Corrective Action Plans

Finding 520227 (2024-003)

Material Weakness 2024

IN

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

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,59...

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025

View Audit 339860

Finding 520156 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Bluefield

WV

HUD Housing Programs Subrecipient Monitoring Eligibility

2024-001 – ALN 14.850 – Public Housing Operating Fund – Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Tony Webster, Executive Director Projected Completion Date: June 30, 2025

View Audit 339710

Finding 520054 (2024-001)

None 2024

The Cleveland Institute of Art and Subsidaries

OH

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all stude...

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.

View Audit 339558

Finding 519999 (2024-001)

Significant Deficiency 2024

Texas Casa, Inc.

TX

Subrecipient Monitoring § 200.332

Planned Corrective Action: In order to ensure that all subrecipients receive adequate notice of any changes to the grant funding source which may occur midyear, e.g. with an “offset” grant award from the Governor’s Office, Texas CASA will email an initial notification within one month to all subreci...

Planned Corrective Action: In order to ensure that all subrecipients receive adequate notice of any changes to the grant funding source which may occur midyear, e.g. with an “offset” grant award from the Governor’s Office, Texas CASA will email an initial notification within one month to all subrecipients once we receive a midyear “offset” award with a different funding source. This initial notification will include the new FAIN, award date, total award, assistance listing number/title, name of the federal or state agency, pass-through entity, and contact information. After the “offset” grant funding source has been expended via reimbursements to subrecipients, Texas CASA will send a final notification to each subrecipient with the total amount of funding each entity received from the “offset” grant funding source, again including the FAIN, award date, total award, assistance listing number/title, name of the federal or state agency, pass-through entity, and contact information. Responsible Parties: Tamea Byrd, CFO Estimated Completion Date: December 31, 2024

View Audit 339434

Finding 519893 (2024-003)

Material Weakness 2024

Citadel Gardens, Inc. Dba the Woodlands at Citadel

MO

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding 2024-003 Responsible Party Name: Fred Gibbs Position: President, Management Agent Telephone Number: (913) 709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements A/B – Activities Allowed...

Finding 2024-003 Responsible Party Name: Fred Gibbs Position: President, Management Agent Telephone Number: (913) 709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements A/B – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Type Federal Awards Auditee’s Comments on Finding We agree with the auditors’ finding. Corrective Action We will follow procedures to ensure expenditures are not greater than the HUD approved budget and expenditures include supporting documentation before they are posted to the general ledger. We will also review the accuracy / completeness of all documentation prior to making payment. Anticipated Completion Date December 31, 2024

View Audit 339220 Questioned Costs: $1

Finding 519892 (2024-002)

Material Weakness 2024

Citadel Gardens, Inc. Dba the Woodlands at Citadel

MO

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding 2024-002 Responsible Party Name: Fred Gibbs Position: President, Management Agent Telephone Number: (913) 709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements E - Eligibility Finding ...

Finding 2024-002 Responsible Party Name: Fred Gibbs Position: President, Management Agent Telephone Number: (913) 709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements E - Eligibility Finding Type Federal Awards Auditee’s Comments on Finding We agree with the auditors’ finding. Corrective Action We will follow procedures to ensure tenant eligibility and establishing and maintaining security deposits for tenants moving out and we will review the accuracy / completeness of the documentation being processed in the tenant files on a periodic basis. Anticipated Completion Date December 31, 2024

View Audit 339220

Finding 519891 (2024-001)

Material Weakness 2024

Citadel Gardens, Inc. Dba the Woodlands at Citadel

MO

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to p...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended March 31, 2024. Finding 2024-001 Responsible Party Name: Fred Gibbs Position: President, Management Agent Telephone Number: (913) 709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comments on Finding We agree with the auditors’ finding. Corrective Action We will follow our policies and procedures to ensure that our accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date December 31, 2024

View Audit 339220

Finding 519855 (2024-001)

None 2024

Corporacion La Fondita De Jesus

PR

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

Corporación La Fondita de Jesús Corrective Action Plan December 27, 2024 Finding number: 2024-001 Federal program: 14.267 Continuum of Care Category: Compliance/internal control Condition: An immediate family member of the Executive Director was promoted to Director of Services, and the safeguard me...

