Corrective Action Plans

Finding 522641 (2024-004)

Material Weakness 2024

IL

Questioned Costs Subrecipient Monitoring Eligibility § 200.516

Corrective Action Plan Finding No.: 2024 - 004 Condition: The District did not meet its maintenance of effort on either the aggregate or the per capita basis for fiscal year 2024. The shortfall in maintenance of effort was $401,982. Plan: The District will implement procedures and internal con...

Corrective Action Plan Finding No.: 2024 - 004 Condition: The District did not meet its maintenance of effort on either the aggregate or the per capita basis for fiscal year 2024. The shortfall in maintenance of effort was $401,982. Plan: The District will implement procedures and internal controls in FY 2025 to monitor maintenance of effort compliance. Furthermore the District will perform a comprehensive review of fiscal year 2024 expenditures to identify the cause of the decrease in special education expenditures from the FY 2023 amounts to determine if allowable exceptions can be identified in accordance with federal guidelines. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Sheila Johnson, Assistant Superintendent of Finance and Operations

View Audit 341891 Questioned Costs: $1

Finding 522635 (2024-002)

None 2024

City of Buffalo Section 8 Housing Assistance Payments Program Ny409

NY

Subrecipient Monitoring HUD Housing Programs Reporting

View of Responsible Officials and Planned Corrective Action Plan—The City was unaware of the FFATA reporting requirements. As a result of this finding, we have reached out to HUD to obtain reporting instructions and have begun the process of gathering subrecipient information necessary for reporting...

View of Responsible Officials and Planned Corrective Action Plan—The City was unaware of the FFATA reporting requirements. As a result of this finding, we have reached out to HUD to obtain reporting instructions and have begun the process of gathering subrecipient information necessary for reporting. As soon as all pertinent information has been gathered, the Office of Strategic Planning will begin filing all past due reports until we become current.

View Audit 341882

Finding 522622 (2024-001)

None 2024

Culberson County, Texas

TX

Procurement, Suspension & Debarment Subrecipient Monitoring

The County will document in the next 60 days its risk assessment to support the County's micro purchas threshold polcy of $50,000. The County treaurer will verify remediation.

View Audit 341865

Finding 522594 (2024-001)

Significant Deficiency 2024

Cny Works, Inc.

NY

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to r...

Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to report that in January 2024 CNY Works welcomed a new Director of Youth Services which has led the department to transform and flourish in the last year. Under the new leadership, the Youth Department has implemented new internal controls, processes and has staff focused and running programs under the Workforce Innovation and Opportunity Act (WIOA). Nonetheless, CNY Work youth staff along with the Executive Director and the Director of Youth Services will review current policies and procedures to ensure these are operating effectively reflecting allowable activities and allowable costs (including hours worked by youth in the program) are allocated and charged accurately to the federal program. Emphasizing the importance of internal controls to ensure documents are signed by designated individuals to comply with requirements. The Director of Youth Services will continue to review timesheets, eligibility forms, and signatures, along with other requirements of the program to ensure internal control procedures are adequate and operating as intended. Finally, management will continue to analyze methods for monitoring the operational effectiveness of the applied internal controls on compliance and document any mitigating controls that are developed and implemented. Contact Person Responsible for Corrective Action Plan: Rosemary Avila-Ticio Executive Director, CNY Works Phone Number: 315-477-6901 Email: ravila@cnyworks.com Anticipated Completion Date of Corrective Action Plan: March 30, 2025

View Audit 341825

Finding 522589 (2024-001)

Significant Deficiency 2024

Town of Kennebunkport

ME

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

Management’s response/corrective action plan: The Town acknowledges the finding and is taking steps to address the deficiency. Actions include implementing procedures to verify and document contractor eligibility. These measures will ensure contractors are not suspended or debarred, particularly for...

Management’s response/corrective action plan: The Town acknowledges the finding and is taking steps to address the deficiency. Actions include implementing procedures to verify and document contractor eligibility. These measures will ensure contractors are not suspended or debarred, particularly for federally funded projects. The Town is committed to maintaining compliance and protecting federal funding.

View Audit 341812

Finding 522588 (2024-001)

Significant Deficiency 2024

Housing for Rockdale Elders, Inc.

