Corrective Action Plans

Finding 528469 (2024-010)

Material Weakness 2024

State of Kansas

KS

Subrecipient Monitoring Reporting § 200.1 § 200.303

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: The Kansas Division of Emergency Management (Management) did not report subawards to FSRS during SFY 2024 in compliance with FSRS reporting requirements. Recommendation: We r...

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: The Kansas Division of Emergency Management (Management) did not report subawards to FSRS during SFY 2024 in compliance with FSRS reporting requirements. Recommendation: We recommend that Management continue to implement its corrective action plan from the prior year. Management should review and update its procedures and internal controls to ensure that subawards are accurate, reported timely and reviewed timely to FSRS. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Management will download awards every 2 weeks to ensure that the data is reviewed and entered timely. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief Planned completion date for corrective action plan: Ongoing

View Audit 346470

Finding 528463 (2024-008)

Significant Deficiency 2024

State of Kansas

KS

Subrecipient Monitoring Reporting § 200.1 § 200.303

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: The Kansas State Department of Health and Environment (Department) reported awards issued to contractors to FSRS when contractor agreements are not considered subawards and should not be reported. R...

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: The Kansas State Department of Health and Environment (Department) reported awards issued to contractors to FSRS when contractor agreements are not considered subawards and should not be reported. Recommendation: We recommend that the Department develop procedures and internal controls to ensure that required subawards are reported accurately to FSRS and that contractor agreements are not reported to FSRS as subawards. Views of responsible officials: Management agrees with the finding. Action taken in response to finding: Process has been updated so that only POs coded as Aid To Local (550100, 550600) will be submitted on FFATA reports. Name(s) of the contact person(s) responsible for corrective action: Shelley Russell, Lead Fiscal Analyst, Division of Public Health Planned completion date for corrective action plan: Immediately. New process will be used for any reports moving forward. Reports that have already been submitted will be reviewed and updated so that only ATL obligations are reflected on the reports.

View Audit 346470

Finding 528459 (2024-006)

Material Weakness 2024

State of Kansas

KS

Subrecipient Monitoring § 200.303 § 200.331

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information. Recommendation: We recommend that the Depar...

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information. Recommendation: We recommend that the Department develop a subaward template that includes all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. Views of responsible officials: Management disagrees with the finding. Multi-year subrecipient agreements executed prior to March 2024 did not include the Sub-Recipient Agreement Submission Form. The agreements were not re-executed after March 2024 to include the form. The audit findings should only pertain to agreements newly executed after March 2024; however, because the audit included agreements executed prior to March 2024, the audit found that information is missing. Action taken in response to finding: All subrecipient agreements executed after March 2024 include the Sub-Recipient Agreement Submission Form. Name(s) of the contact person(s) responsible for corrective action: Farah Ahmed and Sheri Tubach, Bureau of Epidemiology and Public Health Informatics Planned completion date for corrective action plan: Completed

View Audit 346470

Finding 528448 (2024-001)

Material Weakness 2024

Prairie Heights Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.313 § 200.317 § 200.318 § 200.319

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was...

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Description of Corrective Action Plan: School Corporation will reach out to the Cooperative to discuss internal controls over procurement, and suspension and debarment and request annual listing of vendors exceeding federal and state procurement thresholds to ensure Cooperative adheres to regulations and established procurement policy and request that procurement policies are written, and all procurements are fully documented based upon the applicable federal and state standards Anticipated Completion Date: The School Corporation will implement the actions noted above quarterly to ensure proper internal controls are in place. The treasurer will request this information starting in April of 2025 for the first quarter of the calendar year.

View Audit 346468

Finding 528364 (2024-010)

Significant Deficiency 2024

Penasco Independent School District

NM

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Significant Deficiency § 200.430

Recommendation We recommend that for hourly employees, both the employee and the supervisor sign the timecard, either manually or electronically, to provide evidence that the employee takes responsibility for the hours worked and the supervisor can attest to the hours worked. Management Response Co...

Recommendation We recommend that for hourly employees, both the employee and the supervisor sign the timecard, either manually or electronically, to provide evidence that the employee takes responsibility for the hours worked and the supervisor can attest to the hours worked. Management Response Corrective Action: The District has actively been working with staff and management to review and sign their timesheets before processing payroll. Due Date of Completion: June 30, 2025 Responsible Party(ies): Business Manager

View Audit 346420

Finding 528361 (2024-005)

None 2024

West Harvey-Dixmoor School District 147

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 2 reports were filed late. Plan: Management will review its policies and procedures regarding timely grant expenditure report submissions with staff. Furthermo...

