Corrective Action Plans

Finding 513973 (2024-007)

Significant Deficiency 2024

IL

Questioned Costs Subrecipient Monitoring Cash Management

Condition: The expenditure reports filed with the Illinois State Board of Education do not match the general ledger detail. Plan: To avoid this reporting issue, the District should review expenditure reports prior to using them to prepare the projects’ quarterly reports. Anticipated Date of Comple...

Condition: The expenditure reports filed with the Illinois State Board of Education do not match the general ledger detail. Plan: To avoid this reporting issue, the District should review expenditure reports prior to using them to prepare the projects’ quarterly reports. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Jason Brunaugh, Assistant Superintendent of Finance and Human Resources Management Response: The District will work to properly report transactions in the future.

View Audit 332183 Questioned Costs: $1

Finding 513972 (2024-004)

Significant Deficiency 2024

Community Unit School District 100

IL

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Condition: Quarterly expenditure reports for the projects expenditures were not timely filed for ESSER II CP (1 of 1 quarters required) and ESSER II D2 (1 of 1 quarters required). Plan: To avoid this reporting and internal control issue, the District should schedule the due dates of all expenditure...

Condition: Quarterly expenditure reports for the projects expenditures were not timely filed for ESSER II CP (1 of 1 quarters required) and ESSER II D2 (1 of 1 quarters required). Plan: To avoid this reporting and internal control issue, the District should schedule the due dates of all expenditure reports in order to avoid late filings. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Jason Brunaugh, Assistant Superintendent of Finance and Human Resources Management Response: This District is aware of the issue and has determined that the majority of the problem occurs when a grant is first approved, and the first reporting period is missed or if a grant continues into subsequent project years. Management has found a dashboard within IWAS that has a listing of all grants by project year and dates that the grants and budgets are approved that will help determine when the first expenditure reports are due. Additionally, management will work on a process to ensure that expenditure reports are no longer missed or filed late.

View Audit 332183

Finding 513864 (2024-004)

Significant Deficiency 2024

Umonhon Nation Public Schools District #16

NE

Reporting Procurement, Suspension & Debarment Subrecipient Monitoring

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 Title I reimbursement request was pending, so it was deleted and a new one will be submitted to include prior year spending. The District will amend the ARP Homeless Children and Youth HCY I budget and will include prior year spending on the closeout reimbursement request. The District will work with the grantor agency on any necessary correction of reports and submission of supporting documentation for ESSERS III since that has been fully paid.

View Audit 331883

Finding 513848 (2024-002)

Material Weakness 2024

Department of Transportation - Airports Division, State of Hawaii

HI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented ...

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented during February 2024 in full. Contact person responsible for corrective action: Karen Honda, Fiscal Management Officer Anticipated Completion Date: February 1, 2024

View Audit 331853

Finding 513831 (2024-001)

Significant Deficiency 2024

Doane University

NE

Student Financial Aid Subrecipient Monitoring Significant Deficiency

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an em...

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an email confirmation. Name(s) of Contact Person(s) Responsible for Corrective Action: Federico Peña Jr. (Fred), Financial Aid Director Anticipated Completion Date: November 6, 2024

View Audit 331806

Finding 513810 (2024-001)

Material Weakness 2024

City of Grosse Pointe Farms, Michigan

MI

Subrecipient Monitoring Material Weakness Internal Control / Segregation of Duties § 200.303

Finding Number: 2024-001 Condition: There is no evidence of review of reports submitted to the funding agency. Planned Corrective Action: The City of Grosse Pointe Farms has hired additional staff in the accounting department that will complete review of reports prior to submission to the funding ag...

Finding Number: 2024-001 Condition: There is no evidence of review of reports submitted to the funding agency. Planned Corrective Action: The City of Grosse Pointe Farms has hired additional staff in the accounting department that will complete review of reports prior to submission to the funding agency. Contact person responsible for corrective action: Tim Rowland, Finance Director Anticipated Completion Date: 09/03/2024

View Audit 331782

Finding 513794 (2024-001)

None 2024

McFarland Unified School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

The ESSER III 2024 Fall Report submitted to the California Department of Education on October 15, 2024, reflected the correction made to include the credit not reported on the prior ESSER III quarterly report. The Business Department has been added as an additional reviewer prior to submission.