Corporación La Fondita de Jesús Corrective Action Plan December 27, 2024 Finding number: 2024-001 Federal program: 14.267 Continuum of Care Category: Compliance/internal control Condition: An immediate family member of the Executive Director was promoted to Director of Services, and the safeguard measures established in the Conflict-of-Interest policy and the new organizational protocol were not followed. The following instances were noted: • The Employment Agreement was signed exclusively by the Executive Director and the Director of Services. • The Reasonable Accommodation of the Supervisory Role of the Director of Services Agreement was signed exclusively by the Executive Director and the Director of Services. In addition, another immediate family member of the Director of Services was hired as a professional contractor. At the time of the recruitment, the document establishing the relationship was not signed. Subsequently, the referred document was signed, but it did not specify the existing conflicts between the Director of Services and the Executive Director. Views of responsible officials: Management agrees with the audit findings and is committed to addressing the issues identified to ensure compliance with CFR 200.318, our Conflict-of- Interest policy, and new organizational protocols. We would like to bring to your attention that effective on November 30, 2024, the Executive Director resigned from his position with Corporacion La Fondita de Jesus. We will review and revise our Conflict-of-Interest policy and protocols to ensure they are comprehensive and clear. This includes detailing the steps to be followed when hiring or promoting individuals with familial relationships within the organization. We will establish an independent review and approval process for all employment and promotion agreements involving immediate family members of senior management. This process will include an additional review by a member of the executive committee of the Board of Directors to ensure objectivity and compliance with policies. We will review all contracts to ensure that they comply with the conflict-of-interest clause. Names of the contact persons responsible for the corrective action plan: Geraldine Bayron, Interim Executive Director, and Javier Fraguela, Board of Directors Anticipated completion date: March 31, 2025

View Audit 339130

Finding 519847 (2024-001)

Material Weakness 2024

City of Council Bluffs

IA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA with 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreement...

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA with 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreements.

View Audit 339091

Finding 519833 (2024-001)

Significant Deficiency 2024

Aspira INC of Illinois

IL

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.512

ASPIRA will put in place a process for monitoring the certification of the audit reporting package and ensure to submit the audit reporting package before the deadline.

View Audit 339073

Finding 519823 (2024-004)

Material Weakness 2024

Cots and Affiliates

MI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management § 200.303

Condition: The Organization lacked sufficient controls to ensure consistent reviews/approvals of monthly reimbursement requests and tenant rent calculations throughout the year. Planned Corrective Action: - The Rent Analyst will complete the rent calculations and sign off. - The Director of Account...

Condition: The Organization lacked sufficient controls to ensure consistent reviews/approvals of monthly reimbursement requests and tenant rent calculations throughout the year. Planned Corrective Action: - The Rent Analyst will complete the rent calculations and sign off. - The Director of Accounting will review and approve the checklist in writing. Contact person responsible for corrective action: The Director of Accounting will oversee all rent calculations. Anticipated Completion Date: Effective 01-13-2025.

View Audit 339017

Finding 519817 (2024-001)

Material Weakness 2024

Brownsburg Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-001 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23,...

FINDING 2024-001 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will formally sign off on the Mosaic income guidelines annually prior to each school year. Responsible Party and Timeline for Completion: Shane Hacker, Assistant Superintendent of Operations; Corey Ebert, Director of Finance; Jordan Ryan, Director of Nutrition Services Anticipated Completion Date: February 1, 2025

View Audit 339014

Finding 519772 (2024-007)

Material Weakness 2024

Bishop State Community College

AL

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.308 § 200.309 § 200.403

Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately ...

Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately and completed by June 2025.