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 2 reports were filed late. Plan: Management will review its policies and procedures regarding timely grant expenditure report submissions with staff. Furthermore, staff will be properly trained for adhering to grant compliance reporting deadlines. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Dr. Jerry Jordan, Interim Superintendent. Management Response: Management will work together with staff to verify that grant compliance reporting deadlines are met moving forward.

View Audit 346419

Finding 528360 (2024-003)

Material Weakness 2024

Martin Luther King, Jr. Child Care Center Association, Inc.

KS

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness

2024-003 Ineffective Internal Controls over Authorization of ACH Payments of Federal Expenditures (Material Weakness) Federal Agency: U.S. Department of Education Pass through entity: Kansas Department of Education Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 A...

2024-003 Ineffective Internal Controls over Authorization of ACH Payments of Federal Expenditures (Material Weakness) Federal Agency: U.S. Department of Education Pass through entity: Kansas Department of Education Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 Award Period: June 30, 2024 Recommendation: The Board and/or management approve ACH payments of federal expenditures with evidence of approval. Acton Taken (Unaudited): Management currently receives all ACH submissions rom bank to business email. Management will have a Board Member and/or management to sign/stamp ACH printout that is generated when input is complete. Contact Name – Shalonda Smith, CACFP Director Expected Completion Date – 3/31/2025

View Audit 346415

Finding 528355 (2024-002)

Material Weakness 2024

Bucks County Community College

PA

Subrecipient Monitoring Material Weakness Reporting

Finding 2024-002: Reporting (Material Weakness, repeat finding) U.S. Treasury Department – Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Statement of Condition: During testing several of the College’s quarterly ARPA expenditure reports were submitted to Bucks County after the deadli...

Finding 2024-002: Reporting (Material Weakness, repeat finding) U.S. Treasury Department – Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Statement of Condition: During testing several of the College’s quarterly ARPA expenditure reports were submitted to Bucks County after the deadline per the grant agreements. The reports tested were submitted between 1-189 days late. Criteria: The College is a subrecipient of ARPA funding from Bucks County. The grant agreements state the College must submit quarterly expenditure reports to the County 11 days after the end of the quarter (calendar year). Cause: The College did not have adequate controls in place to ensure the timely filing of expenditure reports. Effect: Failure to comply with ARPA reporting requirements could jeopardize future federal funding. Recommendation: We recommend that the College reconcile, review, and submit reports in a timely manner based on grant agreements. View of responsible officials and planned corrective actions: Management agrees with the finding. The College has strengthened the process to ensure the timely and accurate reconciliation, review, and submission of expenditure reports consistent with the requirements of all grant agreements. The College’s Grant Office created a Grant Project Management Platform to track compliance requirements for all grants including timely invoicing and reporting. This platform provides a dashboard and reminder functions for deadline monitoring. The Associate Dean, Academic Partnerships who manages the Grants Office, participates in weekly meetings with the Grants Manager and Executive Director, Research, Assessment, Data Analytics, & Reporting, to review deadlines and facilitate the timely and accurate completion of all tasks related to grant compliance. Name(s) of Contact Person(s) Responsible for Corrective Action: Patricia Smallacombe, Associate Dean, Academic Partnerships Anticipated Completion Date: February 28, 2025

View Audit 346399

Finding 528354 (2024-007)

Material Weakness 2024

Town of Hanna

WY

Subrecipient Monitoring Reporting

CORRECTIVE ACTION ITEM - MONITORING and REPORTING - CFDA# 15.252- ABANDON MINE LAND RECLAMATION Individual Responsible: Ann Calvert Treasurer Anticipated Completion Date: 03/31/2025 Corrective Action/Management Response: The Town Treasurer has reached out via e-mail to AML representatives Jennifer R...

CORRECTIVE ACTION ITEM - MONITORING and REPORTING - CFDA# 15.252- ABANDON MINE LAND RECLAMATION Individual Responsible: Ann Calvert Treasurer Anticipated Completion Date: 03/31/2025 Corrective Action/Management Response: The Town Treasurer has reached out via e-mail to AML representatives Jennifer Russel and David Pendleton to help with the filing of a SF-245 required report.

View Audit 346396

Finding 528352 (2024-008)

Material Weakness 2024

Union School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the fed...

