Corrective Action Plans

Finding 565221 (2024-002)

Significant Deficiency 2024

Ouachita Multi-Purpose Community Action Program, Inc.

LA

Subrecipient Monitoring Cash Management Internal Control / Segregation of Duties

Management will have the employee responsible for the review of the LIHEAP Agency Invoice Reports sign each weekly report as approved.

View Audit 359115

Finding 565220 (2024-001)

Significant Deficiency 2024

Ouachita Multi-Purpose Community Action Program, Inc.

LA

Subrecipient Monitoring Internal Control / Segregation of Duties

Management agrees with this finding and will develop policies and procedures to ensure all client application are approved prior to granting the client an award.

View Audit 359115

Finding 565207 (2024-002)

Significant Deficiency 2024

American Academy McAllister Institute of Funeral Service, Inc.

NY

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number an...

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.

View Audit 359094

Finding 565206 (2024-001)

Significant Deficiency 2024

American Academy McAllister Institute of Funeral Service, Inc.

NY

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of ...

Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

View Audit 359094

Finding 565180 (2024-001)

Significant Deficiency 2024

University of Guam

GU

Subrecipient Monitoring Special Tests & Provisions § 200.303

Finding NO. 2024-001 Special Tests and Provisions – Gramm-Leach-Bliley Act–Student Information Security View of the University of Guam and Corrective Action Plan: The University’s Office of Information Technology is developing a written Information Security Program that complies with the requireme...

Finding NO. 2024-001 Special Tests and Provisions – Gramm-Leach-Bliley Act–Student Information Security View of the University of Guam and Corrective Action Plan: The University’s Office of Information Technology is developing a written Information Security Program that complies with the requirements of the Gramm-Leach-Biley Act applicable to universities. The Information Security Program will be reviewed annually to ensure minimum requirements are met. Name of Contact Person: Vincent Dela Cruz, Chief Information Officer Proposed Completion date: January 30, 2026

View Audit 359091

Finding 565163 (2024-003)

Significant Deficiency 2024

Kaskaskia Community College District #501

IL

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Action taken in response to finding: The College will work to update the written information security program (WISP) to ensure compliance with all the required elements of the Gramm-Leach Bliley Act (GLBA).

View Audit 359072

Finding 565124 (2024-001)

Material Weakness 2024

National Children's Museum

DC

Cash Management Subrecipient Monitoring § 200.305

The cash draw findings were focused on tracking staff time and effort. The Museum implemented corrective action regarding the use of time sheets for federal award tracking immediately after the DOE grant performance period and exists for each time period in FY25. The Human Resources department has i...

The cash draw findings were focused on tracking staff time and effort. The Museum implemented corrective action regarding the use of time sheets for federal award tracking immediately after the DOE grant performance period and exists for each time period in FY25. The Human Resources department has incorporated the timesheets into employee training, onboarding, and the updated staff handbook. Already Completed. Kevin Cantfil, VP of Finance and Administration.

View Audit 359058

Finding 565124 (2024-001)

Material Weakness 2024

National Children's Museum

DC

Cash Management Subrecipient Monitoring § 200.305

Drawdown requests that include reimbursement for time and attendance will include documented approval by one additional staff member. If programmatic staff prepare the drawdown, the VP of Finance and Administration will complete the final approval. If the VP of Finance and Administration prepares th...

Drawdown requests that include reimbursement for time and attendance will include documented approval by one additional staff member. If programmatic staff prepare the drawdown, the VP of Finance and Administration will complete the final approval. If the VP of Finance and Administration prepares the drawdown, a member of the Advancement department will complete the final approval. June 30, 2025. Kevin Cantfil, VP of Finance and Administration.

View Audit 359058

Finding 565108 (2024-005)

None 2024

Hazel Crest School District 152.5

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. Plan: Management will review its policies and procedures regarding timely grant expenditure report submissions with staff. Furthermore, staff will be properly trained for...

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. 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: Justin Whitten, Business Manager. Management Response: Management will work together with staff to verify that grant compliance reporting deadlines are met moving forward.