View Audit 338909 Questioned Costs: $1

Finding 519744 (2024-002)

Significant Deficiency 2024

Independent School District 695

MN

Internal Control / Segregation of Duties Subrecipient Monitoring

Inadequate Segregation of Duties Actions Planned - The District has implemented a plan to mitigate this finding for federal programs by distiributing duties, and adding additional oversight. Program managers have been assigned to mon...

Inadequate Segregation of Duties Actions Planned - The District has implemented a plan to mitigate this finding for federal programs by distiributing duties, and adding additional oversight. Program managers have been assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on all receipts and disbursements. A principal will act as a program manager for Title funds, and the Superintendent will act as program manager for all other federal funds. Request for reimbursement and receipting will be completed by the Business Manager with oversight by the Superintendent. The key action to eliminate inadequate segregation of duties is developing strong contols over the review and approval of adjusting journal entries. This will involve detailed review by the program manager and the Superintendent. Adjusting journal entries are discussed and signed off on each month to timely detect misstatements. Official Responsible - Business Manager and Superintendent of Schools. Planned Completion date - Discussed with School Board December 30, 2024. This is considered ongoing to to current staffing available. Disagreement with Finding - None. ISD #695 - Chisholm concurs with the finding. Plan to Monitor - The Distirct is aware of the situation and will monitor, as it deems appropriate. Monitoring will include educating program managers to provide additional oversight for the interim and year end reporting.

View Audit 338862

Finding 519730 (2024-001)

Significant Deficiency 2024

Muskingum Valley Educational Service Center

OH

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency

Planned Corrective Action: I acknowledge the identified instance where supervisory approval was not obtained for a documented personnel expense. We have taken immediate steps to address this issue by implementing a more robust process to ensure that all personnel expense documentation is reviewed an...

Planned Corrective Action: I acknowledge the identified instance where supervisory approval was not obtained for a documented personnel expense. We have taken immediate steps to address this issue by implementing a more robust process to ensure that all personnel expense documentation is reviewed and approved by a supervisory-level employee before submission. Additionally, we will reinforce this practice through staff training and remind supervisors of their responsibility to approve all personnel expense reports. We are committed to maintaining strong internal controls, and we will monitor the implementation of this process to ensure compliance and reduce the risk of unallowable costs in the future. Anticipated Completion Date: Immediately Responsible Contact Person: Danielle Devoll

View Audit 338857

Finding 519729 (2024-001)

Significant Deficiency 2024

Towpath Trail High School

OH

Subrecipient Monitoring Reporting Significant Deficiency § 200.208 § 200.328

Finding Number: 2024-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2025 Responsible Contact Person: Dave Massa, Treasurer

View Audit 338848

Finding 519695 (2024-004)

Significant Deficiency 2024

Lake County Community College District

OH

Student Financial Aid Subrecipient Monitoring Cash Management § 200.302 § 200.305

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to fed...

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

View Audit 338777

Finding 519669 (2024-001)

Significant Deficiency 2024

San Jose Grail Family Services

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

We have implemented the following protocol to ensure the accuracy of the Form 801A State Attendance Reporting: The site supervisor prepares a Monthly Attendance Form from the daily Attendance Sign-in Sheets and submits it to the ECE Director of Programs, with a copy to the Enrollment Coordinator. ...

We have implemented the following protocol to ensure the accuracy of the Form 801A State Attendance Reporting: The site supervisor prepares a Monthly Attendance Form from the daily Attendance Sign-in Sheets and submits it to the ECE Director of Programs, with a copy to the Enrollment Coordinator. The Enrollment Coordinator reviews the accuracy of the report based on a re-comparison to source sign-in/sign-out sheets, as well as other source information, and submits the report, corrected as necessary, to the ECE Director of Programs. The ECE Director of Programs will review and approve to submit for reporting and invoicing. Once approved, the monthly forms are submitted to the finance department by the site supervisor. GFS’s finance team will complete one more review of the totals before submitting to the CDE and CDSS.

View Audit 338744

Finding 519666 (2024-001)

Significant Deficiency 2024

Northwest Michigan Health Services, Inc.