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have a contract with the company that included the clause for the federal wage rate requirements. The total amount disbursed and reported on the SEFA during the audit period is $467,094 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will ensure that they follow the Davis-Bacon requirements. Anticipated Completion Date: 05/01/2025

View Audit 346388

Finding 528350 (2024-007)

Material Weakness 2024

Union School Corporation

IN

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

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 II and ESSER III amounts reported for the reports covering the ...

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 II and ESSER III amounts reported for the reports covering the FY22 time period ($0 and $0, respectively) did not agree to the underlying expenditure records ($79,112 and $99,245 respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($178,829 and $874,154, respectively) did not agree to the underlying expenditure records ($159,450 and $789,489), respectively, 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 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will make sure all expenditures match annual data reports. Anticipated Completion Date: 05/01/2025

View Audit 346388

Finding 528349 (2024-006)

Material Weakness 2024

Union School Corporation

IN

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Material Weakness § 200.303

Context: The School Corporation was required to submit one workbook covering FY21 and FY22 to the Indiana Department of Education (IDOE) during the audit period to meet federal the Level of Effort - Maintenance of Effort requirements. We noted the amounts reported covering the FY21 time period ($86...

Context: The School Corporation was required to submit one workbook covering FY21 and FY22 to the Indiana Department of Education (IDOE) during the audit period to meet federal the Level of Effort - Maintenance of Effort requirements. We noted the amounts reported covering the FY21 time period ($865,515) did not agree to the underlying expenditure records ($1,474,349 for the period of July 1, 2020 through June 30, 2021). Additionally, we noted the amounts reported covering the FY22 time period ($937,948) did not agree to the underlying expenditure records ($2,695,619, for the period of July 1, 2021 through June 30, 2022). Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Manager will work with INDLS to ensure the MOE workbook matches expenditures. Anticipated Completion Date: 06/30/25

View Audit 346388

Finding 528348 (2024-005)

Material Weakness 2024

Union School Corporation

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.309 § 200.461

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. Th...

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. The School Corporation did not pay the service provider until April 30, 2024 for $258,488 for the services provided. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will have all Special Ed funds paid before liquidation date. Anticipated Completion Date: 12/29/25

View Audit 346388

Finding 528343 (2024-004)

Significant Deficiency 2024

Union School Corporation

IN

Cash Management Subrecipient Monitoring § 200.303 § 200.305

Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $3,782,381 for the audit period. For all invoices during the...

Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $3,782,381 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. There was significant delay in the time between the School Corporation was reimbursed by IDOE and when the School Corporation paid the service provider. The delay in payment was in the range of 2 – 4 months for the payments made during the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will pay Special Ed invoice to INDLS within the same week as receiving the reimbursement. Anticipated Completion Date: 05/01/2025

View Audit 346388

Finding 528342 (2024-003)

Material Weakness 2024

Union School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. For 1 of the 5 sample payments to the service provider, the School Corporation only reviewed a summary level invoice from the service provider which did not include the underly...

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. For 1 of the 5 sample payments to the service provider, the School Corporation only reviewed a summary level invoice from the service provider which did not include the underlying support or detail of the reimbursable costs incurred by the service provider. The sample amount paid to the service provider without underlying support or detail was $1,138,684. The lack of underlying support was isolated to the 22611-122-PN01 grant. The School Corporation received the support for all other payments tested. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation and INDLS has already put in place to receive a detailed invoice for Special Education funds. Going forward INDLS will provide detailed invoices for all reimbursable costs. Anticipated Completion Date: 05/01/2025

View Audit 346388

Finding 528310 (2024-005)

Significant Deficiency 2024

Workforce Dev Bd of Flagler & Volusia CO Dba Careersource Flagler Volu

FL

Subrecipient Monitoring

2024-005 – WIOA Cluster – Subrecipient Financial Monitoring This finding recommends the Organization completes subrecipient financial monitoring for FY24 for the WIOA cluster to comply with the grant compliance requirements, to implement additional controls over subrecipient monitoring going forwar...

2024-005 – WIOA Cluster – Subrecipient Financial Monitoring This finding recommends the Organization completes subrecipient financial monitoring for FY24 for the WIOA cluster to comply with the grant compliance requirements, to implement additional controls over subrecipient monitoring going forward, and to verify that subrecipients get all required audits completed. The Organization is working toward completing this subrecipient financial monitoring and will continue to improve controls in this area during FY25 after the consolidation.

View Audit 346369

Finding 528301 (2024-001)

Significant Deficiency 2024

Miles College

AL

Student Financial Aid Reporting Subrecipient Monitoring

Finding 2024-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Supplemental Opp...