View Audit 331746

Finding 513770 (2024-003)

Significant Deficiency 2024

Childfund International, USA

VA

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of p...

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of proper period end cut-offs with the Accounting and Grants Teams. Moving forward, the Grants and Project Management team will discuss expense cut-offs during the kick-off meetings and the importance of year-end accruals. The Accounting Department will also provide additional training and reminders around year-end cut-offs and the importance of reviewing invoice dates for accruals that are under our normal threshold of $1,000 USD for grants.

View Audit 331718

Finding 513769 (2024-002)

Significant Deficiency 2024

Childfund International, USA

VA

Subrecipient Monitoring § 200.303

Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Laura Meloy, VP, Finance Completion Date: Completed Corrective Action: The ChildFund Management team has taken immediate action by creating the organization’s profile and account on the Federal Fundi...

Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Laura Meloy, VP, Finance Completion Date: Completed Corrective Action: The ChildFund Management team has taken immediate action by creating the organization’s profile and account on the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). We have also submitted the required report for the previous period. Moving forward, the Grants and Project Management team will be responsible for managing this requirement by tracking and reporting each subaward in a timely manner, following FFATA legislation and Office of Management and Budgets guidance to report subawards greater than or equal to $30,000 by the end of the month following the month in which ChildFund issues any subawards under any federal awards.

View Audit 331718

Finding 513768 (2024-001)

Significant Deficiency 2024

Childfund International, USA

VA

Procurement, Suspension & Debarment Subrecipient Monitoring

Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The vetting conducted for the subject procurement aligns with ChildFund’s current terrorist vetting policy and...

Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The vetting conducted for the subject procurement aligns with ChildFund’s current terrorist vetting policy and procedures. As a multi-donor organization operating globally, ChildFund faces varying thresholds and requirements for vetting vendors, contractors, suppliers, service providers, and consultants depending on the specific donor. In some cases, there may be no threshold at all. In order to make sure we follow the most restricted situation and requirements, we will update our terrorist vetting policy and procedures to ensure compliance with the most restricted donor by conducting repetitive vetting within a reasonable timeframe and threshold. Once this update is complete, we will ensure that the revised policy and procedures are adequately communicated throughout the organization and that appropriate internal controls are put in place.

View Audit 331718

Finding 513712 (2024-001)

None 2024

Episcopal Children's Services, Inc.

FL

Eligibility Subrecipient Monitoring Cash Management

Correction Action: Management determined that this recipient was ineligible during the program year and changed their status to inactive. However, new staff did not process reimbursement for the overpayment. To address this, management has improved its quality assurance procedures by having personne...

Correction Action: Management determined that this recipient was ineligible during the program year and changed their status to inactive. However, new staff did not process reimbursement for the overpayment. To address this, management has improved its quality assurance procedures by having personnel run monthly eligibility reports to identify recipients whose ages fall outside acceptable ranges prior to submitting the monthly invoice. Any ineligible recipients who have not been terminated will be promptly removed from service and excluded from the monthly invoice. The quality assurance team will also evaluate any potential overpayments that may have occurred and, if necessary, will apply refunds as credits on the next invoice to the Division of Early Learning. In relation to the issue mentioned in this finding, management has recorded the amount of $1,947.06 as a credit on a Prior Year 23-24 Invoice in the 5045 report and has processed this amount for repayment to the Division of Early Learning as of September 13, 2024. Management conducted a thorough review of the identified eligibility issue and found only two cases among all enrolled participants. The total claims billed after the age-out date that remain unpaid amounted to $4,503.69 for both instances during the fiscal year. These amounts have been submitted to the Division of Early Learning for repayment.