MI

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Recommendation – We recommend the Center provide proper training to employees to ensure that the sliding fee discounts are being properly applied and documented. In addition to implementing policies and procedures to ensure the sliding fee discounts are being properly monitored and supervised on a ...

Recommendation – We recommend the Center provide proper training to employees to ensure that the sliding fee discounts are being properly applied and documented. In addition to implementing policies and procedures to ensure the sliding fee discounts are being properly monitored and supervised on a periodic basis to ensure compliance. Action Taken – We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Additional staff training on slide fee discounts is in place and monthly review and testing of compliance with Center sliding fee discount policy will be done.

View Audit 338738

Finding 519636 (2024-005)

Material Weakness 2024

Upland Unified School District

CA

Subrecipient Monitoring Material Weakness

A comprehensive schedule for all sites for the entire year has been created. Responsible staff are assigned to visit the site on the dates outlined and then submit monitoring forms to the department secretary within 3 days. The Director of Nutrition Services will review all monitoring forms monthly ...

A comprehensive schedule for all sites for the entire year has been created. Responsible staff are assigned to visit the site on the dates outlined and then submit monitoring forms to the department secretary within 3 days. The Director of Nutrition Services will review all monitoring forms monthly with a review of corrective action plans within 45 days. In the event of staff absence or turnover, a backup staff member is assigned to conduct the site visit.

View Audit 338734

Finding 519614 (2024-003)

None 2024

Cleary University

MI

Subrecipient Monitoring

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: To address the GLBA finding regarding sufficient vendor management policies and reviews, we are actively enhancing our oversight process by collecting security attestations (SOC or HECVAT) from all vendors. These attestations are ...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: To address the GLBA finding regarding sufficient vendor management policies and reviews, we are actively enhancing our oversight process by collecting security attestations (SOC or HECVAT) from all vendors. These attestations are being evaluated and translated into our newly developed risk matrix, which aligns with our broader risk management framework. This approach allows us to systematically assess each vendor's security posture and assign corresponding risk levels, ensuring compliance with GLBA requirements and supporting informed decision-making in vendor relationships Person Responsible for Corrective Action Plan: Eric Riddering, Chief Information Officer Anticipated Date of Completion: June 30, 2025

View Audit 338706

Finding 519608 (2024-005)

Significant Deficiency 2024

Board of Education Baltimore County

MD

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.430

Title III – Assistance Listing No. 84.364 Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time an...

Title III – Assistance Listing No. 84.364 Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Multilingual Achievement will ensure that Time and Effort Statements are completed two times each year. These documents will be completed and signed on January 6 and July 6 of each year. Name of the contact person responsible for corrective action: Sonja Bloetner, Director of Multilingual Achievement Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 338700 Questioned Costs: $1

Finding 519599 (2024-003)

Significant Deficiency 2024

Board of Education Baltimore County

MD

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.430

Title I – Assistance Listing No. 84.010 Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time and ...

Title I – Assistance Listing No. 84.010 Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Weekly payroll runs will be cross-referenced with Title I position logs. Any discrepancies will be investigated promptly. • Unauthorized Employees: Employees not listed on Title I position logs will be removed from payroll to ensure only sponsored employees are attributed to the grant. • Missing Sponsored Employees: Sponsored employees not appearing on payroll reports will be investigated to determine the cause and appropriate corrective actions will be taken. Names of the contact persons responsible for corrective action: Michele Stansbury, Director of Title I Deanna Ashenfelter, Accounting Manager Brent Harry, Fiscal Supervisor III Planned completion date for corrective action plan: Implemented September 17, 2024

View Audit 338700 Questioned Costs: $1

Finding 519549 (2024-002)

Significant Deficiency 2024

Independent School District 701

MN

Internal Control / Segregation of Duties Subrecipient Monitoring

Inadequate Segregation of Duties Actions Planned - The school district has implemented a process for federal programs by distributing duties, and adding additional oversight. Program managers are assigned to monitor and give oversigh...

