Corrective Action Plans

Finding 529716 (2024-003)

Material Weakness 2024

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Yea...

Information on the federal program: Subject: Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Condition and Context: 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 Special Tests and Provisions - Wage Rate Requirements compliance requirements. The School Corporation had projects for construction of new facilities including an early learning center and improvements to sports facilities which was funded with ESSER II (84.425D) and ESSER Ill (84.425U) grant awards. In our sample of three vendors, the School Corporation did not include Davis-Bacon wage rate requirements in the vendor contract, and therefore the vendor did not include the verbiage within their subcontractor agreements. Also, the School Corporation did not obtain the weekly payroll reports certifications from the construction vendor to monitor compliance with Davis-Bacon wage rate requirements. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements during the audit period. The total project costs disbursed during the audit period in our sample was $3,681,455 which includes material and labor costs. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Vincennes Community School Corporation will comply with the Davis-Bacon wage rate requirements in all future projects using federal funds. Responsible Party for Corrective Action: Michele Fleck, Treasurer Timeline for Completion: Effective immediately.

View Audit 347612

Finding 529712 (2024-002)

Material Weakness 2024

Vincennes Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context: 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 Reporting compliance requirements. The School Corporation was required to submit 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 I amount reported on the Year 3 report ($86,004) did not agree to the underlying expenditure records ($196,436) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER Ill amounts reported on the Year 3 report ($0 and $1,684,755, respectively) did not agree to the underlying expenditure records ($1,391,963 and $4,330,649, respectively), for the period of July 1, 2022 through June 30, 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Vincennes School Corporation will include the Federal Programs Coordinator when preparing any annual reports to confirm accuracy of the reporting. Responsible Party for Corrective Action: Michele Fleck, Treasurer Timeline for Completion: Effective immediately.

View Audit 347612

Finding 529710 (2024-001)

Significant Deficiency 2024

City of Whittier

CA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Program/Cluster: CDBG – Entitlement/Special Purpose Grants Cluster Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award Year: 2023-24 Grant Award Number: B-23-MC-06-0533 Compliance Requirement: Reporting Management’s Response: We...

Program/Cluster: CDBG – Entitlement/Special Purpose Grants Cluster Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award Year: 2023-24 Grant Award Number: B-23-MC-06-0533 Compliance Requirement: Reporting Management’s Response: We concur. Views of Responsible Officials and Corrective Action: As stated in the condition, the City has subsequently submitted the report after the due date. The City has implemented policies and procedures to ensure timely submission to the Federal Funding Accountability and Transparent Act Subaward Reporting System (FSRS). Name of Responsible Person: Community Development Department, Werner Abrego, Senior Economic Development and Housing Analyst Projected Implementation Date: Implemented.

View Audit 347601

Finding 529683 (2024-001)

Material Weakness 2024

City of Taylor, Michigan

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Condition: The community development manager’s payroll expenses charged to the grant were supported by time records, but these records were not reviewed or approved by another individual. Planned Corrective Action: The community development manager will submit his/her payroll time records to either ...

Condition: The community development manager’s payroll expenses charged to the grant were supported by time records, but these records were not reviewed or approved by another individual. Planned Corrective Action: The community development manager will submit his/her payroll time records to either the outside consultant or Chief of Staff who will review and approve accordingly before being charged to the grant. Contact person responsible for corrective action: Joan Hennessey (Outside Consultant) or Dan Bzura (Chief of Staff). Anticipated Completion Date: 3/12/2025

View Audit 347590 Questioned Costs: $1

Finding 529515 (2024-009)

Material Weakness 2024

Cannelton City School Corporation

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

FINDING 2024-009 Finding Subject: Covid-19-Education Stabilization Fund-Special Test and Provisions-Wage Rage Requirements Summary of Finding: Construction contracts in excess of $2000 financed by federal assistance funds must pay prevailing wage rates by the Department of Labor. Additionally, the S...

FINDING 2024-009 Finding Subject: Covid-19-Education Stabilization Fund-Special Test and Provisions-Wage Rage Requirements Summary of Finding: Construction contracts in excess of $2000 financed by federal assistance funds must pay prevailing wage rates by the Department of Labor. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. However, this is not a new finding. This is continued from the previous audit period under the same contract. No new contracts were made in the current audit period. Description of Corrective Action Plan: The Superintendent will make sure to let the contractors know when we are using federal monies so that they include the payment of prevailing wage in the contract. Anticipated Completion Date: The noncompliance will be addressed immediately. The additional controls will be implemented by August 2025.