View Audit 331618

Finding 513702 (2024-003)

Significant Deficiency 2024

City Colleges of Chicago

IL

Reporting Subrecipient Monitoring § 200.303

Condition • For four of the twelve (33.3%) reports tested for the Child Care and Development Block Grant program, City Colleges did not timely submit certain quarterly reports to the grantor. Reports were submitted between one to thirty days late. • For four of the fifteen (26.7%) reports tested f...

Condition • For four of the twelve (33.3%) reports tested for the Child Care and Development Block Grant program, City Colleges did not timely submit certain quarterly reports to the grantor. Reports were submitted between one to thirty days late. • For four of the fifteen (26.7%) reports tested for the Coronavirus State and Local Fiscal Recovery Funds, City Colleges did not timely submit certain quarterly and close-out reports to the grantor. Reports were submitted between one to two days late. Cause Submission delays were a result of poor time management and breakdowns in communication between PIs, grantor, and the District Office Institutional Resource Development Team. Corrective Action Taken or Planned Institutional Resource Development (IRD) team is fully staffed. IRD launched a comprehensive Grants Management Platform, which will assist with tasks and reporting timeline reminders. Principal Investigators (PIs) will meet with Grant Managers to finalize reports. The managers will review the reports prior to submission to the funders in a timely manner. Contact Person: Lizz Gardner, Associate Vice Chancellor, Institutional Resource Development Anticipated Completion Date: November 30, 2024

View Audit 331604

Finding 513700 (2024-002)

Significant Deficiency 2024

City Colleges of Chicago

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, th...

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. • For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. • For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Cause CCC sends enrollment files of all students to National Student Clearinghouse (NSC) monthly, who then reports CCC enrollment data to National Student Loan Data System (NSLDS). It was discovered that two of the errors occurred due to an update in NSLDS and CCC was not aware the update caused missing files. In the other instances files were sent in late February, but not corrected within NSC until March 5th thus, it missed the beginning of the March roster. Corrective Action Taken or Planned CCC will work with NSC to monitor future updates and ensure files are accurately shared with NSLDS. Records, Financial Aid, Decision Support and OIT continue to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. In addition, the compliance team will monitor updates and announcements from NSC regarding file errors to ensure timely updates are submitted. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 20, 2024

View Audit 331604

Finding 513671 (2024-001)

Material Weakness 2024

Bronx Charter School for Better Learning

NY

Subrecipient Monitoring Cash Management Reporting

Recommendation It is recommended that the Charter School implement procedures to ensure the reporting of expenditures is accurate in the Education Stabilization Fund Annual Reporting. This will ensure the information is shown in accordance with the instructions for the NYSED report and the related U...

Recommendation It is recommended that the Charter School implement procedures to ensure the reporting of expenditures is accurate in the Education Stabilization Fund Annual Reporting. This will ensure the information is shown in accordance with the instructions for the NYSED report and the related U.S. Department of Education requirements. Management response We agree with the findings and recommendation. We will implement procedures to ensure that future reporting of expenditures on this required report is accurate. Corrective Action Nicole Tennant, Director of Finance, will establish a standardized procedure for reporting expenditures in the Education Stabilization Fund to ensure all required information is captured accurately and in compliance with the reporting guidelines. Nicole Tennant and relevant staff members involved in the preparation of the report will undergo additional training on the specific NYSED and U.S. Department of Education reporting requirements to ensure full understanding and adherence to the guidelines. Prior to submission, an internal review process will be instituted, where reports will be cross-checked to ensure accuracy and compliance. Nicole Tennant will improve documentation and maintain proper records to support all expenditure entries.

View Audit 331578

Finding 513661 (2024-002)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Subrecipient Monitoring Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonst...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

View Audit 331568

Finding 513609 (2024-006)

Significant Deficiency 2024

Cleveland State University

OH

Cash Management Procurement, Suspension & Debarment Subrecipient Monitoring

Name of the contact person responsible for corrective actions planned: Nicole Addington Chief Financial Officer Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3613 E-mail: naddington@csuohio.edu Corrective actions planned: During the audit, management reported that...