View Audit 359057

Finding 565092 (2024-003)

Material Weakness 2024

Ark-Tex Council of Governments

TX

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Planned Corrective Action: We have provided communication and training to caseworkers, inspectors, and property managers regarding the program requirements. ATCOG has updated its administrative processes for HUD programs, which has included a strengthened review process over admissions to ensure tha...

Planned Corrective Action: We have provided communication and training to caseworkers, inspectors, and property managers regarding the program requirements. ATCOG has updated its administrative processes for HUD programs, which has included a strengthened review process over admissions to ensure that all required elements, including a passed inspection, are present before Housing Assistance Payments are made. Contact Person Responsible for Corrective Action: Mary Beth Rudel, Executive Director Completion Date: March 31, 2025

View Audit 359044

Finding 565091 (2024-002)

Material Weakness 2024

Ark-Tex Council of Governments

TX

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

Planned Corrective Action: When this condition was discovered, ATCOG was already in the process of updating and amending its administrative policies for HUD programs. These updates were begun in Fall 2024 and included clarifying procedures over the waiting list process. Moreover, ATCOG has implement...

Planned Corrective Action: When this condition was discovered, ATCOG was already in the process of updating and amending its administrative policies for HUD programs. These updates were begun in Fall 2024 and included clarifying procedures over the waiting list process. Moreover, ATCOG has implemented a review process for its waiting list process so that the errors that led to the improper selection method will not be repeated. Contact Person Responsible for Corrective Action: Mary Beth Rudel, Executive Director Completion Date: March 31, 2025

View Audit 359044

Finding 565082 (2024-001)

None 2024

Future Forward, Inc.

WI

Subrecipient Monitoring § 200.1 § 200.332 § 200.414

2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency wa...

2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency was incorrect. The contact information was Education Analytics, Inc., the Organization’s grantor, but should have been Future Forward, Inc. Further, one of the two subawards selected for testing had information missing from the subaward including all requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award. We consider this condition to be an instance of noncompliance relating to the Subrecipient Monitoring compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: Future Forward will re-issue contracts/MOUs for its two subawards with the correct awarding agency listed (Future Forward instead of Education Analytics). In addition, Future Forward will include requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award in the revised contracts/MOUs. Responsible Person for Corrective Action Plan: Kate Bauer-Jones, Executive Director Implementation Date for Corrective Action Plan: May 15, 2025

View Audit 359026

Finding 565078 (2024-002)

Material Weakness 2024

Southeast Texas Food Bank, Inc.

TX

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

2024-002 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture , Passed through the Texas Department of Agriculture Internal Control – Monitoring Criteria : Monitoring should be such that there is an assurance that controls are being performed in a timely manner. Co...

2024-002 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture , Passed through the Texas Department of Agriculture Internal Control – Monitoring Criteria : Monitoring should be such that there is an assurance that controls are being performed in a timely manner. Condition and Context :The policies and procedures in place during 2024 did not include proper monitoring of the program policies and procedures. Repeat finding : 2023-002 Recommendation : Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding CORRECTIVE ACTIONS : ALL purchases being made for federal and state funding will be reviewed by the President/CEO and the CFO of the Southeast Texas Food Bank for proper monitoring and compliance of procurement policies. The President/CEO will sign off for approval prior to purchasing.

View Audit 359015

Finding 565055 (2024-003)

Material Weakness 2024

Child Care & Nutrition INC

MN

Internal Control / Segregation of Duties Subrecipient Monitoring

Child Care and Nutrition, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2024. Audit period: October 1, 2023-September 30, 2024 The findings from the September 30, 2024 schedule of findings and questioned costs are discussed below. The findings ar...