MA

Questioned Costs HUD Housing Programs Special Tests & Provisions

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

View Audit 341811 Questioned Costs: $1

Finding 522542 (2024-002)

Significant Deficiency 2024

Capital Area Food Bank, Inc.,

DC

Questioned Costs Eligibility Subrecipient Monitoring

Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible c...

Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible community partner organization was able to order approximately 100 pounds of TEFAP food from CAFB’s website. CSFP – We noted that for one out of 40 individual participants sampled for CSFP, one participant’s original enrollment documents supporting eligibility was missing. The organization did have the participant’s re-enrollment documents for the subsequent fiscal year. This is related to a person being eligible to receive food. Views of Responsible Officials and Planned Corrective Actions: The Organization's investigation into the root causes of the two incidents revealed clerical errors. For the TEFAP incident, a mistake in the partner organization's profile allowed access to USDA food via our online ordering portal. Regarding the CSFP participant, the initial eligibility documents were misplaced, but subsequent reauthorization documents were available. The Organization’s planned corrective actions with respect to the two instances include the following: TEFAP partner eligibility:  Review and enhance existing procedures for establishing partner organization profiles; and  Establish a periodic reconciliation of partner organization’s authorized to access TEFAP commodities in the online ordering portal with a listing of authorized TEFAP partners CSFP eligibility:  Review and enhance existing procedures for filing individual eligibility documents; and  Continued internal reviews by the Organization’s compliance department covering the filing of individual eligibility documents Anticipated Completion Date: March 2025

View Audit 341804 Questioned Costs: $1

Finding 522516 (2024-001)

Material Weakness 2024

Capital Area Food Bank, Inc.,

DC

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

Finding 2024-001: Suspension and Debarment – Material Weakness in Internal Control Over Compliance Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25...

Finding 2024-001: Suspension and Debarment – Material Weakness in Internal Control Over Compliance Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Views of Responsible Officials and Planned Corrective Actions: The Organization's ability to perform the current manual control for suspension and debarment was impacted by the sustained high level of activity. In December 2024, the Organization developed and implemented a Robotic Process Automation (RPA) tool designed to identify new vendors added to the accounts payable system. This tool then searches sam.gov for these vendors and sends an email with the results. Utilizing artificial intelligence, the tool also creates a service ticket for any suspect vendors that require manual research. Anticipated Completion Date: December 2024

View Audit 341804

Finding 522511 (2024-003)

Material Weakness 2024

Carthage Independent School District

TX

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

Action Taken: The district concurs with this finding. The district has implemented internal controls over the collection of local revenue, in particular the fees for student reduced and full priced meals and ala cart items to include segregation of duties at the campus level. The staff accountant wi...

Action Taken: The district concurs with this finding. The district has implemented internal controls over the collection of local revenue, in particular the fees for student reduced and full priced meals and ala cart items to include segregation of duties at the campus level. The staff accountant will reconcile the monthly reports to the deposits received from the campuses. The CFO will verify the reconciliation process. This will be done monthly. We have also included monitoring and collections process of our negative balances. Each week a report will be generated and given to the campuses to be sent home with the students. A principal’s designee at each campus will follow up by phone with the parents. As a part of the district’s internal controls, at least monthly the administrative assistant to the CFO will physically observe and count meals served in each cafeteria and the CFO will compare that count to the point of sale systems reports to insure counting and claiming used for basic claims reporting is reasonable.

View Audit 341786

Finding 522481 (2024-002)

Material Weakness 2024

Freetown-Lakeville Regional School District

MA

Subrecipient Monitoring Reporting

Posting Financial Activity: (Currently being implemented) We are ensuring all financial activity is posted as intended, as part of our overall monitoring and grants administration processes. This involves enhanced oversight and verification procedures to confirm the accuracy of entries. Consistent R...

