Corrective Action Plans

Finding 526244 (2024-017)

Significant Deficiency 2024

VA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Responsible Contact Person(s): Steve Hanoka, Information Security Officer Corrective Action Planned: Third-party Management that will cover ensuring all deliverables required are part of a procedure and work instruction. In addition, to specifically address the points in the finding, ISO will ensure...

Responsible Contact Person(s): Steve Hanoka, Information Security Officer Corrective Action Planned: Third-party Management that will cover ensuring all deliverables required are part of a procedure and work instruction. In addition, to specifically address the points in the finding, ISO will ensure that the work instructions cover obtaining a confirmation on the geographic location of sensitive data monthly and vulnerability scan results at least every 90 days. During this procedure implementation, ISO will also work to specifically obtain these deliverables from the vendor in question. Estimated Completion Date: 3/31/2025

View Audit 345214

Finding 526238 (2024-105)

None 2024

Commonwealth of Virginia

VA

Questioned Costs Subrecipient Monitoring

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Diana Clark, Assistant Director of Division of Benefit Programs Frank Smith, Associate Director of Benefit Programs Mark Golden, Economic Assistance and Employment Manager - Division of Benefit Programs Corrective Action Plan...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Diana Clark, Assistant Director of Division of Benefit Programs Frank Smith, Associate Director of Benefit Programs Mark Golden, Economic Assistance and Employment Manager - Division of Benefit Programs Corrective Action Planned: DSS will work to provide additional training to local agency eligibility workers on how to properly determine and document eligibility determinations in the case management system. Additionally, DSS will consider monitoring local agency eligibility worker’s use of manual overrides to confirm that they properly document eligibility determinations in the case management system. Estimated Completion Date: 12/31/2025

View Audit 345214 Questioned Costs: $1

Finding 526237 (2024-104)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additio...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additionally, DSS will create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526226 (2024-106)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 3/15/2025

View Audit 345214

Finding 526223 (2024-101)

Material Weakness 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Eligibility Material Weakness

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Mark Golden, Economic Assistance and Employment Manager - Division of Benefit Programs Corrective Action Planned: Perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Mark Golden, Economic Assistance and Employment Manager - Division of Benefit Programs Corrective Action Planned: Perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. A Change Request has been submitted to address these findings. The results of the implementation and effectiveness of the implemented changes will be analyzed. Benefit Program working with appropriate parties to resolve outstanding errors. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526222 (2024-086)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring § 200.332

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A spreadsheet to track monitoring activities by the BP SRM Coordinator was developed and implemented to ensure that Program Consultants adhere to the developed schedule. The BP SRM Coordinator reviews t...

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A spreadsheet to track monitoring activities by the BP SRM Coordinator was developed and implemented to ensure that Program Consultants adhere to the developed schedule. The BP SRM Coordinator reviews the completed audit documents to ensure that all required audit documents are uploaded to the enterprise management application timely and that reviews are conducted in accordance with the SRM Plan. A SRM monitoring desk tool will be created for Practice Consultants as a quick reference to the SRM Plan. Training for all Program Consultants conducting SRM will be provided on the new updated monitoring plan as well as ongoing training for newly hired Program Consultants. Estimated Completion Date: 3/31/2025

View Audit 345214

Finding 526221 (2024-085)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring § 200.332

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A risk assessment tool was developed as part of the SFY2024 SRM Plan and will be implemented with the new plan. Risk Assessments were included in the FY2024 and FY2025 Business Plan Subrecipient Monitori...

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A risk assessment tool was developed as part of the SFY2024 SRM Plan and will be implemented with the new plan. Risk Assessments were included in the FY2024 and FY2025 Business Plan Subrecipient Monitoring plans. Both the Regional Practice Consultants and Home Office staff completing SRM are required to complete Risk Assessments for the upcoming review year. DSS has found some issues with a few staff members not completely understanding the process; however, after additional trainings were completed, this should not occur with the FY2026 review cycle. Estimated Completion Date: 8/1/2025

View Audit 345214

Finding 526220 (2024-084)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.332

Responsible Contact Person(s): Ousman Kah, Subrecipient Monitoring Coordinator Kevin Platea, Chief Information Officer Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply wi...

