Corrective Action Plans

Finding 524497 (2024-001)

Material Weakness 2024

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524461 (2024-005)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Subrecipient Monitoring Material Weakness Reporting

Beginning March 2025, the City's Finance department will review and sign off on any annual financial reports submitted to the U.S. Department of Treasury. The City will provide training to appropriate staff that Finance Departmental review is required.

View Audit 343795

Finding 524447 (2024-001)

Significant Deficiency 2024

National 4-H Council

DC

Questioned Costs Subrecipient Monitoring § 200.1 § 200.211 § 200.303 § 200.332

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial managemen...

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

View Audit 343772 Questioned Costs: $1

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524430 (2024-002)

Significant Deficiency 2024

Municipality of Quebradillas

PR

Subrecipient Monitoring Reporting § 200.328

The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.

View Audit 343714

Finding 524393 (2024-002)

Material Weakness 2024

Loma Linda University

CA

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs § 200.329

Finding 2024-002 – Internal control deficiency and noncompliance over Reporting related to performance reports Connecting Minority Communities Pilot Program – Timeliness and Accuracy During testing over the Reporting compliance requirement, management did not have effective internal controls in pl...

Finding 2024-002 – Internal control deficiency and noncompliance over Reporting related to performance reports Connecting Minority Communities Pilot Program – Timeliness and Accuracy During testing over the Reporting compliance requirement, management did not have effective internal controls in place to ensure performance reports were submitted by the deadline and completed correctly. Management did not submit the required performance reports by the deadline and certain key line items were not completed correctly. Management Response and Action Plan: Management will meet with the Principal Investigator and provide additional training emphasizing the importance of timely submission and accuracy of grant documentation and reports. In addition, management will monitor submission deadlines and follow-up with the Principal Investigator to ensure timely filing. Responsible Person: Executive Director of Sponsored Project Administration Target Date: February 2025

View Audit 343628

Finding 524366 (2024-003)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were ...

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

View Audit 343584

Finding 524359 (2024-003)

Material Weakness 2024

Pitt County, North Carolina

NC

Subrecipient Monitoring Eligibility Material Weakness

Corrective Action/Management Response: Supervisor responsible for submitting report has become more familiar with the due dates in which this report is due. In addition, a reminder has been placed on the Outlook calendar to ensure that the report is completed timely. This practice has seemed to ...

Corrective Action/Management Response: Supervisor responsible for submitting report has become more familiar with the due dates in which this report is due. In addition, a reminder has been placed on the Outlook calendar to ensure that the report is completed timely. This practice has seemed to work as the report submitted for the 1st quarter was submitted timely. Proposed Completion Date: 11/21/2024

View Audit 343583

Finding 524346 (2024-003)

Significant Deficiency 2024

Isd #482 - Little Falls

MN

Subrecipient Monitoring Cash Management Reporting

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and re...

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

View Audit 343576

Finding 524336 (2024-001)

None 2024

South Cook County Intermediate Service Center #4

IL

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant...

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant requirements, we noted the following: For Public Safety Partnership and Community Policing Grants - • One of 2 (50%) quarterly federal financial reports were submitted 36 days late. • One of 1 (100%) semi-annual performance report was submitted 47 days late. For McKinney-Vento Education for Homeless Children and Youth - • Four of 4 (100%) quarterly expenditure reports and the Grant Accountability and Transparency Act (GATA) reports were submitted but the South Cook Intermediate Service Center #4 was unable to provide proof of submission; therefore, we were unable to determine if the required reports were submitted timely or at all. • South Cook Intermediate Service Center #4 did not formally establish a Community Advisory Group. PLAN: Management will develop more formal and comprehensive grant monitoring procedures that will include a checklist for all the necessary reporting and compliance requirements. Specifically for the Mc-Kinney Vento grant, formal documentation for the established Community Advisory Group will be obtained in consultation with the grantor. ANTICIPATED DATE OF COMPLETION: June 30, 2025 CONTACT PERSON: Dr. Anthony Marinello, Executive Director

View Audit 343535

Finding 524287 (2024-002)

Significant Deficiency 2024

Close Up Foundation

VA

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.329

Views of Responsible Officials: Historically, the Foundation has submitted all required documents per the grant agreement. GrantSolutions is a newer platform by which all documents must be uploaded. When the final financial reports were submitted, the grant was closed without the performance report ...