Finding 2024-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2024; Teachers Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Instances of noncompliance were noted as more fully described in the context below. Questioned Costs – $0 Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: (a) Six (6) out of 6 students tested for withdrawals and the return of Title IV funds were completed using the incorrect semester dates. 34 CFR 668.22. (b) Three (3) out of 3 students tested for Enrollment Reporting had untimely reporting. 34 CFR 685.309(b), 34 CFR 682.610(c), 34 CFR 674.33(j). (c) We noted postings for the Fall and Spring awards in Direct Loans and Pell were posted to student accounts after the payment period and fiscal year ended June 30, 2024. Cause – Oversight by responsible employees of properly monitoring regulatory requirements. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. View of Responsible Officials – (a) All six students have been recalculated with the correct date. The issue originated from implementing the Colleague (ERP) system. The College has now established a procedure to ensure this process is reviewed during the RT24 calculation. (b) The College has hired a financial professional with experience in the Colleague (ERP) system. This professional has provided staff training and established standard operating procedures to promote better operating efficiency and effectiveness. (c) The issue resulted from implementing the Colleague (ERP) system. Standard Operating Procedures have been developed, and the financial aid staff has been trained to help prevent these types of issues in the future.

View Audit 346360

Finding 528280 (2024-001)

None 2024

Schuyler-Industry Community Unit School District No. 5

IL

Subrecipient Monitoring Reporting § 200.328

Condition: The District did not comply with the reporting requirements with respect to filing accurate quarterly reports with the ISBE. Plan: The District will submit accurate expenditure reports in the future regardless of the project end date. Anticipated Date of Completion: July 1, 2024. Name of ...

Condition: The District did not comply with the reporting requirements with respect to filing accurate quarterly reports with the ISBE. Plan: The District will submit accurate expenditure reports in the future regardless of the project end date. Anticipated Date of Completion: July 1, 2024. Name of Contact Person: Dr. Beau Fretueg, Superintendent. Management Response: We will review grant expenditures on a quarterly basis and submit accurate expenditure reports to the ISBE as required.

View Audit 346328

Finding 528272 (2024-001)

Significant Deficiency 2024

Columbia County District School Board

FL

Questioned Costs Subrecipient Monitoring § 200.403 § 200.431

Planned Corrective Action: The District agrees with the finding. We will work with DOE and other district finance officers to ensure processes going forward are accurate and appropriate with no programs being overcharged. Anticipated Completion Date: 06/30/2025 Responsible Contact Person: Lindsay...

Planned Corrective Action: The District agrees with the finding. We will work with DOE and other district finance officers to ensure processes going forward are accurate and appropriate with no programs being overcharged. Anticipated Completion Date: 06/30/2025 Responsible Contact Person: Lindsay Laxton, CFO

View Audit 346313 Questioned Costs: $1

Finding 528264 (2024-005)

Material Weakness 2024

Housing Authority of the City of Newton, Kansas

KS

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Finding 2024 – 005: Deposit Collateralization We agree with the finding as Union State Bank had bonds, they had listed which did qualify meet HUDs requirements. We will work with the Union State Bank to make sure all collateral pledged meets HUD requirements.

View Audit 346293

Finding 528259 (2024-002)

None 2024

Town of Arrowsic

ME

Internal Control / Segregation of Duties Subrecipient Monitoring

Finding: Reconciliation of the Town’s Accounting Records During the audit, we proposed 20 journal entries to be recorded by management of which 8 were material. Name of contact person responsible for corrective action: Eileen Bonine, Treasurer Anticipated completion date: June 30, 2025 Corrective Ac...

Finding: Reconciliation of the Town’s Accounting Records During the audit, we proposed 20 journal entries to be recorded by management of which 8 were material. Name of contact person responsible for corrective action: Eileen Bonine, Treasurer Anticipated completion date: June 30, 2025 Corrective Action Plan: This was mostly due to turnover of Town personnel and implementation of a new accounting software, which resulted in issues with beginning balances and reconciliation of accounts. Management realizes the importance of performing reconciliations and is in the process developing processes for future reconciliations

View Audit 346292

Finding 528243 (2024-001)

Significant Deficiency 2024

Merced County

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.332

COUNTY OF MERCED CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2024 Federal Award Findings and Questioned Costs Finding 2024-001 – Procurements and Suspension and Debarment (Significant Deficiency) Management’s Response or Department’s Response Management agrees with the finding and recomm...

