Corrective Action Plans

Finding 509371 (2024-001)

Significant Deficiency 2024

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action pla...

JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 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 None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: Jubilee Senior Homes should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for Jubilee Senior Homes through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 329158

Finding 509369 (2024-001)

Significant Deficiency 2024

3250 Sacramento Housing, Inc.

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective acti...

3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 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 None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: 3250 Sacramento should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for 3250 Sacramento through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 329156

Finding 509329 (2024-002)

Significant Deficiency 2024

Cornell College

IA

Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend that the College review each element of GLBA to ensure compliance with all necessary requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Add sections to the existing policy ...

Recommendation: We recommend that the College review each element of GLBA to ensure compliance with all necessary requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Add sections to the existing policy to correct deficiencies found in the audit Name of the contact person responsible for corrective action: Sean Mays Planned completion date for corrective action plan: December 2024

View Audit 329119

Finding 509300 (2024-001)

None 2024

Interfaith Community Services of South Carolina, Inc.

SC

Subrecipient Monitoring

Interfaith Community Services Organization agrees with the finding. However, in Consultation with the SC Department of Social Services, it was determined that Interfaith would terminate its role as a CACFP sponsor organization as of September 1, 2024. This date is 1 month prior to the end of the gra...

Interfaith Community Services Organization agrees with the finding. However, in Consultation with the SC Department of Social Services, it was determined that Interfaith would terminate its role as a CACFP sponsor organization as of September 1, 2024. This date is 1 month prior to the end of the grant period, September 30, 2024, in which the remaining monitoring visits would have been completed if the organization had not terminated the contract.

View Audit 329106

Finding 509287 (2024-003)

Significant Deficiency 2024

Ord Public Schools District No. 5

NE

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

ESTABLISH INTERNAL CONTROL OVER FINANCIAL STATEMENT PREPARATION AND REVIEW Recommendation: The District should review and approve the proposed auditor adjusting entries and the adequacy of schedule of the expenditures of federal awards disclosures prepared by the auditors and apply analytic proc...

ESTABLISH INTERNAL CONTROL OVER FINANCIAL STATEMENT PREPARATION AND REVIEW Recommendation: The District should review and approve the proposed auditor adjusting entries and the adequacy of schedule of the expenditures of federal awards disclosures prepared by the auditors and apply analytic procedures to the draft financial statements, among other procedures as considered necessary by management. Action Taken: The District will prepare of schedule of federal expenditures based on expenditure categories as found in the District's general ledger and value of commodities for lunch program. This will be prepared using an excel spreadsheet. The District will review the audit adjustments as presented by the external auditors including those related to the federal expenditures and the related worksheet. We will ensure the adjustments made to federal award expenditures are appropriate by examining the nature and amount of the adjustments. Questionable items will be discussed and agreed upon between the District and the auditors. After review and approval of the entries, they will be input into the District's general ledger and the SEFA spreadsheet will be updated. This will be compared to the SEFA that is included in the audit report and if they are in agreement, this will be approved by management. All variances will be addressed prior to finalization of the audit report and submission to the Nebraska. If the Nebraska Department of Education has questions regarding this plan, please call Dr. Heather Nebesniak at 308.728.5013.

View Audit 329096

Finding 508378 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Subrecipient Monitoring

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a mon...

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a monthly basis to prevent the accumulation of interfund receivables and payables. IHA will also strengthen its cash management practices by reviewing and reconciling inter-program balances on a monthly basis. This process will include a detailed review to ensure that program-level cash components are accurate, and resources are being used exclusively for their intended purposes.

View Audit 328993

Finding 508377 (2024-005)

Significant Deficiency 2024

Walthill Public Schools District #13

NE

Subrecipient Monitoring

The district has received the subcontractor list and is gathering the certified payroll certifications for the subcontractors onsite. We will work with the general contractor to ensure the documents we have are complete. We will monitor that these controls are taking place as planned.

View Audit 328983

Finding 508376 (2024-004)

Significant Deficiency 2024

Walthill Public Schools District #13

NE

Reporting Subrecipient Monitoring Cash Management

The district will add procedures to monitor that additional spending is not being done after the grant is fully spent. In addition, the District will implement controls to ensure approved budget amendments are secured prior to spending. The District will also implement controls to ensure prior year ...