Posting Financial Activity: (Currently being implemented) We are ensuring all financial activity is posted as intended, as part of our overall monitoring and grants administration processes. This involves enhanced oversight and verification procedures to confirm the accuracy of entries. Consistent Reconciliation: (Currently being implemented with 3 meetings since July 1, 2024) Biweekly/monthly reconciliation meetings are conducted between the finance team and grants administration personnel. This ensures that adjusting entries are posted in a timely manner, maintaining the accuracy of the general ledger and financial reports filed with pass-through entities. Evaluation of Grants Management Policies and Procedures: (This has been included as part of our biweekly meetings) We are conducting a thorough evaluation of our current grants management policies and procedures. This review focuses on identifying areas for improvement and refining our practices to enhance accuracy and compliance. As part of our routine risk assessment program, we are incorporating regular evaluations of our grants management processes to identify and mitigate risks proactively. Staff Training and Development: (Upon review, it is evident that current staff possess the skills to execute the necessary procedures and processes. Former business office management did not monitor staff or provide opportunities for departmental communication. These issues are in the process of being corrected through regular staff meetings and discussions) We are providing training for our finance and grants administration staff to ensure they are well-versed in the updated procedures and reconciliation processes. This will help in maintaining the accuracy and integrity of our financial records. Cross-training programs are being implemented to ensure continuity and coverage during staff absences or turnover. Monitoring and Continuous Improvement: (In process of implementation. See details in attached documents) A monitoring process is being established to continuously assess the performance of our internal controls and reconciliation processes. Regular internal reviews are being conducted to ensure compliance and identify areas for further improvement. We have established clear timelines and reporting methodologies to facilitate ongoing monitoring and timely detection and correction of errors and misstatements.

View Audit 341747

Finding 522480 (2024-001)

Material Weakness 2024

Freetown-Lakeville Regional School District

MA

Subrecipient Monitoring Material Weakness Reporting

Control Environment: (Currently being implemented through weekly staff meetings, individual finance meetings {accounts payable, payroll, accounts billable})We have established a stronger control environment by facilitating a tone of open communication and accountability throughout the business offi...

Control Environment: (Currently being implemented through weekly staff meetings, individual finance meetings {accounts payable, payroll, accounts billable})We have established a stronger control environment by facilitating a tone of open communication and accountability throughout the business office, reinforcing and ensuring proper governance structures are in place. This includes consistent oversight from administration and timely monitoring of all financial processes; including accounts billable, accounts payable, payroll, grants management and general accounting. Policies are being reviewed and updated on a consistent basis to reflect our commitment to a strong internal control framework. Risk Assessment: (See Risk Assessment Process Document) A comprehensive risk assessment process has been implemented to identify, evaluate, and manage financial reporting risks. This has included monthly and quarterly meetings with the business office staff and grants management personnel to identify and identify potential risks and corresponding mitigation strategies. We are implementing formal documentation procedures to ensure all evaluations and decisions are recorded systematically. Information and Communication: (See Procedures for Financial Information Management Document) We are designing and implementing procedures and records to support the identification, capture, and exchange of pertinent information. This includes grants management review meetings that are monthly, as well as monthly meetings with facilities, technology, athletics and food service directors. Training sessions are being conducted to ensure relevant staff understand their roles and responsibilities in maintaining effective communication channels. Control Activities: (See Procedure for Ensuring Effective Financial Management and Governance Document) We are developing and enforcing policies and procedures that ensure management and governance directives are carried out effectively. This includes cross-training, where appropriate, are implemented to ensure staff competency and adequate coverage during turnover or absences. Monitoring: (Monitoring and timeline development are in progress. Expecting completion by October, 2024) A monitoring process is being established to continuously assess the performance of internal controls. This includes regular management reviews, and follow-up procedures to ensure corrective actions are implemented in a timely manner. We have defined expected timelines and reporting Methodologies to facilitate ongoing monitoring and timely detection and correction of errors and misstatements.

View Audit 341747

Finding 522479 (2024-004)

Significant Deficiency 2024

Morning Calm Apt

WA

Eligibility Subrecipient Monitoring Reporting

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2022-004 Statement of Condition: Management had developed activity level controls over compliance that included compliance review of all tenant certifications including income verifications used in determining the amount of rent amounts d...

