Corrective Action Plans

Finding 518523 (2024-003)

Material Weakness 2024

CA

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

The prior Director of Nutrition Services contracted with a third party in order to collect the eligibility forms and automate the data input in our SIS system. The District will no longer use that third party, and the District has moved to a Provision 2 status, which no longer requires the collectio...

The prior Director of Nutrition Services contracted with a third party in order to collect the eligibility forms and automate the data input in our SIS system. The District will no longer use that third party, and the District has moved to a Provision 2 status, which no longer requires the collection of meal application forms. Alternative Income forms collected in the future will be clerked by the office managers at the school sites, and double checked by the Student Data specialist prior to interim auditing each year.

View Audit 336985

Finding 518516 (2024-002)

Material Weakness 2024

Ojai Unified School District

CA

Subrecipient Monitoring Cash Management Material Weakness

The District will create a procedure for monthly review of meal counts at sites and reconciliation with the monthly claims. Reports will require a second person to review and approve before filing. The Director of Nutrition Services will review the Title 7 requirements and review the new procedure f...

The District will create a procedure for monthly review of meal counts at sites and reconciliation with the monthly claims. Reports will require a second person to review and approve before filing. The Director of Nutrition Services will review the Title 7 requirements and review the new procedure for compliance.

View Audit 336985

Finding 518515 (2024-002)

Significant Deficiency 2024

New Mexico Early Childhood Education and Care Department

NM

Subrecipient Monitoring Reporting School Nutrition Programs

U.S. Department of Agriculture Summer Food Service Program - Child Nutrition Cluster Assistance Listing Numbers: 10.559 Recommendation: While the program did perform the monthly FNS418 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the da...

U.S. Department of Agriculture Summer Food Service Program - Child Nutrition Cluster Assistance Listing Numbers: 10.559 Recommendation: While the program did perform the monthly FNS418 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the data collected from the subrecipients into the FSRF portal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time of audit completion, the relevant FFATA information from the Food and Nutrition Bureau was submitted to the Grant Manager for proper reporting, ensuring compliance for FY2025. To support this process, Legal will collaborate with the program to ensure that award letters accurately identify the awardee. Additionally, the CFO conducted Federal Grant Management training in May 2024, which included FFATA documentation and reporting, along with an overview of ECECD’s final policies and procedures for Grant Management. The CFO and ASD will continue to update training materials to maintain compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Valerie Garcia, Budget Director; Amanda Carlisle, Grants Manager; ECECD Program Managers. Planned completion date for corrective action plan: The CFO has already implemented some of the review processes in collaboration with the Budget Director, Grant Management team, and relevant programs. The remaining processes will be addressed and fully implemented by June 30, 2025. If the U.S. Department of Agriculture has questions regarding this plan, please contact: Carmel Pacheco-Aragon Chief Financial Officer New Mexico Early Childhood Education & Care Department 1120 Paseo de Peralta Santa Fe, NM 87501 Phone: (505) 901-8226 Carmel.Pacheco1@ececd.nm.gov

View Audit 336975

Finding 518455 (2024-002)

Significant Deficiency 2024

City of Battle Creek

MI

Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: 2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Program: Community Development Block Grants/Entitlement Grants (ALN 14.218); U.S. Department of Housing and Urban Development; Direct award; All project numbers. Lead Hazard Reduction Grant Program (ALN 14.905...

Finding: 2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Program: Community Development Block Grants/Entitlement Grants (ALN 14.218); U.S. Department of Housing and Urban Development; Direct award; All project numbers. Lead Hazard Reduction Grant Program (ALN 14.905); U.S. Department of Housing and Urban Development; Direct award; All project numbers. Auditor Description of Condition and Effect: The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders. Responsible Person: Aaron Kuhn, Revenue Services Director Anticipated Completion Date: June 30, 2025

View Audit 336917

Finding 518452 (2024-001)

Significant Deficiency 2024

Stepstone Academy

OH

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing c...

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the Academy will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the Academy has received an executed copy of the form. Upon notification of construction commencement, the Academy will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 336907

Finding 518451 (2024-001)

Significant Deficiency 2024

Cleveland College Preparatory School

OH

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing co...

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 336896

Finding 518427 (2024-002)

None 2024

University of St. Thomas

TX

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

Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid ru...

Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid runs a query once a month to find students who have received Title IV or state aid and have withdrawn. The student in question did not appear on the query when we believe they should have, but was on the subsequent report. We have changed our procedures to run the query and complete Return to Title IV calculations weekly, rather than monthly. We believe this will help us find any discrepancies more quickly. We also reviewed the query and made some edits to attempt to increase accuracy. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid Implementation Date: 09/01/2024

View Audit 336808

Finding 518425 (2024-001)

Significant Deficiency 2024

University of St. Thomas

TX

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that...

