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The Annual Data Reports were prepared by School Corporation management and reviewed by someone other than the preparer, however, the review process in place did not prevent, or detect and correct, errors. During testing of the accuracy of the annual data reports, the following errors were noted: • The Year 2 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $2,219,321 for the period of July 1, 2021 through June 30, 2022 compared to underlying disbursement detail of $2,715,940. • The Year 3 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $224,309 for the period of July 1, 2022 through June 30, 2023 compared to underlying disbursement detail of $306,194. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There will be two people who look over the ESSER reports before submitting to the state to make sure they agree with the reports. Anticipated Completion Date: When next report is due.

View Audit 347048

Finding 529112 (2024-001)

Significant Deficiency 2024

Chicago Commons Association

IL

Subrecipient Monitoring Cash Management Internal Control / Segregation of Duties § 200.305 § 200.516

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to v...

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to verify account updates; • Limited the amount of per vendor/subrecipient daily payments to our insurance limits, with verifications prior to releasing additional funds when the total payment exceeds the insurance limits; • Subrecipient payment receipt is verified by both the subrecipient and the Commons grants team; • Updated our policy and procedures to direct our subrecipients to request banking changes through our procurement system and not through email; and • Expanded implementation of our Kissflow procurement system across the organization, which includes new vendor process as well as a change of vendor information module. Vendor changes would be approved first by the program/department that works with the vendor prior to Finance approval. Completion Date With the exception of implementing the change of vendor information module in Kissflow, the above actions have all been completed by the date of this report. The projected completion date for Kissflow change of vendor information module is April 30, 2025. Responsible Party Dana Thomas, Chief Financial Officer Angela Allen, Vice President of Finance

View Audit 347007

Finding 529106 (2024-002)

Significant Deficiency 2024

Ecological Society of America, INC

DC

Subrecipient Monitoring § 200.332

Views of Responsible Officials: Because the subawards were given to partners who NSF requested that ESA work with, it was not deemed necessary to perform the risk assessment. These will be done in the future. To address audit finding regarding subawardee risk assessments, ESA will create a defined r...

Views of Responsible Officials: Because the subawards were given to partners who NSF requested that ESA work with, it was not deemed necessary to perform the risk assessment. These will be done in the future. To address audit finding regarding subawardee risk assessments, ESA will create a defined risk assessment policy that will be implemented for all subawardees.

View Audit 346998

Corrective Action Plans

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