The district will add procedures to monitor that additional spending is not being done after the grant is fully spent. In addition, the District will implement controls to ensure approved budget amendments are secured prior to spending. The District will also implement controls to ensure prior year spending is considered for reimbursement requests. The District will work with the grantor agency on any necessary correction of reports and submission of supporting documentation since both grants' reimbursement requests have been fully paid for the total grant amounts.

View Audit 328983

Finding 508352 (2024-001)

Material Weakness 2024

Family Life Academy Charter Schools

NY

Subrecipient Monitoring Cash Management Reporting

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and...

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and ARP grants to report since we had incurred expenses exceeding the cash payments received prior to 6/30/2022. The original reports were reviewed by NYSED during their desk audit and they did not report any issues with it. In the future, we will contact the agency for the reporting instruction clarifications.

View Audit 328954

Finding 508325 (2024-001)

Significant Deficiency 2024

Oakridge Public Schools

MI

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

Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Ent...

Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Entitlement Commodities, 230900 and 240900 Award Year End: September 30, 2023 and September 30, 2024 Recommendation: The School District should follow established procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Food Service Director, October 2024 If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.

View Audit 328887

Finding 508304 (2024-001)

Material Weakness 2024

Creo College Preparatory Charter School

NY

Subrecipient Monitoring Cash Management Reporting

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and ...

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and consult with on financial management and will work closely with the new partner to ensure that future Education Stabilization Fund Annual Reports are completed based on the amount of reimbursement payments received. Management will review the report and confirm the reported amounts agree to the reimbursement payments received on the NYSED Grants Finance reports via the NYSED website.

View Audit 328877

Finding 508302 (2024-002)

Material Weakness 2024

Hebrew Language Academy Charter School 2

NY

Subrecipient Monitoring Cash Management Reporting

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensur...

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

View Audit 328856

Finding 508299 (2024-001)

Material Weakness 2024

Hebrew Language Academy Charter School

NY

Subrecipient Monitoring Cash Management Reporting

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensur...

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

View Audit 328855

Finding 508261 (2024-002)

Significant Deficiency 2024

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Item # 2024-02 Indirect Costs Incorrectly Allocated to Federal Award (Significant Deficiency in Internal Control over Federal Major Program) Criteria: Under Uniform Guidance regulations and per the terms of the federal award, the de minimis 10% indirect cost rate for indirect cost allocations must...

Item # 2024-02 Indirect Costs Incorrectly Allocated to Federal Award (Significant Deficiency in Internal Control over Federal Major Program) Criteria: Under Uniform Guidance regulations and per the terms of the federal award, the de minimis 10% indirect cost rate for indirect cost allocations must be used on federal award expenditures. The Guidance also prohibits application of 10% de minimis rate on all subgrants in excess of $25,000 during the period of performance. Condition: Based on the results of our audit testing, we noted indirect costs were allocated incorrectly during the grant period. The total known questioned costs are $1,142. Cause: Management failed to charge indirect costs correctly on the federal subaward during the year ended June 30, 2024. Effect: The effect of the condition was $1,142 in known questioned costs charged to two federal subawards during the year ended June 30, 2024. Auditor’s Recommendation: Management should perform a thorough analysis of the indirect cost allocation to ensure it is reasonable and calculated correctly in accordance with the Uniform Guidance Regulation. Views of Responsible Officials and Planned Corrective Actions: Management understands that indirect expenses incurred on federal awards must be reviewed and allocated appropriately. Management will ensure that it properly allocates indirect costs in accordance with Uniform Guidance and the terms of its federal awards.

View Audit 328788 Questioned Costs: $1

Finding 508231 (2024-002)

Significant Deficiency 2024

Mid-Atlantc Christian University

NC

Subrecipient Monitoring Student Financial Aid Significant Deficiency

2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was...