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024

View Audit 336808

Finding 518423 (2024-004)

Significant Deficiency 2024

Rochester Childfirst Network

NY

Subrecipient Monitoring Eligibility

Finding 2024-004 – Child and Adult Care Food Program, Passed Through NYS Department of Health, AL#10.558; for the Year Ended June 30, 2024 Recommendation: The Organization should ensure that processes are in place so that eligibility forms are reviewed and compared to the levels in the computer. ...

Finding 2024-004 – Child and Adult Care Food Program, Passed Through NYS Department of Health, AL#10.558; for the Year Ended June 30, 2024 Recommendation: The Organization should ensure that processes are in place so that eligibility forms are reviewed and compared to the levels in the computer. Action Taken: The organization will ensure that eligibility on the forms and eligibility levels entered in the computer are monitored and reviewed for accuracy. The Director of CACFP Program will be responsible for implementing this updated process and it will be fully implemented by June 30, 2025.

View Audit 336798

Finding 518382 (2024-001)

Material Weakness 2024

New Albany-Floyd County Consolidated School Corporation

IN

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

Finding 2024-001 – Child Nutrition Cluster – Eligibility 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 ...

Finding 2024-001 – Child Nutrition Cluster – Eligibility 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. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A manager will review eligibility determination and guidelines moving forward. Anticipated Completion Date: Immediate correction.

View Audit 336751

Finding 518130 (2024-001)

None 2024

Cift

OH

Subrecipient Monitoring Reporting Program Income

State of Condition:During the year ended June 30, 2024, the Center had unexpended program income for the 5 year term of the cooperative agreement. Corrective Action: Resolved. The Center made restitution for the unexpended amount as well as implemented new procedures to track program income and ex...

State of Condition:During the year ended June 30, 2024, the Center had unexpended program income for the 5 year term of the cooperative agreement. Corrective Action: Resolved. The Center made restitution for the unexpended amount as well as implemented new procedures to track program income and expenses to ensure the issue does not occur in the future

View Audit 336437

Finding 518106 (2024-007)

Material Weakness 2024

Washoe County

NV

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Internal controls will be created to ensure that the Quarterly Compliance Reports agree to internal supporting documents and that reports will be submitted timely.

View Audit 336406

Finding 518090 (2024-004)

Material Weakness 2024

Washoe County

NV

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Establish a procedure to track and monitor the single audits (if required) of the subrecipients of grants issued through Washoe County.

View Audit 336406

Finding 518015 (2024-001)

Significant Deficiency 2024

East Side Union High School District

CA

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

Finding 2024-001: Time and Effort Requirements (50000) Assistance Listing No. 84.010 - Title I, Part A Assistance Listing No. 84.425 - Education Stabilization Funds (ESSER) U.S. Department of Education Passed through California Department of Education Response to finding 2024-001: Time and effort r...

Finding 2024-001: Time and Effort Requirements (50000) Assistance Listing No. 84.010 - Title I, Part A Assistance Listing No. 84.425 - Education Stabilization Funds (ESSER) U.S. Department of Education Passed through California Department of Education Response to finding 2024-001: Time and effort requirements Controller Marisol Esparza has developed a process that includes completing corrections by January 31, 2025, and receiving all future forms promptly. Managers of each employee group have been notified of the importance of completing the time and effort requirements. Managers, with the support of the administrative/department secretaries, are now tasked with monitoring, reconciling, and ensu ing that these documents are completed and submitted monthly.

View Audit 336357

Finding 518008 (2024-003)

None 2024

Mass General Brigham Incorporated

MA

Questioned Costs Subrecipient Monitoring Cash Management § 200.208 § 200.305 § 200.334

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management ...

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management requirements due to the nature of the award. Mass General Brigham (MGB) has removed the $215K of questioned costs from the Schedule of Expenditures of Federal Awards (SEFA). The funding will be returned to Advanced Regenerative Manufacturing Institute, Inc. in January 2025. Additionally, management will review the limited instances where departments have been previously approved to request federal cash. This review is to confirm that an exception to the standard practice of managing this through the central Research Finance team is appropriate. Based on results of this review, to be completed by March 2025, management will determine criteria and prior approval requirements for departments to request federal cash if MGB concludes this practice will continue on a limited exception basis. The review will be conducted with oversight by the MGB Vice President of Research Management and Research Finance and the MGB Research Controller.

View Audit 336310 Questioned Costs: $1

Finding 518002 (2024-001)

Material Weakness 2024

Sampson County Partnership for Children

NC

Eligibility Subrecipient Monitoring § 200.303

Moving forward, we will require that all NC Pre-K program staff receive intense training on the proper procedures for reviewing student folders for edibility and to qualifications for the NC Pre-K program. The NC Pre-K score cards will be reviewed by two staff members, signed, and printed for confir...