Name of the contact person responsible for corrective actions planned: Nicole Addington Chief Financial Officer Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3613 E-mail: naddington@csuohio.edu Corrective actions planned: During the audit, management reported that they had discovered that one individual violated existing University policy and misused a Purchasing Card (P-Card) resulting in unauthorized and unallowable purchase totaling $85,258. The purchases had limited supporting documentation, no management approval and a business purpose could not be validated. The individual utilizing the P-Card admitted he was using it for personal use and was terminated. Of the identified purchases $79,772 were charged to a federal grant. Subsequent to the draw down of federal funds management identified the misuse and immediately adjusted a subsequent request effectively reimbursing the federal funding source for funds received. Internal audit then performed testing over a sample of P-Card transactions and identified 51% of the transactions tested lacked supervisory review and approval. Their testingwas limited to a certain division which was considered to have risk of this occurring. RSM performed testing over the full population of P-Card transactions and identified 2 instances of monthly P-Card statements not being approved by the employee’s supervisor in a timely manner. Management will conduct a comprehensive review of current P-Card transactions, revise the training program for P-Card holders and enhance the monitoring and approval processes to prevent future misuse. Anticipated completion date: March 2025

View Audit 331516

Finding 513576 (2024-002)

Material Weakness 2024

Woodbury University

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness ...

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance Conditions: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, auditors selected a sample of 17 students who received direct loans. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Corrective Action Plan: If the student is planning to leave the University. Students must withdraw from all classes before the withdraw date. Also, the students must circulate their form to the listed departments for a signature. The issue is something this was completed by email with several forms for the same student. We will work with Redlands to create a Soft Doc/ electronic withdraw form which can be completed by the student on line. This form will be accessible to the offices listed on the form paper. Also, this will aid in the Registrar's Office and Financial Aid to have more accurate record of the students who have completed the withdraw process. Name of Contact Person: Verletta Jackson, Registrar, (818) 252-5277 Projected Completion Date: Spring 2025

View Audit 331458

Finding 513465 (2024-001)

Significant Deficiency 2024

Cooperative for Assistance and Relief Everywhere, Inc. (care)

GA

Reporting Subrecipient Monitoring § 200.170

Finding 2024-001 Reporting – Federal Funding Accountability and Transparency Act (FFATA) CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified und...

Finding 2024-001 Reporting – Federal Funding Accountability and Transparency Act (FFATA) CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on federal awards, including subaward activities, be made available to the public through a website maintained by the Office of Management and Budget (OMB). Application and Requirements FFATA applies to all US Government (USG) grants, cooperative agreements and contracts managed by CARE as the prime recipient. Under FFATA, CARE must report any subgrant greater than or equal to $30,000 and any subsequent obligation increase through the FSRS.gov website by the end of the month following the month of the subaward. Compliance Issues Identified as part of the FY2024 Audit Delays identified in the FY24 Single Audit occurred due to the departure of a Grant Manager in a country office and FFATA deadline reminder emails were sent to the grant manager with no response due to his departure. Root Causes The root causes for the delay in reporting the partner organizations (i.e., subrecipients) information with whom CARE works with is as follows: Although there are controls in place to assure FFATA reporting compliance, if there is non-responsiveness to proactive reminder emails already in place, there is no procedure for escalating the non-responsiveness. Recommended Solutions by CARE Management Team by June 30, 2025 CARE will take steps to institute a process to investigate and resolve delays in country office submission of FFATA reporting information. The control process will include an escalation procedure for country office non-responsiveness to the current proactive reminder communications. Award Management Solutions (AMS) and Shared Services Center will also introduce the following additional controls: • AMS will hold engagement sessions within 90 days with the CARE country offices and regional offices managing USG awards. The sessions will re-enforce their accountability as a key performance indicator for complying with the FFATA reporting requirements, ensuring responsiveness to Shared Services Center communications and submissions of required documentation within the regulatory timeframe. • Shared Services Center will activate set-up in CARE accounting system (PeopleSoft) of a new partner funding agreement (PFA) and partner modifications only with submission of the FFATA reporting information. • AMS to modify the PFA review and approval checklist to incorporate the FFATA information. Responsible Contact: Jason Zeno, CARE USA, AVP Grants, Contracts & Donor Compliance, email: jason.zeno@care.org

View Audit 331337

Finding 513460 (2024-001)

Significant Deficiency 2024

Middle Kentucky Community Action Partnership, Inc.