View Audit 347515

Finding 529508 (2024-008)

Material Weakness 2024

Cannelton City School Corporation

IN

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

FINDING 2024-008 Finding Subject: Covid-19-Education Stabilization Fund-Reporting Summary of Finding: Not all reports filed by the school corporation during the audit period were properly supported by the records of the school corporation. Additionally, the School corporation did not properly implem...

FINDING 2024-008 Finding Subject: Covid-19-Education Stabilization Fund-Reporting Summary of Finding: Not all reports filed by the school corporation during the audit period were properly supported by the records of the school corporation. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. However, these data collections reports are not user-friendly and we receive very little guidance on how to do them. One email that we received from the IDOE stated it was for the ESSER III year 3, however the attachment was named year 4 with the year 3 dates listed on the spreadsheet. The due date that it showed for this report was July 24, 2025 on the subject of the memo, but said July 24, 2024 within the body of the memo. Description of Corrective Action Plan: In the future all reports will be done by the Corporation Treasurer and the Grant Specialist and signed off on by the Superintendent. Anticipated Completion Date: The noncompliance will be addressed immediately. The additional controls will be implemented by August 2025.

View Audit 347515

Finding 529504 (2024-007)

Material Weakness 2024

Cannelton City School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.302 § 200.303 § 200.403

FINDING 2024-007 Finding Subject: Covid-19-Education Stabilization Fund-Allowable Costs/Cost Principles Summary of Finding: This finding claims federal awards were not in compliance with the terms and conditions as well as the allowable cost compliance requirements. Additionally, the School corporat...

FINDING 2024-007 Finding Subject: Covid-19-Education Stabilization Fund-Allowable Costs/Cost Principles Summary of Finding: This finding claims federal awards were not in compliance with the terms and conditions as well as the allowable cost compliance requirements. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. The reason we spent the money the way we did is because the IDOE approved our budget. We spent exactly as it was approved not knowing that we could not spend it on items or services that were being paid for prior to the grant’s application. If it was not supposed to be spent this way, then IDOE should have never approved it. To prevent noncompliance going forward, the school’s grant administrator will review disbursements of the program to ensure they were not spent on items or services that were in place prior to the grant’s application. Description of Corrective Action Plan: To prevent noncompliance going forward, the school’s grant administrator will review disbursements of the program to ensure they were not spent on items or services that were in place prior to the grant’s application. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The noncompliance will be addressed immediately. The additional controls will be implemented by August 2025.

View Audit 347515 Questioned Costs: $1

Finding 529497 (2024-006)

Material Weakness 2024

Cannelton City School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

FINDING 2024-006 Finding Subject: Covid-19-Education Stabilization Fund - Internal Controls Summary of Finding: The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal controls to ensure they were operating effectively. Cont...

FINDING 2024-006 Finding Subject: Covid-19-Education Stabilization Fund - Internal Controls Summary of Finding: The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal controls to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. All of the Covid-19 Education Stabilization Funds have been expended at this time. Anticipated Completion Date: August 2025

View Audit 347515

Finding 529492 (2024-005)

Material Weakness 2024

Cannelton City School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not p...

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will follow all correct procurement plans set forth in the future. We will also verify with each vendor and have a form filled out stating that they are not suspended or debarred. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The School will ensure proper procurement methods are followed and that vendors are properly checked for suspension and debarment by December 2025. The additional controls will be implemented by August 2025.

View Audit 347515

Finding 529487 (2024-004)

Material Weakness 2024

Cannelton City School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403

FINDING 2024-004 Finding Subject: Child Nutrition Cluster-Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Payments made based on statements or no supporting documentation. The School corporation did not properly implement a process to identify and assess internal...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster-Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Payments made based on statements or no supporting documentation. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Invoices are already being given to the Corporation Treasurer monthly and are being attached to each Accounts Payable Voucher to show exactly what is being paid for. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The noncompliance was corrected as of January 2025. The additional controls will be implemented by August 2025.