Moving forward, we will require that all NC Pre-K program staff receive intense training on the proper procedures for reviewing student folders for edibility and to qualifications for the NC Pre-K program. The NC Pre-K score cards will be reviewed by two staff members, signed, and printed for confirmation of eligibility with each application. The Applications will then be placed in each child file for proof of eligibility and qualification. The Eligibility training will be conducted through the NC Pre-K DCDEE Program Policy Consultant Jeanne Barnes.

View Audit 336291

Finding 517996 (2024-002)

Material Weakness 2024

Unified School District #457

KS

Subrecipient Monitoring Allowable Costs / Cost Principles Equipment & Real Property Management

The District's management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate, with a planned implementation date by the Financial Officer of December 13, 2024.

View Audit 336264

Finding 517988 (2024-001)

None 2024

Monmouth College

IL

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ...

2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)). Condition: The College did not implement a written information security program and a risk assessment as part of the Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Corrective Action Plan: We are currently working with our IT vendors (CampusWorks and Lockstep) on policies and increasing GLBA compliance. Responsible Person for Corrective Action Plan: Holly Tharp, Vice President for Finance and Business Implementation Date for Corrective Action Plan: June 30, 2025

View Audit 336252

Finding 517983 (2024-002)

Material Weakness 2024

City of Port Huron, Michigan

MI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

Condition: We noted during testing that the City did not maintain sufficient documentation to ensure that subrecipients and contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into a contract or agreement with the third party. Planned C...

Condition: We noted during testing that the City did not maintain sufficient documentation to ensure that subrecipients and contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into a contract or agreement with the third party. Planned Corrective Action: The City of Port Huron will implement a new process for approval of all invoices related to ARPA grant expenses. This includes a check for suspension and debarment prior to any invoices approval and appropriate documentation. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: December 31, 2024.

View Audit 336249

Finding 517974 (2024-003)

Significant Deficiency 2024

Mount Mercy University

IA

Subrecipient Monitoring Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University 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. Ac...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University 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: Mount Mercy University’s information technology department has implemented an annual process to review access controls and ensure access is only provided to authorized individuals. Authorized users will only have access to sensitive information which is required to perform their roles and responsibilities. Name(s) of the contact person(s) responsible for corrective action: Curtis Sanders Planned completion date for corrective action plan: 06/30/2025

View Audit 336229

Finding 517937 (2024-004)

Significant Deficiency 2024

State of New Mexico Workforce Solutions Department

NM

Subrecipient Monitoring § 200.332 § 200.521

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirement...

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location and, therefore we also recommend standardizing the documentation of monitoring activities, using monitoring logs, monitoring checklists, and audit test sheets, etc. If the Department is experiencing periods where understaffing or staffing turnover is an issue causing risk of noncompliance, we recommend that the Department properly address those risks and consider contracting out certain monitoring controls to a third-party professional service firm. Management Response Corrective Action: Serve New Mexico acknowledges the lack of sufficient documentation for annual site visits and that fiscal monitoring activities for the 2023-2024 program year were not sufficient. To address this, we are revising our policies and procedures to comply with 2 CFR 200.303 (Internal Controls) and 2 CFR 200.332 (Requirements for Pass-Through Entities). Key actions we are implementing include: 1. Site Visits Documentation: We will conduct regular site visits as a component of our monitoring activities for 2024-2025 program year with clear, consistent and documented objectives for each visit and proper documentation of monitoring activities conducted during each visit. 2. Expansion of Fiscal Monitoring: Review of cost documentation will be expanded to include all subgrantees, regardless of risk, and for subrecipients subject to heightened fiscal monitoring, review of more than one month of documentation will be conducted. 3. Centralized Documentation: All supporting documentation will be scanned and stored in a centralized shared folder. This will ensure clarity and accessibility of records, particularly in the event of staff turnover. 4. Collaboration with a Consultant: Our Fiscal and Compliance Officer is working closely with a consultant to streamline fiscal policies and procedures in line with 2 CFR 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 5. Uniform Audit Test Sheet: We will develop a standardized audit test sheet to ensure that all programmatic and fiscal monitoring activities are consistently documented across all programs. These steps are designed to ensure compliance and enhance the effectiveness of our monitoring processes, addressing the findings of the audit comprehensively Due Date of Completion: June 30, 2025 Responsible Party(ies): Serve New Mexico Director

View Audit 336212

Finding 517934 (2024-003)

Material Weakness 2024

State of New Mexico Workforce Solutions Department

NM

Subrecipient Monitoring § 200.332 § 200.521

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allows for compliance with all applicable federal laws, regulations, and compliance requireme...