Child Care and Nutrition, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2024. Audit period: October 1, 2023-September 30, 2024 The findings from the September 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2024-001 Internal Accounting Controls Recommendation: We recommend management be aware to the lack of segregation of duties within the accounting functions and provide oversight to ensure the internal control policies and procedures are being implemented by organization staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will continue to review the accounting functions of all affected departments so segregate them as it is cost beneficial. Name of the contact person responsible for corrective action: Sherri Looft, Executive Director Planned completion date for corrective action plan: September 30, 2025. MATERIAL WEAKNESS 2024-002 Annual Financial Reporting Under Generally Accepted Accounting Principles Recommendation: Management should continue to evaluate their internal staff capacity to determine if an internal control policy over the annual financial reporting is beneficial. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization understands this is required communications for the preparation of the financial statements and will continue to work at this area to achieve the overall goal. Name of the contact person responsible for corrective action: Sherri Looft, Executive Director Planned completion date for corrective action plan: September 30, 2025. FINDINGS – FEDERAL AWARD PROGRAMS 2024-003 Internal Accounting Controls Federal Agency: U.S. Department of Agriculture Federal Program: Child and Adult Care Food Program CFDA Number: 10.558 Pass Through Agency: Minnesota Department of Education, Child Nutrition Section Pass Through Number: 1000003400 Award Periods: Year ended September 30, 2024 Recommendation: We recommend management be aware to the lack of segregation of duties within the accounting functions and provide oversight to ensure the internal control policies and procedures are being implemented by organization staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will continue to review the accounting functions of all affected departments so segregate them as it is cost beneficial. Name of the contact person responsible for corrective action: Sherri Looft, Executive Director Planned completion date for corrective action plan: September 30, 2025.

View Audit 358982

Finding 565022 (2024-001)

Significant Deficiency 2024

Chicago Commons Association

IL

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

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

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

View Audit 358908

Finding 565012 (2024-001)

Material Weakness 2024

Lapeer County

MI

Questioned Costs Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.327

May 27, 2025 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Re: Corrective Action Plan Regarding Section III: Schedule of Findings and Questioned Costs for the Fiscal Year Ended September 30, 2024, in Reference to 2024-001 Procurement It was identified in the findings...

May 27, 2025 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Re: Corrective Action Plan Regarding Section III: Schedule of Findings and Questioned Costs for the Fiscal Year Ended September 30, 2024, in Reference to 2024-001 Procurement It was identified in the findings of 2024-001 Procurement (repeat comment) that LCCMH had not followed proper procurement requirements and procedures regarding the agreement in reference to ALN 93.969 Certified Community Behavioral Health Clinics (CCBHC) expansion Grants. LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Thank you, Brooke Sankiewicz Chief Executive Officer Lapeer County Community Mental Health (810) 667-0500 bsankiewicz lapeercmh.org

View Audit 358880 Questioned Costs: $1

Finding 565001 (2024-001)

Material Weakness 2024

Holland Home

MI

Subrecipient Monitoring Material Weakness Reporting

Condition: The Organization has engaged a subrecipient as part of this grant program, which was subsequently determined, but did not have an executed agreement with the subrecipient until October 2024. As a result, the Organization did not meet the requirements of performing formal risk assessment p...

Condition: The Organization has engaged a subrecipient as part of this grant program, which was subsequently determined, but did not have an executed agreement with the subrecipient until October 2024. As a result, the Organization did not meet the requirements of performing formal risk assessment procedures prior to engaging with the subrecipient. Planned Corrective Action: Management has executed an agreement with the identified subrecipient and implement formalized policies and procedures to ensure no risk factors for non-compliance exist and to properly monitor the subrecipient activity. The identified subrecipient has met all documentation and submission requirements to support reporting and appropriate usage of grant funds related to the grant program. Contact person responsible for corrective action: Adam Kinder, CFO Anticipated Completion Date: October 2024

View Audit 358874

Finding 564747 (2024-004)

Material Weakness 2024

Stillwater County

MT

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

Response: Project numbers will be utilized for the grant programming from this point further so that the income and expenses will be more easily defined and isolated for reporting.

View Audit 358820

Finding 564735 (2024-003)

Significant Deficiency 2024

Washtenaw County

MI

Subrecipient Monitoring § 200.332

Lack of Subrecipient Monitoring Auditor Description of Criteria, Condition, and Effect: Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and condi...