Responsible Contact Person(s): Ousman Kah, Subrecipient Monitoring Coordinator Kevin Platea, Chief Information Officer Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply with these requirements. A new budget request has been submitted for funding of a contingent Subrecipient Monitoring System solution. This will help bridge the deficiencies noted until an integrated permanent solution is implemented. Additionally, an interim solution is being considered where these subrecipients will be reviewed and tracked through a manual system. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526219 (2024-083)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Responsible Contact Person(s): Michele Skaggs, Director of General Services Adrienne Childress, Strategic Sourcing Purchasing Manager Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: DSS will dedicate the necessary resources to reviewing federal regulations to include all r...

Responsible Contact Person(s): Michele Skaggs, Director of General Services Adrienne Childress, Strategic Sourcing Purchasing Manager Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: DSS will dedicate the necessary resources to reviewing federal regulations to include all required information in subaward renewal agreements. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526206 (2024-107)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Reporting Significant Deficiency

Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office...

Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office of Purchasing and General Services, and Office of Financial Management. Employees responsible for managing grants and subrecipients will receive training on the new process. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526205 (2024-087)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring § 200.331 § 200.332

Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office...

Responsible Contact Person(s): Kimberly Boehme, OPGS Director Corrective Action Planned: Policies and procedures for grant management - to include subrecipient monitoring and FFATA reporting - will be revised. Oversight responsibilities will be determined for the Office of Grant Management, Office of Purchasing and General Services, and Office of Financial Management. Employees responsible for managing grants and subrecipients will receive training on the new process. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526161 (2024-090)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Reporting Subrecipient Monitoring

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implem...

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implement corrective actions to ensure that the University reports accurate and timely student enrollment status changes to the National Student Loan Data System. - Management will consider implementing a quality control review process to monitor the accuracy of campus and program-level batch submissions, such as implementing regularly scheduled self-audits of NSC data. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: The University has developed detailed procedures to improve reporting to NSLDS. These procedures include reviewing and updating Colleague system processing, designating staff members in both the Registrar and Financial Aid Offices to process, review and resolve reporting issues, and continued monitoring and verification of reports transmitted to NSLDS from the National Student Clearinghouse. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Angelique Robinson, College Registrar Zina Jemison, Associate College Registrar Corrective Action Planned: Step 1: College Registrar (CR) and Associate College Registrar (ACR) will review National Student Loan Data System trainings, documentation, and initiate training sessions with appropriate NSLDS staff to answer any outstanding questions about the system. Step 2: CR and ACR will review important NSLDS deadlines and incorporate lessons learned from the trainings to set the tone for internal deadline processing changes so that the semi-automated graduation process can be performed in a faster manner. The CR and ACR will also determine which additional team members within the College Records Office will assist in the completion of record updating and reporting requirements within NSLDS, outlining the specific tasks that will need to be done by each participating member and the information system queries that will be used for internal auditing purposes. Step 3: CR and ACR will consult with Financial Aid staff to finalize new internal record adjustment processing deadlines to ensure that the changes in procedures are made in a timely manner and in support of Financial Aid processes. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Carrie John, University Registrar Corrective Action Planned: The University is taking corrective action to ensure accurate and timely reporting of student enrollment changes to NSLDS. Corrective actions include enhancing procedures, providing additional training, and improving internal reviews. Estimated Completion Date: 6/30/2026 RU Responsible Contact Person(s): Katie Piper, Registrar Corrective Action Planned: The Registrar's Office has met and completed initial planning and timelines to address procedural changes needed to report the loan data timely. Estimated Completion Date: 12/31/2025 UVA Responsible Contact Person(s): Steve Kimata, Associate Vice President for Enrollment and University Registrar Corrective Action Planned: The University will implement additional controls to ensure the accuracy and timeliness of enrollment data reported to NSLDS. This includes working collaboratively with Student Financial Services and Information Technology Services to monitor and report late withdrawals, review and update the information system process for creating enrollment files, and implement a quality control review to check student status change batches for accuracy and timeliness. Estimated Completion Date: 6/30/2025 VSU Responsible Contact Person(s): Nedra Jones, University Registrar Corrective Action Planned: 1) VSU has implemented an automated alert system to notify staff of upcoming reporting deadlines, cross-referenced information system data with the SCHEV Degree Inventory Report, and are actively collaborating with SCHEV to resolve discrepancies. These items are complete. 2) Additionally, VSU is in the process of implementing the following additional corrective actions: A.) A comprehensive review of current enrollment reporting processes; B.) Closer collaboration with VSU third-party service provider to streamline and improve the enrollment reporting; C.) Designating an individual within the Registrar's Office to oversee National Student Clearinghouse (NSC) and NSLDS reporting duties; and D.) establishing a quality control process to include monthly random sample audits of enrollment data. Additionally, VSU will reconcile student addresses between the information system and NSLDS for Federal Direct Loan borrowers. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526130 (2024-089)

Significant Deficiency 2024

Commonwealth of Virginia

VA

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

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. ...