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2022-004 Statement of Condition: Management had developed activity level controls over compliance that included compliance review of all tenant certifications including income verifications used in determining the amount of rent amounts due from eligible PRAC 202 participants (tenants) by the management firm compliance department. However, during our testing it was discovered that the files were missing documentation of varying importance which if properly reviewed, should have been identified as missing; some files were missing evidence of file review. Auditor Recommendation: Management has a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process. S3800-130: Response Indicator: Agree. S3800-140: Completion Date: February 3, 2025 S3800-150: Action Taken: The board had decided to change property management firms because of the history and severity of financial statement findings and major program fundings. The board believes that the new management firm has a properly designed and functioning system of internal controls to prevent tenants from being improperly housed at the property and granted rental assistance for which they are not eligible.

View Audit 341741

Finding 522477 (2024-002)

None 2024

Morning Calm Apt

WA

Subrecipient Monitoring HUD Housing Programs Reporting

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended June 30, 2023, only $2,702 of the required ...

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended June 30, 2023, only $2,702 of the required $16,212 in deposits were made, leaving the account behind schedule by another $13,510, for a total deficiency of $17,563; for the year ended June 30, 2024, only $5,404 of the required $16,212 in deposits were made, leaving the account behind schedule by another $10,808, for a total cumulative deficiency of $28,371. Auditor Recommendation: Management should institute a monitoring process to ensure all required monthly deposits to the replacement reserve are made. Such processes could include initiating automatic recurring monthly transfers with the financial institution that maintains the replacement reserve account. We also recommend contacting the HUD project manager to develop a plan to pay all outstanding liabilities and fund the reserve account.. S3800-130: Response Indicator: Agree. S3800-140: Completion Date: February 3, 2025 S3800-150: Action Taken: As a result of the discovered unpaid invoices discussed in Finding 2024-001, property management will be unable to make the required reserve deposits and pay all vendors without a rent increase from HUD. Management plans to contact the HUD Project Manager to develop a plan pay all vendors for amounts owed and fund the reserve account. A rent increase may be necessary.

View Audit 341741

Finding 522454 (2024-002)

Significant Deficiency 2024

West Perry School District

PA

Allowable Costs / Cost Principles Subrecipient Monitoring

#2024-002 – Allowable Costs/Cost Principles – Time and Effort Certifications Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be review...

#2024-002 – Allowable Costs/Cost Principles – Time and Effort Certifications Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be reviewed, approved, and maintained by administrative personnel. A written plan has been developed to guide the process. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year. Contact Person Responsible: Cory Hoffman, Business Manager/Board Secretary If the Department of Education has questions regarding this plan, please contact Cory Hoffman, Business Manager/Board Secretary. Sincerely, Cory Hoffman Business Manager/Board Secretary

View Audit 341731

Finding 522420 (2024-001)

None 2024

Food for Kids, Inc.

TX

Subrecipient Monitoring Cash Management Significant Deficiency

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Oper...

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Operation will make monitoring visit assignments for the month. Step 2: Each Compliance Officer is to submit the monitoring form to the Director of Operation no later than the last day of the month the visit was due to be performed. Step 3: The Director of Operation will follow up with each Compliance Officer to ensure forms were received, review the form, and enter the date the visit was completed into the data base to ensure visits are made as TDA requires. Step 4: The Executive Director will review the final report of all visits conducted for the month to sensure forms are accounted for. Step 5: The Director of Operation and the Office Clerk will perform random binder checks to see if forms are filed correctly. Step 6: The Director of Operation will oversee the labiling and thinning process of forms and binders before sending boxes to storage. This will ensure stored files can be easily located. The Executive Director has final responsibility for the implementation and maintenance of this procedure.

View Audit 341706

Finding 522409 (2024-001)

Significant Deficiency 2024

Atlantic States Marne Fisheries Commission

VA

Subrecipient Monitoring § 200.332

Funding Agency: Department of Commerce Assistance Listing Number: 11.469, 11.472 Finding: Reporting - The Commission did not provide timely Federal Funding Accountability and Transparency Act (FFATA) reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Correct...