Lack of Subrecipient Monitoring Auditor Description of Criteria, Condition, and Effect: Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Auditor Recommendation: We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department. Corrective Action: The Office of Community and Economic Development will implement a subrecipient monitoring policy specific to grants and operations including a schedule of monitoring and risk assessment. OCED program and finance staff will undergo training specific to subrecipient monitoring to ensure alignment in policies across programs. The OCED Finance and Operations Division Administrator will lead subrecipient monitoring activities and will coordinate as necessary with other OCED department division administrators to develop a monitoring schedule and communication plan for subrecipients. Washtenaw County Finance will assist in developing this subrecipient monitoring policy and will perform an overall review of all subrecipient monitoring to ensure compliance and consistency across departments and programs. Responsible Person: Chief Financial Officer Anticipated Completion Date: December 2025

View Audit 358817

Finding 564705 (2024-001)

Material Weakness 2024

Heber-Overgaard Unified School District No. 6

AZ

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.512

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Forest Service Schools and Roads Cluster, Education Stabilization Fund Assistance Listing Number: 10.665, 84.425 Contact Person: Andrea Despain, Business Manager Anticipated Completion Date: June 30, 2025 Planned Corrective Action: The ...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Forest Service Schools and Roads Cluster, Education Stabilization Fund Assistance Listing Number: 10.665, 84.425 Contact Person: Andrea Despain, Business Manager Anticipated Completion Date: June 30, 2025 Planned Corrective Action: The District will collaborate with all grant stakeholders to strengthen internal controls by clearly defining responsibilities, tracking submission deadlines, and ensuring strict adherence to policies. Oversight will be reinforced through regular grant management meetings and reviews conducted by the Business Manager. To enhance reporting accuracy and documentation practices, staff will receive targeted training on compliance requirements. Additionally, recordkeeping processes will be standardized, with periodic reviews to verify adherence and improve efficiency. These corrective actions will be implemented promptly and continuously supported through ongoing monitoring, ensuring more timely and accurate audits while maintaining compliance with federal regulations.

View Audit 358807

Finding 564663 (2024-003)

Material Weakness 2024

Pioneer Resources, Inc.

MI

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding 2024-003: MATERIAL WEAKNESS—Transit Services Programs Cluster Payroll Procedures U.S. Department of Transportation Pass-through Entity: Michigan Department of Transportation Assistance Listing Numbers: 20.516 and 20.521 Award Numbers: 215509NI, 215541NI, 220776NI and 221303NI Award Year ...

Finding 2024-003: MATERIAL WEAKNESS—Transit Services Programs Cluster Payroll Procedures U.S. Department of Transportation Pass-through Entity: Michigan Department of Transportation Assistance Listing Numbers: 20.516 and 20.521 Award Numbers: 215509NI, 215541NI, 220776NI and 221303NI Award Year End: September 30, 2024 Recommendation: The Organization should follow its established procedures to ensure that payroll records, including manual and electronic, are properly and timely filed and maintained in accordance with the Organization’s written record retention policy so that they can be readily located when needed. Action Taken: Staff responsible for these tasks will be educated on the importance of following the Organization’s policy. Responsible Person and Anticipated Completion Date: The Executive Director will oversee the implementation of this plan by September 30, 2025.

View Audit 358795 Questioned Costs: $1

Finding 564651 (2024-004)

Material Weakness 2024

Teach.org Inc.

CA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

Auditor’s Recommendation: Internal control should be documented to ensure compliance with the reporting compliance requirement. Documentation should include a signed certification by the preparer and a reviewer that the requests for payment, written summaries of reporting-specific meetings with gran...