2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in February 2024, which addressed several of the deficiencies noted in the existing policy, but not all. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance Corrective Action Plan Summary-The university recently reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to effectively monitor antl administer the policy. In April 2024, we hired an IT company to help with various campus needs, including data compliance procedures and security measures. The company has been reviewing our current policies and making recommendations to implement appropriate safeguards to keep the university up to date and compliant. We have already installed multi-factor authentication features for our software systems, and there are more updates to come. In July 2024, we received a notice of compliance from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley Act. Anticipated Completion Date- July 1, 2025

View Audit 328701

Finding 508224 (2024-001)

Material Weakness 2024

Discovery Charter School

NY

Subrecipient Monitoring Cash Management Reporting

Mengel, Metzger, Barr & Co. LLP (MMB) recommended management review the NYSED Grants Finance reports via the NYSED website to determine the reimbursement payments received during the applicable reporting period and agree the amounts per the website to the total amounts shown in the Education Stabili...

Mengel, Metzger, Barr & Co. LLP (MMB) recommended management review the NYSED Grants Finance reports via the NYSED website to determine the reimbursement payments received during the applicable reporting period and agree the amounts per the website to the total amounts shown in the Education Stabilization Fund Annual Reporting. Corrective Action: – Management will ensure that the reporting method utilized for any further Annual Education Stabilization ESSER Fund reports will be completed on a cash basis. Anticipated Completion Date: The corrective action will be implemented by February 2025 Person responsible for implementation: Anne Culver, Finance & HR Manager

View Audit 328698

Finding 508203 (2024-001)

Material Weakness 2024

Vertus Charter School

NY

Subrecipient Monitoring Cash Management Reporting

Finding Reference Number: 84.425U ARP ESSER Description of Finding: Vertus Charter School was required to submit the Education Stabilization Fund Annual Reporting to New York State Education Department. It was found that Vertus Charter completed the reporting based on cash expenditures made during t...

Finding Reference Number: 84.425U ARP ESSER Description of Finding: Vertus Charter School was required to submit the Education Stabilization Fund Annual Reporting to New York State Education Department. It was found that Vertus Charter completed the reporting based on cash expenditures made during the required period of July 1, 2022, to June 30, 2023, and not based on the cash expenditures related to cash received during the stated required reporting period. Statement of Concurrence or Nonconcurrence: Vertus Charter School agrees with the audit finding. Corrective Action: Immediate Actions Taken: 1. Upon identification of the issue, the organization immediately reviewed the instructions to complete the Education Stabilization Fund Annual Reporting and compared it to the report submitted to identify the discrepancy. 2. The organization will determine appropriate steps to correct the report and/or other actions based on guidance provided by New York State Education Department. Root Cause Analysis: The reporting error occurred because there was a misinterpretation of the reporting methodology required to file the ESF Annual Report. Instead, the organization used the reporting methodology required to file the Annual ESSA Financial Transparency Report – Charter School Actual Expenditures, whereby the actual cash expenditures made during the reporting period are reported, vs. reporting expenditures made using the cash received under the program during the reporting period. Planned Actions to Prevent Recurrence: 1. Training for Staff: a. All staff responsible for preparing and submitting financial reports will undergo mandatory training on federal reporting requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Complete by January 15, 2025 2. Revised Reporting Procedures: a. The organization will ensure that information reported in the ESF Annual Report is based on the correct accounting methodology in accordance with instructions from the New York State Education Department and the U.S. Department of Education requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Effective immediately Name of Contact Person: Julie Locey, Chief Education Officer, 585-747-8911. jlocey@vertusschool.org Projected Completion Date: All corrective actions will be completed by February 15, 2025. If there are any questions regarding this Plan, please call me at 585-747-8911.

View Audit 328667

Finding 508162 (2024-002)

None 2024

The King's University

TX

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: Procedures have been implemented to ensure that disbursement reporting to COD are reflective of the actual disbursement dates and amounts in the student information system. Person Responsible for Corrective Action Pl...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: Procedures have been implemented to ensure that disbursement reporting to COD are reflective of the actual disbursement dates and amounts in the student information system. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Implemented

View Audit 328600

Finding 508030 (2024-001)

Significant Deficiency 2024

African Wildlife Foundation, Inc.

DC

Subrecipient Monitoring Reporting Significant Deficiency

2024-001 Trans-National Crime – Assistance Listing No. 19.705 Recommendation: We recommend African Wildlife Foundation design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Repo...