Views of Responsible Officials: Historically, the Foundation has submitted all required documents per the grant agreement. GrantSolutions is a newer platform by which all documents must be uploaded. When the final financial reports were submitted, the grant was closed without the performance report and the grant was removed from the dashboard. The performance report was prepared by the deadline, but the grant manager was not aware of the alternative dropdown to upload the file. Moving forward, everyone who has access to GrantSolutions, both in Finance and Development, must acquaint themselves with the site and crosscheck that the required documents are uploaded timely, especially prior to a grant closing.

View Audit 343499

Finding 524224 (2024-002)

Significant Deficiency 2024

Staywell Healthcare, Inc.

CT

Eligibility Subrecipient Monitoring Significant Deficiency § 200.303

2024.02 - Eligibility Recommendation We recommend that management provide training to those responsible for verifying eligibility to ensure that documentation and internal control over eligibility is maintained. Action Taken 1) To ensure patient eligibility is properly assigned to patients, the Dir...

2024.02 - Eligibility Recommendation We recommend that management provide training to those responsible for verifying eligibility to ensure that documentation and internal control over eligibility is maintained. Action Taken 1) To ensure patient eligibility is properly assigned to patients, the Director of Clinical Operations will perform random audits on a Monthly basis of patients that are assigned. 2) The Director of Clinical Operations will also ensure proper training to those that are assigning eligibility to ensure that proper documentation is obtained and properly stored. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Eric Newman, CFO at (203) 756-8021 x 3015. Sincerely yours, Eric Newman Chief Financial Officer

View Audit 343418

Finding 524220 (2024-001)

Significant Deficiency 2024

Staywell Healthcare, Inc.

CT

Special Tests & Provisions Subrecipient Monitoring Eligibility

SIGNIFICANT DEFICIENCY 2024.001 - Sliding Fee Scale Discount Recommendation The Center should implement a system of controls to ensure all sliding fee discounts are properly supported. Action Taken 1) To ensure Sliding Fee Discounts are properly supported, the Director of Program Management will ass...

SIGNIFICANT DEFICIENCY 2024.001 - Sliding Fee Scale Discount Recommendation The Center should implement a system of controls to ensure all sliding fee discounts are properly supported. Action Taken 1) To ensure Sliding Fee Discounts are properly supported, the Director of Program Management will assign random audits on a Monthly basis of patients that are assigned a sliding fee. 2) Director of Program Management as well as Program Managers will monitor Phreesia dashboard to identify self-pay patients on the schedule and work to ensure that accounts are updated accordingly. a. For any accounts that need to be updated, they will inform the PSA who checked in the patient to make the updates as necessary and provide additional training if needed. b. Provide trainings to PSAs to ensure that they are offering the Sliding Fee Discount to all patients that may need to apply, and appropriately applying those slides. 3) If a Pt has had a visit and left prior to getting sliding fee information, PSAs are to call the patient to let them know that they may have to apply for a sliding fee (or receive insurance information over the phone). 4) Practice Managers will identify Self-pay accounts via Phreesia each morning that may need attention and send a list of accounts to the PSAs at the beginning of each day. PSA will then contact the patients to remind them to bring in proof of income to apply for the sliding fee if eligilble.

View Audit 343418

Finding 524170 (2024-002)

Significant Deficiency 2024

United Way of Tucson and Southern Arizona, Inc.

AZ

Subrecipient Monitoring § 200.332

The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation of subrecipient monitoring including a risk assessment for each subrecipient Revise all federal subrecipient contracts to include federal award identifica...

The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation of subrecipient monitoring including a risk assessment for each subrecipient Revise all federal subrecipient contracts to include federal award identification number and the amount of federal funds awarded to each subrecipient Distribute policies and procedures and contract templates to all applicable finance and programmatic staff Train staff on the new policies and procedures

View Audit 343343

Finding 524159 (2024-006)

Significant Deficiency 2024

City of Santa Fe

NM

Subrecipient Monitoring

Auditor recommendation: We recommend the City strengthen policies and procedures to ensure program directors are following procedures and documenting review and approval as part of monitoring of subrecipients, and that subawards reported on the SEFA are verified against the characteristics of the ag...