Auditor’s Recommendation: Internal control should be documented to ensure compliance with the reporting compliance requirement. Documentation should include a signed certification by the preparer and a reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and any other reporting activities are complete, accurate, and agree to supporting records of expenditures or other accounting or database information. Written policies and procedures should be designed and implemented for documentation of internal controls performed for reporting. Corrective Action: TEACH.org will write a policy to address internal controls for reporting. TEACH staff will obtain training on documentation of internal controls performed for reporting related to Federal awards. After training, TEACH staff will review all documentation of internal controls and make changes to our policies as needed to properly document our internal controls. Responsible for Corrective Action: TEACH.org Deputy Chief of Staff will obtain training on internal controls documentation for Federal grants. Once training is completed, DCoS will review all fiscal policies and add or edit our policies as needed to address proper documentation of internal controls performed for reporting. Anticipated Completion Date: TEACH.org DCoS will obtain training by September 30, 2025 and conclude their review of TEACH fiscal policies by December 31, 2025.

View Audit 358749

Finding 564649 (2024-002)

Material Weakness 2024

Teach.org Inc.

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.430

Auditor’s Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate, allowable, and properly allocated. Written policies and procedures should be designed and...

Auditor’s Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate, allowable, and properly allocated. Written policies and procedures should be designed and implemented for documentation of time and effort. Corrective Action: TEACH.org will write a policy regarding documenting required procedures to track employee time & effort charged to Federal grants. Each employee who charges time to a Federal grant will receive a copy of this policy annually. The policy will indicate that employees must provide signed time & effort tracking statements at least quarterly while they are charging time to Federal grants. Each statement will be signed by the employee, their supervisor, and the program director. These statements will be used to properly document time & effort charged to Federal grants and prepare invoices or claims for all Federal grants. Each invoice or claim will be compared to time & effort tracking and tied out to the amounts charged to the Federal grant. Responsible for Corrective Action: TEACH.org internal and external accounting staff will write the time & effort procedures with oversight from a TEACH Co-Executive Director. Once the procedures are approved, TEACH internal and external accounting staff will be responsible for identifying employees working on Federal grants and must supply them with a copy of the policy at least annually. Quarterly time & effort documentation forms will be prepared by internal and external accounting staff, and sent to employees, supervisors and program directors. TEACH internal and external accounting staff will be responsible for collecting and retaining all required time & effort documentation. TEACH program directors will be responsible for reviewing all completed time & effort documentation and reconciling time tracked to invoices or claims prepared for all Federal grants. Anticipated Completion Date: TEACH.org will write the time & effort tracking procedures, supply to all employees working on Federal grants, complete all time & effort tracking documents, and tie out to all invoices and claims retroactively to July 1, 2024. This work will be concluded by June 30, 2025, and starting July 1, 2025 the new procedures will be implemented for all Federal grants.

View Audit 358749 Questioned Costs: $1

Finding 564605 (2024-004)

Material Weakness 2024

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards. Action Plan:  See the “Conduct Training Sessions fo...

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards. Action Plan:  See the “Conduct Training Sessions for Expenditures Personnel” and “Audit of all FY25 YTD Expenditures” sections of management’s action plan for finding 2024-001  Review and update the Allowable Funds document o Locate the latest Allowable Funds Guide created by KIPP Delta. o Review and update the guide as necessary. o Store the updated guide in a central cloud location for responsible personnel to access easily. o Process completed as of April 17, 2025.  Develop a Federal Funds Workflow in Avid for POs and invoices: o A designated finance team member must review all federally funded purchases to improve the federal funds purchasing process. Steps include:  Create a separate workflow in Avid for POs and invoices to track federal purchases.  Ensure a purchase order is created before an invoice is submitted and paid.  Attach all required documentation to the PO, as with all other expenditures.  Verify that the expenditure complies with the Allowable Funds guide o Anticipated completion date of May 30, 2025.

View Audit 358741 Questioned Costs: $1

Finding 564593 (2024-005)

Significant Deficiency 2024

Goshen Community Schools

IN

Cash Management Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) - Internal Controls Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Cash ...

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) - Internal Controls Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Cash Management Requests for reimbursement will not be submitted until the Treasurer has attached the supporting documentation from the financial software system (member schools will provide documentation). The documentation will be reviewed and approved by the Executive Director of ECSEC prior to submission to the Treasurer. The reimbursement request will require an approval signature from the Chief Financial Officer/Treasurer prior to submittal. Anticipated Completion Date: June 2025

View Audit 358719

Corrective Action Plans

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