KY

Subrecipient Monitoring Reporting Significant Deficiency

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date...

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date. From this calendar an alert can and will e sent to the CFO and a designated second person to alert them as to the upcoming required date that this and other reports are to be submitted. The calendar both electronic and in written form is now in use and no further instances of this occurrence should occur within the fiscal department in the future.

View Audit 331309

Finding 513409 (2024-003)

None 2024

The Open Door Network

CA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for whi...

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for which matching funds can be used. The Organizations Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259 Questioned Costs: $1

Finding 513404 (2024-002)

None 2024

The Open Door Network

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program...

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program needs for which matching funds can be used. The Organization's Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting, and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259

Finding 513376 (2024-002)

None 2024

City of Charlotte

MI

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.318

CORRECTIVE ACTION PLAN 2024-002 – Written Policies Required by Uniform Grant Guidance Corrective Action: Institute a formal grant policy in accordance with Uniform Grant Guidance. Responsible Party: Finance Director Date to Complete By: 1-31-25

View Audit 331213

Finding 513212 (2024-001)

Significant Deficiency 2024

Southwestern Oregon Community College

OR

Subrecipient Monitoring § 200.303 § 200.332

CCDF Cluster – Assistance Listing No. 95.575, 95.596 Recommendation: We recommend the college implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Explanation of disagreement with audit finding: There is no disagreemen...

CCDF Cluster – Assistance Listing No. 95.575, 95.596 Recommendation: We recommend the college implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: College staff are drafting policy and procedures for subrecipient monitoring including a survey tool and risk assessment tool. Name(s) of the contact person(s) responsible for corrective action: Leigh FitzHenry Planned completion date for corrective action plan: March 31, 2025

View Audit 331167

Finding 513101 (2024-001)

Significant Deficiency 2024

Southwestern Law School

CA

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Te...

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Tests and Provisions - Enrollment Reporting: Significant Deficiency in Internal Control over Compliance. Responsible Offices and Individuals: Improving procedures around enrollment reporting is the joint responsibility of the Registrar's Office and the Information Office. Eileen Zwiers, Registrar, and Sean Murphy, Chief Information Officer, are responsible for implementing the corrective action plan. Corrective Action Plan: Southwestern has prepared and implemented a new Enrollment Reporting Policy to ensure Title IV compliance when reporting changes in student enrollment status to the National Student Loan Data System. The policy outlines Southwestern's procedures for timely, accurate and complete through the National Student Clearinghouse. Additionally, the Financial Aid Office will conduct monthly audits of reported submissions directly from the National Student Loan Data System portal to ensure accuracy. The Financial Aid Office documents and securely stores these verified submissions to support the federal audit, in compliance with federal retention and data management policies. Anticipated Completion Date: Southwestern took immediate action to improve the policies and procedures around enrollment reporting. The remediation was appropriately completed September 2024. Sincerely, Eileen Zwiers Registrar Sean Murphy Chief Information Officer

View Audit 331074

Finding 513088 (2024-003)

Material Weakness 2024

Village of Lexington

MI

Questioned Costs Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.319 § 200.327

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely w...

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely with USDA representatives as we have moved through the program. A budget for all costs was approved as part of the grant award. All invoices, including all engineering fees, are approved directly by our assigned Area Specialist. The project costs are currently all within budget. The Village of Lexington will ensure that engineering services follow correct procurement procedures in any future grant program it is awarded.

View Audit 331022 Questioned Costs: $1

Corrective Action Plans

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