Funding Agency: Department of Commerce Assistance Listing Number: 11.469, 11.472 Finding: Reporting - The Commission did not provide timely Federal Funding Accountability and Transparency Act (FFATA) reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Corrective Action Plan: The Commission agrees with the finding. The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024

View Audit 341683

Finding 522370 (2024-002)

Material Weakness 2024

Catholic Charities Maine

NH

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.329

Corrective Action Plan Response to Finding 2024-001 and Finding 2024-002: Management agrees with the recommendations and will implement the following changes: 1. On a monthly basis the Controller will review and approve all financial reporting submitted to programs to allow finance department t...

Corrective Action Plan Response to Finding 2024-001 and Finding 2024-002: Management agrees with the recommendations and will implement the following changes: 1. On a monthly basis the Controller will review and approve all financial reporting submitted to programs to allow finance department to capture and record missing information. This will be implemented by January 31, 2025. 2. A member of the finance department will participate in the sub-recipient monitoring to provide the monitoring team with oversight and ensure compliance with accounting best practices. This will be implemented by February 28, 2025. 3. The “Budgeting, Contracts, and Grants Manager” within the OMRS program will be responsible for notifying the Chief Financial Officer of any non-compliance from Sub-recipient grants and agreements within ten business days. This will be implemented by January 31, 2025. 4. The two sub-recipients with late invoicing will be issued corrective actions plans by Office of Maine Refugee Services for timely submittal of financial reports and invoicing. This will be completed by January 31, 2025. Estimated completion date for all items above: February 28, 2025 Responsible party: Reed L. Westgate, Chief Financial Officer

View Audit 341646

Finding 522361 (2024-002)

None 2024

Community Services and Employment Training, Inc.

CA

Subrecipient Monitoring Reporting

Management's Response/Planned Corrective Action: Management acknowledges the finding and accepts the recommendation. Management is committed to reporting accurate data and has implemented steps to support validation. Lola Balandran/Assistant Director for the Expanded Subsidized Employment Program wi...

Management's Response/Planned Corrective Action: Management acknowledges the finding and accepts the recommendation. Management is committed to reporting accurate data and has implemented steps to support validation. Lola Balandran/Assistant Director for the Expanded Subsidized Employment Program will provide staff training on the importance of entering data accurately and will use a checklist to ensure key data points are captured accurately. The Assistant Director for the ESE Program and Marlene Acosta/Sr. Program Coordinator will monitor staff data entry activities for accuracy, ensuring alignment with activities and calculation of participation hours. The Expanded Subsidized Employment Program will complete a two-phase validation process, where both the first and second reviewers will validate the report before it is submitted to the funding source. This process will reduce or eliminate data entry errors and confirm hours of participation are accurately calculated. The documentation compiled (for that point intime) will be used and saved as the underlying data that supports the outcomes. CSET's Compliance Director will review reports quarterly to ensure compliance with reporting requirements. On November 14, 2024, CSET began implementing the above-outlined corrective action plan.

View Audit 341640

Finding 522353 (2024-002)

Significant Deficiency 2024

Catskill Central School District

NY

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84....

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84.425D) ARP Summer Enrichment (Assistance Listing# 84.425U) ARP Comprehensive After School (Assistance Listing# 84.425U) ARP ESSER III (Assistance Listing# 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria - Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. ( d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context - We haphazardly sampled five COVID-19 - Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor's review prior to payment. Cause - Management override of established controls. Effect - Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs - None. The improper payment was subsequently adjusted out of expenditures. Recommendation - We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action - The Business Office will review and adhere to all cash disbursements procedures and protocols. Completion Date - Effective immediately. Respectfully Submitted, Dr. Brett Miller, Assistant Supt. for Business

View Audit 341608

Finding 522347 (2024-004)

Significant Deficiency 2024

Region One Education Service Center

TX

Subrecipient Monitoring § 200.332

2024-004 Subaward Agreements The Center is the recipient of GEAR UP awards based on prior grant applications submitted with its related program partners which include local educational agencies and other partners. While the audit revealed that no formal agreement was in place during the audit year, ...