Auditor recommendation: We recommend the City strengthen policies and procedures to ensure program directors are following procedures and documenting review and approval as part of monitoring of subrecipients, and that subawards reported on the SEFA are verified against the characteristics of the agreement and the relationship with the other entity. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. Vacancies in key positions resulted in a lack of robust oversight of subrecipient monitoring during FY24. These key positions have now been filled. The Accounting Officer, Grants Manager and Accounting Financial Analyst positions in the Finance Department have been filled with qualified people who have extensive grant management experience, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to work more closely with federal grant program managers throughout City government. During the second half of FY24 the Finance team worked with our accounting consulting firm to develop and deploy Uniform Guidance training to over 50 employees City-wide. The AGA Recipient checklist for determining if the entity receiving funds has a contractor or subrecipient relationship was discussed and provided during this training and some City departments are now using it as part of the process to develop agreements that use federal funds. The Finance Director’s review of proposed agreements now includes an evaluation of the reasonableness of the subrecipient or contractor determination prior to the Finance Director signing the agreement. In CY25 the Finance team will work to develop additional procedures to ensure that subawards reported on the SEFA are verified against the characteristics of the agreement and the relationship with the other entity. Additionally, the Finance Director, the Accounting Officer, and the Grants team will work to strengthen policies and procedures and deploy training to ensure program managers understand subrecipient monitoring procedures, including documenting review and approval as part of monitoring of subrecipients. The City plans to provide additional Uniform Guidance training for staff in CY25 which will include subrecipient monitoring requirements. Responsible Official: Emily Oster, Finance Director, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Estimated Completion Date: June 30, 2025

View Audit 343340

Finding 524108 (2024-005)

Significant Deficiency 2024

Natrona County, Wyoming

WY

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously...

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

View Audit 343312

Finding 524106 (2024-004)

Material Weakness 2024

Natrona County, Wyoming

WY

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.400

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously...

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

View Audit 343312 Questioned Costs: $1

Finding 524090 (2024-001)

None 2024

Warren Wilson College

NC

Student Financial Aid Subrecipient Monitoring Reporting

Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group...

Corrective Action Plan from College: This is submitted to Derrick Everhart, Director of Financial Aid, by the College Registrar Brooke Millsaps. In order to correct the need to have a monitoring mechanism in place, the College has taken the following actions: ● Warren Wilson College convened a group of stakeholders to review our exit and withdrawal procedures. This group included representatives from the following offices: Financial Aid, Registrar, tudent Accounts, Student Engagement, Office of the Provost. ● The group revised our procedures when a student indicates they want to leave the College. These revised procedures include the following: 1. Developed a specific chart to determine the classification of the student, the time of year of the action, and the circumstances of the action: See Corrective Action Plan for chart / table. 2. Removed a student's ability to complete the exit form once classes started in order to prevent an erroneous student exit 3. Implemented an Administrative Exit - census verification process . This allows the college the opportunity to verify through roster verification, work participation, and residential status if a student should be administratively exited. 4. As a result of this revised institutional procedure, the Office of the Registrar reviewed and revised its procedures regarding exits and withdrawals to ensure that we are documenting accurate information in the appropriate locations within Jenzabar. This will ensure that when we report data to the National Student Clearinghouse, the associated exits and withdrawal dates are in alignment. Management Response : The Director of Financial Aid concurs with this finding and noted while the College was out of compliance with the reporting timeframe, the College did make a substantial effort to complete the requirements and follow up with NSLDS and NSC to correct the students enrollment. Contact College personnel for corrective action. Derrick Everhart, Director of Financial Aid deverhart@warren-wilson.edu Brooke Milsaps, College Registrar bmillsaps@warren-wilson.edu

View Audit 343264

Finding 524041 (2024-003)

Material Weakness 2024

Metro Technology Center

OK

Subrecipient Monitoring Material Weakness Reporting

Finding Summary: U.S. Department of Treasury COVID-19- Coronavirus State and Local Fiscal Recovery Funds (SLFRF) (FFAL #20.027) Reporting Material Weakness in Internal Control over Compliance Responsible Individuals: Karla Graham, Director of Grants, Services & Projects Corrective Action Plan: The p...