2024-001 Trans-National Crime – Assistance Listing No. 19.705 Recommendation: We recommend African Wildlife Foundation design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, AWF should ensure that any subawards are reported within the required time frame. The list of data elements required to be reported for each sub-award in excess of $30,000 include the following: • Subaward date • Subaward DUNS number • Subaward amount • Subaward obligation/action date • Subaward number • Subaward report submission date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have created an account at FSRS.gov and are in the process of filing the FFATA reports for our INL sub-awards. Name(s) of the contact person(s) responsible for corrective action: Richard Holly Planned completion date for corrective action plan: 11/01/2024 If the U.S. Department of State has questions regarding this plan, please call Richard Holly at 202-939-3341

View Audit 328537

Finding 507984 (2024-001)

None 2024

Beulah Heights University

GA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • Per 34 CFR 668.34, one (1) student out of 15 tested for satisfactory academic progress requirements (SAP) received Title IV, HEA program ...

We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • Per 34 CFR 668.34, one (1) student out of 15 tested for satisfactory academic progress requirements (SAP) received Title IV, HEA program funds in the amount of $6,342 and was not meeting the requirements specified by the University. The University subsequently returned the funds. The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Action – The University agrees with the finding. To address, the University’s registrar’s office will flag students in the student information system and place a registration hold on their account if they are not currently meeting Satisfactory Academic Progress (SAP) requirements. The financial aid office will check for all holds, any former SAP corrective actions and ensure that all students, including those re-entering the University following an absence, are meeting SAP requirements.

View Audit 328465

Finding 507982 (2024-001)

Significant Deficiency 2024

Atlantic States Marne Fisheries Commission

VA

Subrecipient Monitoring § 200.332

Name of Contact Person: Laura Leach, Director of Finance and Administration Corrective Action: 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...

Name of Contact Person: Laura Leach, Director of Finance and Administration Corrective Action: 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 Subawards stating this requirement. Proposed Completion Date: December 31, 2024

View Audit 328461

Finding 507948 (2024-001)

Significant Deficiency 2024

Idaho State University

ID

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its...

Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton , Director of Grant Accounting. Planned completion date for corrective action plan: Implemented for FY25

View Audit 328453

Finding 507947 (2024-003)

Significant Deficiency 2024

Idaho State University

ID

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional contr...

Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 suspension and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be initiated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. We are also adding the S&D clause to all contracts. Name(s) of the contact person(s) responsible for corrective action: : Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024

View Audit 328453

Finding 507828 (2024-003)

Material Weakness 2024

Classical Charter Schools

NY

Subrecipient Monitoring Cash Management Reporting

Finding #2024-003 Management acknowledges that the reporting method utilized for the Annual Education Stabilization ESSER Fund report should have been completed on a cash basis which is based on reimbursement of expenses received during the fiscal year. Classical Charter Schools will take the necess...

Finding #2024-003 Management acknowledges that the reporting method utilized for the Annual Education Stabilization ESSER Fund report should have been completed on a cash basis which is based on reimbursement of expenses received during the fiscal year. Classical Charter Schools will take the necessary steps to comply with the cash basis reporting method on all future Annual Education Stabilization ESSER Funds reports. The Grants Manager will review the instructions for completing the Annual Education Stabilization ESSER Fund when it is open in the portal (normally in January). Name of Contact Person: Dr. Vivian Cassaberry-Furby, Director of Business vfurby@classicalcharterschools.org

View Audit 328343

Finding 507814 (2024-002)

Significant Deficiency 2024

University of Sioux Falls

SD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program P063P222212,P063P232212 Eligibility Significant Deficiency in Internal Control over Compliance Finding Summary: One student was not awarded Pell assistance...

Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program P063P222212,P063P232212 Eligibility Significant Deficiency in Internal Control over Compliance Finding Summary: One student was not awarded Pell assistance during the summer term as the student's FAFSA was not completed at the time the financial aid office was determining award eligibility. The student later completed the FAFSA within the award year and became eligible for a retroactive disbursement of Pell assistance; however, the financial aid office did not provide the student a retroactive disbursement of Pell. Responsible Individuals: Karrie Morgan, Director of Financial Aid Corrective Action Plan: Management will review procedures and control processes over monitoring retroactive disbursements. Anticipated Completion Date: October 31, 2024.

View Audit 328325 Questioned Costs: $1

Corrective Action Plans

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