View Audit 347515 Questioned Costs: $1

Finding 529482 (2024-003)

Material Weakness 2024

Cannelton City School Corporation

IN

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

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: There was a lack of internal controls. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activitie...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: There was a lack of internal controls. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director now gets all the reports and appropriate supporting documentation, including receipts and disbursements reports, together and goes over it with the high school secretary/deputy treasurer and is then submitted by the secretary/deputy treasurer, printed off and given to the corporation treasurer. The corporation treasurer has a copy of the submission and compares that to what is deposited. All claims have always been approved by the School Board. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: August 2025

View Audit 347515

Finding 529481 (2024-001)

Material Weakness 2024

Altus Independent School District #18

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on all federal awards. Weekly payroll reports will be reviewed with vendors to ensure that the fedreal wage rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 347507

Finding 529478 (2024-001)

Material Weakness 2024

Boone-Apache Public Schools

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Boone-Apache Schools will take the following strict action to assure that the District is in compliance with the Davis Bacon Act for all future construction Projects that are funded by federal dollars: 1. The district will evaluate that policies and procedures are properly in place to meet the requ...

Boone-Apache Schools will take the following strict action to assure that the District is in compliance with the Davis Bacon Act for all future construction Projects that are funded by federal dollars: 1. The district will evaluate that policies and procedures are properly in place to meet the requirements of the Davis Bacon Act which includes Board Policy, and writen procedures. 2. All Administrators and Administrative Assistants will receive webinar training from the United States Department of Education which will be verified by the Superintendent of Schools. 3. The district will develop and follow internal controls that will ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance.

View Audit 347474

Finding 529466 (2024-004)

Material Weakness 2024

Caston School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting 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 Reporting compliance requirements. Context: The School Corporation was required to submit 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 ($288,565 and $115,716, respectively) did not agree to the underlying expenditure records ($139,081 and $88,437, respectively) for the period of July 1, 2022 through June 30, 2023. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the amounts reported on the annual data reports agree to the underlying expenditure detail in the accounting system. Person responsible for implementation and projected implementation date: The Treasurer and the Superintendent will be responsible for implementing the corrective action plan, which will start with the next submission of the annual data report.

View Audit 347466

Finding 529424 (2024-004)

Significant Deficiency 2024

Catholic Social Services, Inc.

AK

Subrecipient Monitoring

One subrecipient was not monitored appropriately, increasing the risk of noncompliance with grant requirements. Corrective Actions: 1. Standardized Subrecipient Monitoring Procedures: o Develop a formal subrecipient monitoring policy to ensure all subrecipients are reviewed. o Target Completion: Pol...

One subrecipient was not monitored appropriately, increasing the risk of noncompliance with grant requirements. Corrective Actions: 1. Standardized Subrecipient Monitoring Procedures: o Develop a formal subrecipient monitoring policy to ensure all subrecipients are reviewed. o Target Completion: Policy finalized within the end of Fiscal Year 2025. 2. Require Annual Audit Reports from All Subrecipients: o CSS will require all subrecipients to submit annual audit reports to identify any compliance risks. o Target Completion: First audit report request within next fiscal quarter. 3. Designated Subrecipient Compliance Director: o Assign a compliance director within the State Refugee Designee team at CSS to oversee and track subrecipient monitoring, ensuring all required reviews are conducted. o Target Completion: Role assigned within the end of Fiscal Year 2025. Responsible Staff: State Refugee Coordinator in conjunction with Senior Director of Grants and Chief Financial Officer

View Audit 347428

Finding 529422 (2024-002)

Material Weakness 2024

Catholic Social Services, Inc.

AK

Subrecipient Monitoring Reporting

Corrective Actions: 1. Automated Tracking System for Reporting Deadlines: o Enhance a compliance tracking system (Sage Intacct) to record reporting deadlines. o Assign a compliance director (Senior Director of Grants) to review and confirm each FFATA filing monthly. o Target completion date: Within ...