Inadequate Segregation of Duties Actions Planned - The school district has implemented a process for federal programs by distributing duties, and adding additional oversight. Program managers are assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on all receipts and disbursements. Monthly reports given to program managers to assist in the oversight. The Special Education Director acts as a program manager for special ed funds, a Principal acts as a program manager for Title funds, and the Superintendent acts as program manager for all other federal funds. Request for reimbursement and receipting is completed by the Administrative Assistant with oversight by the Business Manager and Superintendent. The key action to eliminate inadequate segregation of duties is developing strong controls over the review and approval of adjusting journal entires. This involves detailed review by the program manager and the Superintendent. Adjusting journal entries are discussed and signed off on each month to timely detect misstatements. Official Responsible - Business Manager and Superintendent of Schools Planned Completion Date - December 31, 2024 Disagreement with Finding - None - ISD #701 - Hibbing concurs with the finding. Plan to monitor - The District is aware of the situation and will monitor, as it deems appropriate. Monitoring will include educating program managers to provide additional oversight fo the interim and year end reportin. This finding will like be ongoing due to limited resources.

View Audit 338628

Finding 519539 (2024-004)

Significant Deficiency 2024

Life University, Inc.

GA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Individuals Responsible for Corrective Action Plan: Collections Coordinator (Victoria Beeston)- Responsible for initiating contact with the borrower, providing documentation instructions, and reviewing completed forms. Director of Student Accounts (Ti Jolly)- Responsible for ensuring compliance wi...

Individuals Responsible for Corrective Action Plan: Collections Coordinator (Victoria Beeston)- Responsible for initiating contact with the borrower, providing documentation instructions, and reviewing completed forms. Director of Student Accounts (Ti Jolly)- Responsible for ensuring compliance with all applicable regulations and reviewing the re-assignment documentation. ECSI (Angela Johnson)- Responsible for updating financial records and confirming the reassignment of collection rights. Condition: Federal regulation 34 CFR 674.19(e) and 34 CFR 674.31 indicates that the institution is responsible for creating and maintaining the Master Promissory Note to indicated specifications. The university has found that the existing Master Promissory Note (MPN) or equivalent documentation that acknowledges the debt is either incorrect, incomplete, or missing. Management’s Corrective Action Plan: The following steps outline the corrective actions that will be taken to resolve this issue: 1. Contact the Borrower - Life University will initiate contact with the borrower to inform them of the need to update or establish a new MPN or equivalent documentation. This will be done via the following communication channels: • Phone call (if available) • Email notification • Postal mail (if no response is received through other means) 2. Provide Clear Instructions for Documentation - The university will send a formal notice to the borrower detailing the need for a new MPN or equivalent documentation. This will include instructions on how to sign the new agreement, the importance of the MPN, and a clear explanation of the implications for the outstanding loan amount. 3. Reassign Collection Rights - Once the borrower has completed the required documentation, Life University will work with ECSI to reassign the university’s right to collect on the remaining balance. 4. Documentation Review and Verification - After the MPN is completed by the borrower, Life University will review the new MPN for completeness and accuracy. This review will ensure that the terms are correctly documented, that the borrower’s consent is properly obtained, and that the right to collect on the outstanding amount is clearly assigned. 5. Update Financial Records - Life University will update its financial records to reflect the new MPN and the re-assigned collection rights. The university will also ensure that any outstanding amounts and repayment schedules are updated accordingly. 6. Ongoing Communication and Monitoring - The university will maintain communication with the borrower throughout the process, providing reminders if necessary. Verification of Effectiveness: Upon completion of the corrective actions, the university will verify that: • The borrower has submitted the new MPN or equivalent documentation. • The collection rights have been successfully reassigned. • Financial records have been updated accurately. The university will conduct a follow-up review in February 2025 to verify the effectiveness of the corrective action plan and to ensure that no further issues remain. Anticipated Completion Date: January 1st, 2025

View Audit 338574

Corrective Action Plans

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