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. This will include the Director of Financial Aid and the Associate Director of Financial Aid Information Systems who will set scheduled meetings to conduct periodic reviews of the information system Access each semester using a designated report. Step 2: The Associate Director of Financial Aid Information Systems will create a repository to store the designated reports, which will be accessible by the Director of Financial Aid. Step 3: The Director of Financial Aid and the Associate Director of Financial Aid Information Systems will review access. If changes are needed, the appropriate IT forms will be submitted to have staff members access updated appropriately. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526129 (2024-088)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Responsible Contact Person(s): Ivan Gotay, College Information Security Officer Corrective Action Planned: 1.Oversight of Third-Party Service Providers: NVCC has implemented a written information security program that requires thorough vetting of third-party service providers. Additionally, NVCC ut...

Responsible Contact Person(s): Ivan Gotay, College Information Security Officer Corrective Action Planned: 1.Oversight of Third-Party Service Providers: NVCC has implemented a written information security program that requires thorough vetting of third-party service providers. Additionally, NVCC utilizes an external vendor to perform a detailed risk review of third-party service providers. The steps outlined below were reviewed and completed. Step 1: Developed procedures for overseeing third-party service providers. This contains a formal documentation of the NVCC's third-party risk management procedure, detailing vendor evaluation, review, and remedial processes. Step 2: Developed a plan for frequent reassessments to assure third-party service providers continuous compliance and security. Step 3: Provided further training for key people on implementing and maintaining third-party oversight procedures to guarantee consistency. 2.Data Protection: NVVC has identified the data protection findings and has promoted a project to begin in 2025. Step 1: NVCC will create a project plan to formally address data protection within the infrastructure. The plan will have estimates and milestones of completion to measure progress. Step 2: The extensive project will include data inventory classification and data retention. Step 3: The project will reference Virginia state policies. Step 4: A formal project review will be conducted in the second quarter of 2025 by the PMO. Step 5: Once the project has been completely resourced, it will be formally kicked off in the second quarter of 2025. Step 6: The effectiveness and progression of the project will be measured by the College Information Security Officer. Step 7: Final testing will be conducted by the IT Auditor and the College Information Security Officer. Estimated Completion Date: 7/1/2026

View Audit 345214

Finding 526040 (2024-002)

Significant Deficiency 2024

Great Lakes Commission

MI

Procurement, Suspension & Debarment Subrecipient Monitoring

Auditor Description of Criteria, Condition and Effect: Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contr...

Auditor Description of Criteria, Condition and Effect: Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Auditor Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. Responsible Person: Joseph Bertram, Financial Operations Manager. Corrective Action. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties. Anticipated Completion Date: June 30, 2025.

View Audit 345168

Finding 526022 (2024-001)

Significant Deficiency 2024

Great Lakes Commission

MI

Subrecipient Monitoring Reporting Significant Deficiency

Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountabilit...

Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Joseph Bertram, Financial Operations Manager. Anticipated Completion Date: June 30, 2025.

View Audit 345168

Finding 526003 (2024-004)

Material Weakness 2024

Weld County School District Re-8

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibili...

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibility determination is made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Direct Cert files received from the State starting in August 2024 will be kept on the Food Service Google drive. Names of the contact persons responsible for corrective action: Wesley Haselhorst and Dawn Koshio Planned completion date for corrective action plan: June 30, 2025

View Audit 345145

Finding 525976 (2024-002)

None 2024

Converse University

SC

Student Financial Aid Subrecipient Monitoring Reporting

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, ...

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

View Audit 345135

Finding 525974 (2024-002)

Significant Deficiency 2024

The Rockefeller University

NY

Subrecipient Monitoring

2024-002 Subrecipient Monitoring Research and Development Cluster: National Institutes of Health: Allergy and Infectious Diseases Research (ALN 93.855) Corrective Action Plan: All Office of Sponsored Programs Administration (OSPA) staff have been trained on the requirement to perform a ...