Corrective Actions: 1. Automated Tracking System for Reporting Deadlines: o Enhance a compliance tracking system (Sage Intacct) to record reporting deadlines. o Assign a compliance director (Senior Director of Grants) to review and confirm each FFATA filing monthly. o Target completion date: Within three months. 2. Staff Training on FFATA Compliance: o Conduct or Solicit training sessions for grant managers and finance staff on federal subaward reporting requirements. o Develop a written guide outlining responsibilities for FFATA compliance. o Target completion date: By the end of Fiscal Year 2025. 3. Internal Audit & Oversight Process: o Establish a quarterly compliance review to ensure all subawards are properly documented and reported. o Designate a compliance officer or senior grant staff member to review FFATA reports before submission. o Target completion date: First review to occur within the next fiscal quarter. Responsible Staff: Senior Director of Grants in conjunction with Chief Financial Officer

View Audit 347428

Finding 529403 (2024-002)

None 2024

University of California

CA

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

2024-002 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.06...

2024-002 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Financial Aid Counselors (FAC) can manually award students on the spot and verbally inform students to go online and accept/decline their awards. When this happens, an email may not go out to students. Starting with the 2025-26 financial aid award cycle, we will create a routine in the Banner Financial Aid system that will review student’s email log (RUAMAIL) and if an official email notification is not logged, the system will automatically send one to ensure that every student who is awarded Title IV aid will receive an email notification advising them to review and accept/decline their financial aid award offer. Title IV aid will not disburse until this requirement is met keeping the institution in compliance. To obtain a student’s voluntary consent to participate in electronic actions for the Electronic Signatures in Global and National Commerce Act (“E-Sign Act”), Information Technology Solutions (ITS) will investigate and implement one of the following options: • Reinstate the consent to participate in electronic transactions in R’Web annually and ensure that it captures the history of the acceptance of the Terms of Service (TOS) that will include the date students accepted the TOS. • Present the TOS to students upon logging into Central Authentication Services (CAS) annually and ensure that it captures the history of the acceptance of the TOS that will include the date students accepted the TOS. • Present the TOS to students as a hold annually on Banner that they must acknowledge to clear. Banner records this action on SOAHOLD. The student TOS will be presented to students for acceptance during the first time accessing University systems, depending on the option implemented, and will display it annually during the annual anniversary of the original acceptance. ITS will begin evaluation of the effort in Summer 2025 with a goal of implementing a solution in the 2025-26 academic year. For inquiries regarding the disbursement notifications, please contact Jose A. Aguilar at jose.aguilarjr@ucr.edu. For inquiries regarding the E-Sign Act, please contact Teri Eckman at teri.eckman@ucr.edu

View Audit 347386

Finding 529402 (2024-001)

None 2024

University of California

CA

Student Financial Aid Subrecipient Monitoring

2024-001 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable The Depart...

2024-001 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grants Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.063 Award Year: 2023-2024 Pass-through entity: Not applicable The Department of Education provided verification relief for the 2021-22 and 2022-23 aid years by waiving certain verification requirements. If a record was selected for verification but was not verified, schools were to set the code to “S”. The routine was changed for those two years but was carried forward to the 2023-24 aid year. The automated routine has been corrected, and it is currently assigning the correct verification code based on the completion of the student financial aid verification. This correction has been implemented for the current 2024-25 award year cycle and is working properly for the 2024-25 award year cycle. Starting with the 2025-26 award year cycle, in April of 2025 we will add the review of the verification code assignment based on the completion of the student verification files to the already established annual new year roll in the Banner Financial Aid system. The routine will be reviewed and adjusted as needed and ensure that the routine is set up correctly for the 2025-26 award year. For inquiries regarding this finding, please contact Jose A. Aguilar at jose.aguilarjr@ucr.edu.

View Audit 347386

Finding 529399 (2024-003)

None 2024

University of California

CA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2024-003 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal S...

2024-003 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Award Numbers: Various Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Campus One The Financial Aid and Scholarships (FAS) office will take action to allocate the appropriate staff resources, training, tools and management oversight to ensure timely processing of R2T4s, including the return of applicable funds to COD. We have identified 2 recently hired counseling staff who were trained by our Assistant Director of Compliance on R2T4 processing and provided regulatory and campus updates in the 2024-25 academic year. The staff will complete the initial R2T4 review and calculation on a weekly basis and started this work in February 2025. The FAS team will implement an updated tracking and monitoring mechanism that includes the date of withdrawal, the date the refund is processed, and the date the refund is submitted to the Department of Education. The Assistant Director of Compliance will identify potential delays and check in with staff on their weekly reports. This will allow for corrective action prior to the 45-day deadline. The FAS managers will make R2T4 processing a standing item in management meetings to identify any competing priorities that may contribute to compliance concerns. The report used to identify withdrawn students will be reviewed and revised, with FAS staff input, to create efficiencies for managing the work each week. Anticipated completion date of all adjustments is the end of July 2025, with iterations continuing for reports and the tracking mechanism as needed. For inquiries regarding this finding, please contact Silvia Marquez at semarquez@ucsd.edu. Campus Two While we note that no Return of Title IV Funds calculation errors occurred, the campus will institute improved tracking, reporting, and completion of the secondary review process within the 45-day funds return window. To assist in the review effort the campus has cross-trained multiple staff members to ensure enough personnel have the necessary skills, knowledge, and awareness to manage the review process effectively. Anticipated completion of implementation is May 2025. For inquiries regarding this finding, please contact Nancy Garcia at ngarcia@fas.ucla.edu.