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allows for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. We also recommend standardizing the documentation of monitoring activities, using monitoring logs, monitoring checklists, and audit test sheets, etc. If the Department is experiencing periods where understaffing or staffing turnover is an issue causing risk of noncompliance, we recommend that the Department properly address those risks and consider contracting out certain monitoring controls to a third-party professional service firm. Management Response Corrective Action: The Department acknowledges that we had not completed the required monitoring for Program Years 2022 and 2023. The Department has contracted with a third-party monitor to complete the Program Years 2022 and 2023 monitoring. Program Year 2024 monitoring is on track to be completed by June 30, 2025. The Department has created a corrective action plan to bring the WIOA monitoring into compliance. The Department has completed a risk assessment for Program Year 2024 which is now attached to the grant agreements. The WIOA Monitoring Unit will use the Department’s Grant Risk Assessment tool for future grant agreements. The WIOA Monitoring Unit is in the process of drafting a policy for subrecipient monitoring. This policy will establish monitoring standards for subrecipients and pass-through entities of WIOA Title I-B and related discretionary awards. The policy will include: Frequency of Monitoring Reviews Scope of Monitoring Reviews Monitoring Letters and Reports Due Date of Completion: June 30, 2025 Responsible Party(ies): Administrative Services Division Director

View Audit 336212

Finding 517876 (2024-001)

Significant Deficiency 2024

Orange County Department of Education

CA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

The Attendance and Records Center (ARC) team has put in place a process to check students with any cohort removal codes on a weekly basis, and ensure any required backup documentation is scanned into Aeries. Additionally, all staff received training on the Status Change form and the cohort exit code...

The Attendance and Records Center (ARC) team has put in place a process to check students with any cohort removal codes on a weekly basis, and ensure any required backup documentation is scanned into Aeries. Additionally, all staff received training on the Status Change form and the cohort exit codes that require backup documentation. The ACCESS Administrative Guidelines and Procedures Manual was also shared with staff, including section 3.9 addressing, "Documentation and Evidence Required in Order to Remove a Student from the High School Graduation Rate Cohort." All new staff will receive a copy of the manual. In response to the 2023-2024 audit additional measures have been taken in perpetuity: a) Every four weeks a sql query is run to find all cohort removal exit codes. Each one is confirmed or changed according to the documentation provided. b) Each year we re-train the enrollment staff to follow procedures in alignment with the state requirements. The meeting for this year was held on May 22, 2024 and it will be reviewed again in the Spring. c) Internal Policy and Procedure reflects not only the importance of proper documentation but provides details about what the documentation should be. These monitoring steps will ensure that this will not be a finding in the following year.

View Audit 336087

Finding 517842 (2024-001)

Material Weakness 2024

Notmykid, Inc.

AZ

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

Condition: Total federal expenditures for the year ended June 30, 2024 amounted to $1,095,663. Prior to the performance of financial statement audit procedures, the Organization had determined that federal expenditures during the year ended June 30, 2024 did not exceed the threshold of $750,000. Re...

Condition: Total federal expenditures for the year ended June 30, 2024 amounted to $1,095,663. Prior to the performance of financial statement audit procedures, the Organization had determined that federal expenditures during the year ended June 30, 2024 did not exceed the threshold of $750,000. Recommendation: We recommend that all funding contracts are carefully reviewed to determine whether the amounts awarded represent federal funding and whether they should be classified as contractor payments or as subrecipient payments. If there is any uncertainty, we recommend that the Organization contact the funding source for clarification. We recommend that a schedule of expenditures of federal awards is prepared on an annual basis to determine if total expenditures exceed the threshold which would require a Single Audit. Name of Contact Person: Kristen Genovese, CEO Phone Number: 602-652-0163 Anticipated Completion Date: June 30, 2025 Views of Responsible Officials and Corrective Actions: notMYkid, Inc. will establish procedures to review all contracts and, if necessary, to communicate with funding sources to ensure that receipts of federal funding are properly classified as subrecipient versus contractor arrangements to ensure completeness of the Schedule of Expenditures of Federal Awards. notMYkid, Inc. will also prepare the Schedule of Expenditures of Federal Awards on an annual basis to determine whether the threshold for a Single Audit is exceeded.

View Audit 336012

Finding 517832 (2024-005)

Material Weakness 2024

Lennox School District

CA

Subrecipient Monitoring Material Weakness Reporting

Due to staff turnover and key vacant positions, we were unable to locate some supporting documentation. However, procedures have been developed and implemented to ensure all reports and supporting documentation will be kept on file for a minimum of three years in a location accessible by all employe...

Due to staff turnover and key vacant positions, we were unable to locate some supporting documentation. However, procedures have been developed and implemented to ensure all reports and supporting documentation will be kept on file for a minimum of three years in a location accessible by all employees.

View Audit 335998

Corrective Action Plans

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