Finding Summary: U.S. Department of Treasury COVID-19- Coronavirus State and Local Fiscal Recovery Funds (SLFRF) (FFAL #20.027) Reporting Material Weakness in Internal Control over Compliance Responsible Individuals: Karla Graham, Director of Grants, Services & Projects Corrective Action Plan: The process has been adjusted to ensure quarterly project and expenditure reports are reviewed independently by two different people prior to submission. Anticipated Completion Date: July 1, 2025

View Audit 343223

Finding 523979 (2024-001)

Significant Deficiency 2024

United Way of Southern Nevada, Inc.

NV

Subrecipient Monitoring § 200.332

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2024-001 Internal Controls Systems and Compliance Over Subrecipient Monitoring – U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed Through the State of Nevada Department of Education Cr...

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2024-001 Internal Controls Systems and Compliance Over Subrecipient Monitoring – U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed Through the State of Nevada Department of Education Criteria: In accordance with 2 CFR 200.332(a)(1), the auditee must maintain a system of internal control to ensure information related to federal awards is clearly identified to the subrecipient at the time of the subaward and if any data elements change, include the changes in a subsequent subaward modification. Condition: The Organization receives funding for the Nevada Ready! program through the State of Nevada and the amount of funding provided by federal and state sources changes annually. The Organization did not identify that certain information required to be communicated for federally sourced awards was missing from the information provided to subrecipients for subawards they received during the year. Context: Nineteen preschool centers did not receive notification that the funding they received included funds that were federally sourced and additional information required to be communicated related to the federal funding was not provided. Cause: The design and implementation of internal controls over subrecipient monitoring was not effective. Effect: Not communicating the inclusion of federal funding in a subaward and all related requirements in a subaward to subrecipients could result in the subrecipients not complying with federal regulations. Recommendation: We recommend management design and implement a system of internal controls whereby every subaward that includes federal funding be clearly identified to the subrecipient as a federal subaward and include all data elements required to be provided to the subrecipient at the time of the subaward and if any of the data elements change, include the changes in a subsequent subaward modification. Views of Responsible Officials and Planned Corrective Action: We appreciate the identification of this compliance issue and are committed to addressing the finding with a robust corrective action plan. The following steps outline the measures we will take to ensure compliance with federal requirements for subrecipient monitoring under 2 CFR 200.332, effective June 30, 2024, and related guidance: 1. Implementation of Updated Grant Award Communication Procedures Future Grants to Centers: - We will estimate the amount of federal funds included in each grant and include this amount in the agreement at the time of award issuance. - Agreements will be updated to clearly delineate the specific requirements for both federal and state funds. - Each Center will acknowledge their responsibilities and obligations for federal and state funds, with detailed requirements provided for both funding sources. Annual Notifications: - A statement will be provided to each Center annually, clearly notifying them of the amount of federal funding included in their subaward. 2. Prioritization of FY24 Subrecipients - Upon receipt of these findings, immediate focus was placed on Nonprofit Centers, and we confirmed that none received more than $749,999 in federal awards (either directly as a recipient or indirectly as a subrecipient) in aggregate for all its projects during the fiscal year. - A statement will be provided to each Center annually, clearly notifying them of the amount of federal funding included in their subaward. - The corrective actions will be implemented by January 31, 2025. 3. FY25 Proactive Measures - Notifications of federal requirements and the Q1 statement for FY25 will be distributed by January 31, 2025. - We conducted an initial high-level overview of these updated requirements at the Director Training on November 15, 2024. - A comprehensive training session will follow in January 2025 to ensure all subrecipients fully understand their obligations under Uniform Guidance, including subaward identification and compliance monitoring. 4. Alignment with 2 CFR 200.332 Requirements for Pass-Through Entities In compliance with the updated requirements for pass-through entities under 2 CFR 200.332: -Each subaward will be clearly identified as a federal subaward and include all required data elements at the time of issuance. Any subsequent changes will be communicated through a formal subaward modification process. - Indirect cost rate requirements under 2 CFR 200.332 (i) will be explicitly addressed. Specifically: If the subrecipient has an approved federally recognized indirect cost rate, it will be honored. If no approved rate exists, we will collaborate with the subrecipient to determine an appropriate rate. This may include using a previously negotiated rate between the subrecipient and another pass-through entity, without requiring additional justification from the subrecipient. By implementing these measures, we will establish a robust system of internal controls to ensure full compliance with the Uniform Guidance and related federal requirements. We are confident these steps will address the identified issue and strengthen our subrecipient monitoring practices. Responsible Official: Samuel Rudd, President & CEO