View Audit 347386

Finding 529306 (2024-102)

Material Weakness 2024

The Academy of Tucson

AZ

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.306 § 200.308

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted it...

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

View Audit 347332 Questioned Costs: $1

Finding 529305 (2024-103)

Significant Deficiency 2024

The Academy of Tucson

AZ

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.300 § 200.306 § 200.308

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted it...

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

View Audit 347332

Finding 529300 (2024-004)

Material Weakness 2024

Scott County School District 1

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate, Material Weakness Summary of Finding: This was a repeat finding. An effective internal control system was not designed or implemented at th...

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate, Material Weakness Summary of Finding: This was a repeat finding. An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card High School Graduation Rate compliance requirement until the 2023/2024 school year. The School Corporation had not established internal controls for most of the audit period to ensure that the required documentation to remove a student from a cohort was confirmed and maintained with the withdrawal forms prior to removing the student from the cohort. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Starting in the 2023/2024 school year, the building principal now signs off on the supporting documentation that is being retained to support a student’s withdrawal from the cohort. Anticipated Completion Date: The anticipated completion date was the 2023/2024 school year.

View Audit 347331

Finding 529295 (2024-003)

Material Weakness 2024

Scott County School District 1

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll cle...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll clerks. Lack of an internal control. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Clerk will submit the reimbursement requests to the corporation Business Manager for review before the reimbursement is submitted to MAESSU for payment. Anticipated Completion Date: The anticipated completion date will be with the April reimbursement submission.

View Audit 347331

Finding 529261 (2024-001)

Significant Deficiency 2024

Finger Lakes Community College

NY

Student Financial Aid Subrecipient Monitoring

SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management...

SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. As part of this process, the College should then review the current policies and procedures at least annually to determine if any updates should be made. Corrective Action Plan: The College agrees with the finding and as of March 2025 the College has contracted with an outside third party to perform an formal risk assessment. Once the risk assessment has been performed the College will work on ensuring the appropriate safeguards are in place and remediation plans identified. Additionally policies continue to be reviewed and updated through the governance process at the College. FLCC Responsible Party: Jason Tack, VP of Finance and Administration, jason.tack@flcc.edu, 585-785-1208. Audit finding will be corrected by 8/31/2025.

View Audit 347304

Finding 529257 (2024-001)

Significant Deficiency 2024

Pennsylvania Association of Regional Food Banks

PA

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and C...

Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and Cause: There were three instances out of 40 distributions tested where this signoff was not completed. Due to the hectic environment at the lead agencies during food distribution day, oversights have occurred when obtaining the required client signoff. Statement of Concurrence or Nonconcurrence: PARF management has reviewed the 2024-001 finding and concurs with the recommendations as stated. Corrective Action: PARF has an extensive training process in place for lead agencies, in relation to grant award compliance requirements, which includes the provision of training manuals and monthly phone calls to review matters. In addition, PARF provides updates to the lead agencies as new or amended requirements are enacted. Further, PARF does periodic reviews of the lead agencies and completes the biennial review Form 502035 CSFP Management Evaluation. PARF will continue to reiterate the required signoff process with the lead agencies during phone calls, training session and reviews. In addition for FY 2025 PARF will be conducting a mandatory webinar to ensure all the lead agencies are understanding the procedure and why it is important for 100 percent accuracies -https://docs.google.com/presentation/d/1YZgcq7SY4DmvhYrKZE8sp-NDhpuzn827PZDZ0xAKDw/edit?usp=sharing

View Audit 347284

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