2024-004 Subaward Agreements The Center is the recipient of GEAR UP awards based on prior grant applications submitted with its related program partners which include local educational agencies and other partners. While the audit revealed that no formal agreement was in place during the audit year, the Center did have documentation in place with each partner that included a detailed budget, program operating procedures manual, partner commitment form signed by each partner’s superintendent of schools, program monthly meetings, onsite visits, and other activities stipulated in the grant. A new program requirement was published on August 29, 2024, as amended in 34 CFR 75.127 through 75.129 for future Partnership Grants Application and includes language related to a binding agreement. The Center will ensure all future grant applications comply with this new requirement. Proposed Completion Date: February 1, 2025 Name of contact person: Rumalda Ruiz, Deputy Director - Business, Operations, & School Finance Support Contact: (956) 984-6290

View Audit 341604

Finding 522344 (2024-003)

Significant Deficiency 2024

Region One Education Service Center

TX

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

2024-003 Matching The GEAR UP program will update its review and approval process for in-kind documentation submitted by partners to ensure correct and accurate data is submitted in the annual grant close out process which includes the Annual Performance Report (APR) due to USDE in April 2025. Hourl...

2024-003 Matching The GEAR UP program will update its review and approval process for in-kind documentation submitted by partners to ensure correct and accurate data is submitted in the annual grant close out process which includes the Annual Performance Report (APR) due to USDE in April 2025. Hourly values for teachers and other professionals will be updated on an annual basis. The identified rate has been adjusted to ensure the correct rate is used during final submission of in-kind data for teacher hours in the APR. Proposed Completion Date: April 1, 2025 Name of contact person: Rumalda Ruiz, Deputy Director – Business, Operations, & School Finance Support Contact: (956) 984-6290

View Audit 341604

Finding 522305 (2024-002)

Significant Deficiency 2024

School District of the City of Hazel Park

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

See Corrective Action Plan for Chart/Table

View Audit 341580

Finding 522298 (2024-003)

Significant Deficiency 2024

New Mexico Human Services Department

NM

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment

2024-003 Reporting (original finding 2021-001) (Significant Deficiency in Internal Controls over Compliance) What Action(s) Will be Done: ASD staff form the Contracts and Procurement and Grant Management Bureau will work together to monitor any new activity that will need to be reported on the Feder...

2024-003 Reporting (original finding 2021-001) (Significant Deficiency in Internal Controls over Compliance) What Action(s) Will be Done: ASD staff form the Contracts and Procurement and Grant Management Bureau will work together to monitor any new activity that will need to be reported on the Federal Funding Accountability and Transparency Act (FFATA). ASD established and implemented a new contract/agreement system called Bonfire in January 2024. This system is an automated system that includes all the information that was entered on the Contract Request Form (CRF) that was previously used in the Contracts and Procurement Bureau and a copy of the proposed contract/agreement. Now, there is a specific field that can be used to track if any new contact/agreement must be reported on the FFATA. These contracts/agreements are reviewed and pre-approved in Bonfire by many HSD staff which include the Contract and Procurement Bureau Chief and the ASD Director/CFO. We can monitor the FFATA field as we review and provide information to the Grants Management Bureau Chief in real time. We can also run monthly reports to review and track this field to ensure that any new contracts/agreements were not missed to ensure timely FFATA reporting. Who Will Act: Grants Bureau Chief & Contracts and Procurement Bureau Chief When Will Action(s) be Completed: ASD will ensure that a FFATA sub-award report is submitted by the of the month following the month in which HSD awards any sub-grants greater than or equal to $30,000.

View Audit 341573

Finding 522263 (2024-003)

Material Weakness 2024

Hall County Housing Authority

NE

Subrecipient Monitoring Eligibility HUD Housing Programs

Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper do...

Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper documents are retained in the tenant files. Finding 2024-002 Management will familiarize themselves with the requirements and guidelines of their ACOP to better ensure that the Authority is operating and maintaining its policies. Finding 2024-003 See Finding 2024-001.

View Audit 341542

Finding 522229 (2024-001)

Material Weakness 2024

The Halifax - Warren Smart Start Partnership for Children, Inc.

NC

Questioned Costs Eligibility Subrecipient Monitoring

Going forward, all initial rosters submitted to HWSS will be reviewed by at least two different HWSS staff and compared to eligibility results to verify eligibility prior to entering rosters into NCPK KIDS. Any changes to a roster during the year will also be verified by at least two HWSS staff.

View Audit 341479 Questioned Costs: $1

Corrective Action Plans

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