View Audit 343199

Finding 523974 (2024-002)

None 2024

County of Patrick, Virginia

VA

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.516

The School Board will ensure to require all contractors funded with federal funds maintain compliance with prevailing wage requirements and obtain documentation certifying compliance.

View Audit 343176

Finding 523970 (2024-003)

None 2024

County of Patrick, Virginia

VA

Subrecipient Monitoring Reporting

The County reported information inaccurately on the federal CSLFRF reporting but the final report is due during FY2025 and the variance will net and correct itself.

View Audit 343176

Finding 523966 (2024-001)

None 2024

National Center for Teacher Residencies, Inc.

IL

Subrecipient Monitoring § 200.332

NONCOMPLIANCE ...

NONCOMPLIANCE 2024-001 – SUBRECIPIENT MONITORING Recommendation: The auditors recommended the Organization maintain documentation that evidences its compliance with required subrecipient monitoring activities in accordance with 2 CFR 200. Actions Taken or Planned: Management will ensure results of risk assessment and monitoring are documented in writing annually. Person Responsible: Wayne Shen, Chief Operating Officer Estimated Date of Completion: January 31, 2025

View Audit 343146

Finding 523662 (2024-241)

Significant Deficiency 2024

Bais Tova, Inc.

NJ

Subrecipient Monitoring

Bais Tova, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024 Finding 24-1: The School’s net cash resources exceeded three months average expenditures at the end of the year. Recommendation: To keep monitoring the net cash resources throughout the yea...

Bais Tova, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024 Finding 24-1: The School’s net cash resources exceeded three months average expenditures at the end of the year. Recommendation: To keep monitoring the net cash resources throughout the year to ensure that it does not exceed three months average expenditures. Action Taken: Since being made aware of this issue, the School’s administrator has begun to routinely monitor the net cash resources to ensure that it does not exceed three months average expenditures. As such, the required correction actions have been implemented. Implementation Date Corrective Action Plan has been implemented as of December 17, 2024. Person Responsible for Implementation: Yonasan Sanders, the Administrator, is the responsible party for implementation of the CAP. Telephone number: (732) 901-3913.

View Audit 343078

Finding 523620 (2024-002)

Significant Deficiency 2024

Reading Muhlenberg Career & Technology Center

PA

Reporting Subrecipient Monitoring Significant Deficiency

2024-002 REPORTING - SIGNIFICANT DEFICIENCY Condition During the year ended June 30, 2024, the Center submitted a report for the funds used during the year ended June 30, 2023. The report submitted by the Center contained expenditure amounts that did not agree to the final amounts reported on the s...

2024-002 REPORTING - SIGNIFICANT DEFICIENCY Condition During the year ended June 30, 2024, the Center submitted a report for the funds used during the year ended June 30, 2023. The report submitted by the Center contained expenditure amounts that did not agree to the final amounts reported on the schedule of expenditures of federal awards for the year ended June 30, 2023. Recommendation We recommend the Center continue updating its reporting procedures to use the most accurate information possible. In addition, the report should also be reviewed by an individual separate from the person compiling the information. Management Response The grant noted in the finding has since been finalized and a final Expenditure Report has been submitted to the State reflecting the correct total dollars spent. All grants will be tracked within the funding sources provided by the Pennsylvania Department of Education within the general ledger. Grant reporting will be reviewed along with the applicable support by the executive director or another party before being submitted.

View Audit 342994

Corrective Action Plans

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