COUNTY OF MERCED CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2024 Federal Award Findings and Questioned Costs Finding 2024-001 – Procurements and Suspension and Debarment (Significant Deficiency) Management’s Response or Department’s Response Management agrees with the finding and recommendation. Views of Responsible Officials and Corrective Action The County has confirmed that the internal procurement process incorporates the verification that contractors are in possession of valid, applicable licenses and are not barred, suspended or otherwise excluded from receiving federal funds prior to engaging in contracted work. Reference to this process has not been regularly documented; going forward, verifications will be documented on the contract review cover sheet to further support the completion of the process. Copies of supporting documentation will be attached, when applicable, to demonstrate eligibility. Anticipated Completion Date/Completion Date April 2025 Contact Information of Responsible Official Name: Vanessa Anderson Title: Deputy County Executive Officer Phone: 209-385-7456

View Audit 346270

Finding 528145 (2024-004)

Material Weakness 2024

Clay Community Schools

IN

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The school corporation had not designed or implemented a system of internal controls to ensure that the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) wer...

FINDING 2024-004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The school corporation had not designed or implemented a system of internal controls to ensure that the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The reports were prepared by the Director of Business Affairs without a documented oversight, review or approval process in place to prevent, or detect and correct, errors. It is recommended that the school corporation’s management establish internal controls to ensure compliance with the grant agreement and Reporting compliance requirement. Any and all future ESSER reports submitted in Jotform should document an oversight, review or approval process by someone other than the Director of Business Affairs. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When completing data reporting, as requested by the state, for federally funded emergency relief grant funding, the Director of Business Affairs will compile the data necessary to complete the reporting. The data will then be presented to the appropriate member of corporation management for review – data related to student enrollment, eligibility, or other information will be presented to the corporation Data Coordinator. Data related to employee positions, or other employment related data, will be presented to the Director of Human Resources. All other data, including but not limited to corporation financial data, will be presented to the Assistant Superintendent. Anticipated Completion Date: Immediately, upon next required data submission for Education Stabilization Fund reporting.

View Audit 346210

Finding 528141 (2024-003)

Material Weakness 2024

Clay Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests & Provisions – Supplement Not Supplant Summary of Finding: During the Audit period, there were three Title I applications. One of the three applicable grant year applications included information in the su...

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests & Provisions – Supplement Not Supplant Summary of Finding: During the Audit period, there were three Title I applications. One of the three applicable grant year applications included information in the supplement, not supplant section. The other two applications were blank for this section. Documentation of the calculations and per pupil expenditure comparisons were not provided for the audit. Additionally, the Indiana Department of Education (IDOE) monitors compliance with this requirement using Comparability Reports, which compare Full-Time Equivalent (FTE) staff positions for Title I schools to FTE staff positions for non-Title I schools within the school corporation. Although IDOE determined that FTE staff positions were comparable in the 2022, 2023, and 2024 Comparability reports, the school corporation was unable to provide supporting documentation for the FTE staff numbers reported to IDOE. It is recommended that the school corporation adopt and document an acceptable methodology to allocate State and local funds to schools. In addition, it is recommended the calculation of such methodology and any other supporting documentation be retained for audit. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Title I Grant Coordinator, currently Dr. Brady Scott, will monitor this requirement using Comparability reports, as an option considered by the Indiana Department of Education (IDOE). In doing so, the Grant Coordinator will complete a list of FTE staff positions for each Title I school, as well as non-Title I school according to the methodology designed for school corporations as communicated by the IDOE. The Grant Coordinator will confer with the corporation Payroll Specialist (currently Mary Mershon) to ensure accuracy of the data used to complete the reporting, and both the Grant Coordinator and the Director of Business Affairs will maintain a record of the data used to complete the report. Anticipated Completion Date: July 2025

View Audit 346210

Finding 528139 (2024-001)

Material Weakness 2024

Clay Community Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary porti...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: The school corporation did not have a documented oversight, review, or approval process in place to ensure the accuracy of enrollment and poverty data in the Eligible School Summary portion of the Title I application, which is how Title I funding is determined. It is recommended that the school corporation’s management strengthen its system of internal controls to ensure that data in the Eligible School Summary section of the Title I application has been verified for accuracy to the corresponding period’s Pupil Enrollment (PE) report data. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Real time reporting will be compiled by the Data Management Specialist (currently Stephanie Jackson) and will be reviewed by the Title I Grant Coordinator (currently Dr. Brady Scott). Annual Financial reports will be compiled by the Director of Business Affairs (currently John Szabo), and prior to submission those reports will be reviewed by the Title I Grant Coordinator. Anticipated Completion Date: July 2025

View Audit 346210

Corrective Action Plans

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