2024-002 Subrecipient Monitoring Research and Development Cluster: National Institutes of Health: Allergy and Infectious Diseases Research (ALN 93.855) Corrective Action Plan: All Office of Sponsored Programs Administration (OSPA) staff have been trained on the requirement to perform a risk assessment on subrecipients, and we continue to emphasize this requirement in our team meetings. In addition, the requirements were sent to the university community in March 2021 and posted on the OSPA website. OSPA will be re-educating the laboratories on this requirement in the coming weeks via email and will repeat on a semi-annual basis. Contact Person: Collette Ryder, Director of Sponsored Programs Administration Email: cryder@rockefeller.edu Phone: 212-327-8054 Anticipated Completion Date: June 30, 2025

View Audit 345128

Finding 525915 (2024-002)

Material Weakness 2024

Garrett-Keyser-Butler Community School District

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 b...

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. Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler’s Business Manager will work closely with the Special Education Cooperative Treasurer and DeKalb Eastern Business Manager during the grant process and make sure all required documents are collected. Anticipated Completion Date: The Business Manager will implement this procedure March 2025.

View Audit 345074

Finding 525855 (2024-003)

Material Weakness 2024

Unified School District No. 321

KS

Reporting Subrecipient Monitoring Material Weakness § 200.502

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.42...

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported. Contact Name – Kristy Dyche Expected Completion Date – 6/30/2025

View Audit 344992

Finding 525800 (2024-006)

Significant Deficiency 2024

Madison Consolidated Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2024-006 Finding Subject: Special Education – Procurement Summary of Finding: There was no control in place, such as an oversight, review, or approval process, to ensure that contractors or subrecipients were not suspended, debarred, or otherwise excluded from receiving federal funds for the...

FINDING 2024-006 Finding Subject: Special Education – Procurement Summary of Finding: There was no control in place, such as an oversight, review, or approval process, to ensure that contractors or subrecipients were not suspended, debarred, or otherwise excluded from receiving federal funds for the Special Education program. Contact Person Responsible for Corrective Action: Danica Houze Contact Phone Number and Email Address: 812-274-8103 dhouze@madison.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The CFO will monitor encumbrance reports on a regular basis. When federal procurements exceeding $25,000 are encumbered, we will have vendors submit a Suspended and Debarment Certification with their contract agreement when federal dollars are being encumbered. If we are unable to obtain a certification in this manner, alternate procedures such as checking the SAM.gov website will be utilized and the appropriate documentation supporting this review will be retained Anticipated Completion Date: 6/30/2025

View Audit 344970

Finding 525798 (2024-005)

Material Weakness 2024

Madison Consolidated Schools

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.334

FINDING 2024-005 Finding Subject: Title I - Eligibility Summary of Finding: The October 1 Real Time report could not be presented for audit for 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. As such, we were unable to verify the amounts r...

FINDING 2024-005 Finding Subject: Title I - Eligibility Summary of Finding: The October 1 Real Time report could not be presented for audit for 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. As such, we were unable to verify the amounts reported in the grant application. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Additionally, we were unable to verify nonpublic enrollment and poverty data included on the Title I application. Contact Person Responsible for Corrective Action: Janet McCreary Contact Phone Number and Email Address: 812-274-8001 jmccreary@madison.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Due to the timing of the prior audit and the nature of the Real-Time report, this portion of the finding was not able to be completed timely for FY23’s grant. Beginning in FY24, The Data Management Specialist will save all reports submitted to the DOE. This will ensure that supporting documentation is kept that will be used determine Eligibility for Title I. Additionally, for the nonpublic enrollment and poverty data, the grants specialist meets with non-public partners to review enrollment information and verify the student population that encumbers funding. The data management specialist for MCS verifies all enrollment information and poverty identification in concert with the nutrition manager of MCS, building administrators, and the central office administration to verify all data reported to the state. Anticipated Completion Date: 6/30/2025

View Audit 344970

Finding 525796 (2024-004)

Material Weakness 2024

Madison Consolidated Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-004 Finding Subject: Title I - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had a process to provide assessment system security training and to ensure each employee that attended training signed the agreement indicating training wa...

FINDING 2024-004 Finding Subject: Title I - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had a process to provide assessment system security training and to ensure each employee that attended training signed the agreement indicating training was received. However, there was no process in place to ensure that all documentation of school employees being trained was retained for audit. As a result, some of the Indiana Testing and Security agreements were not able to be provided for review. Contact Person Responsible for Corrective Action: Janet McCreary Contact Phone Number and Email Address: 812-274-8001 jmccreary@madison.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This was corrected in FY24. Our testing security coordinator now ensures that all training certifications are on file as required and monitors this via a spreadsheet. Anticipated Completion Date: Already completed.

View Audit 344970

Finding 525786 (2024-003)

Significant Deficiency 2024

Bay Cove Human Services, Inc. & Affiliate

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

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

View Audit 344938

Corrective Action Plans

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