Corrective Action Plans

Finding 516900 (2023-002)

Material Weakness 2023

Grant County

WA

Subrecipient Monitoring

The County will ensure staff receives appropriate training and tools necessary to implement controls that address the finding, specifically identifying when sub-recipient monitoring is required and making sure that it happens.

View Audit 334797

Finding 516865 (2023-001)

Significant Deficiency 2023

Bancroft Global Development

DC

Subrecipient Monitoring Reporting

Views of Responsible Official and Corrective Action Plan: We concur with the finding that we did not file a FFATA subaward report at the required time. This oversight was in part because the awarding agency did not include the reporting requirement in the award documents. When we became aware of ove...

Views of Responsible Official and Corrective Action Plan: We concur with the finding that we did not file a FFATA subaward report at the required time. This oversight was in part because the awarding agency did not include the reporting requirement in the award documents. When we became aware of oversight, we were unable to comply by submitting the report to www.USASpending.gov because the awarding agency had not fulfilled its requirement under 2 CFR 170.200 to register the award. This State Department action is a necessary precondition to meeting our FFATA reporting requirement. Going forward, we will implement policies and procedures that ensure that (1) we file timely FFATA reports for applicable subawards or, in the case such a submission is again not possible, (2) document our requests to the awarding agency to register the award thereby enabling us to comply. Name and Title of Responsible Official: Greg Joachim, Executive Director Planned Completion Date: Immediately.

View Audit 334752

Finding 516750 (2023-003)

None 2023

Holy Names University

CA

Subrecipient Monitoring

Under the University’s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the fede...

Under the University’s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify 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 assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: Employee training and management; Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University’s Information Technology system, we noted through inquiry that a formal risk assessment of the University’s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Corrective Action Planned The organization has engaged an outside IT consultant to manage the organization’s IT needs moving forward. Responsible PersonnelDouglas Burnet Chief Financial OfficerPhone: 415-425-0666 Burnet@hnu.edu

View Audit 334723

Finding 516739 (2023-003)

Material Weakness 2023

Hocking County

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The Auditor’s Office will work alongside the Commissioner’s Office to check vendors at the beginning of the year and recurring vendors will be checked.

View Audit 334701

Finding 516666 (2023-001)

Significant Deficiency 2023

Philip Health Services, Inc.

SD

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

RE: Audit Finding Corrective Action Plan Philip Health Services recognizes the need for an account to be designated for the loan reserve of $210,564. We will designate a CD in the CDARS Accounts in the amount of $250,000 that is insured by FDIC with a term of 2 years. When this CD is renewed, ...

RE: Audit Finding Corrective Action Plan Philip Health Services recognizes the need for an account to be designated for the loan reserve of $210,564. We will designate a CD in the CDARS Accounts in the amount of $250,000 that is insured by FDIC with a term of 2 years. When this CD is renewed, it will continue to be reserved until the loan reaches an amount that will no longer require the designation. Respectfully, Maureen Cadwell Chief Executive Officer Philip Health Services, Inc.

View Audit 334657

Finding 516584 (2023-001)

Material Weakness 2023

Digital Harbor Foundation INC

MD

Subrecipient Monitoring § 200.331

MATERIAL WEAKNESS 2023-001 Documentation of Subawards Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU). Action Taken: • As a First Year Single Auditee, the management team will ensure that senior l...

MATERIAL WEAKNESS 2023-001 Documentation of Subawards Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU). Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings no later than December 31st, 2024. • As a First Year Single Auditee, the management team will ensure that specific policies for sub-awards and sub-recipients will better ensure its internal practices are in alignment with Uniform Guidance standards for federal awards no later than December 31st, 2024. • As a First Year Single Auditee, the management team will have an independent audit firm review these specific policies to ensure they are in alignment and conformance with Uniform Guidance standards no later than December 31st, 2024.

View Audit 334550

Finding 516482 (2023-001)

Material Weakness 2023

Wahkiakum County

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The County did not have adequate controls for ensuring compliance with federal requirements for allowable activities and costs. Name, address, and telephone of County contact person: Tammy Peterson, PO Box 85, 360-795-8005 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). A request was made to the payroll department for a report for the Sheriff’s office for the August payroll. I meant the July time issued on August 5th. The report I received was for August time with a September 5th pay date. This was a misunderstanding and not an intentional oversight. In the future, we will ensure that the report dates match the payroll we are requesting. Anticipated date to complete the corrective action: September 13, 2024

View Audit 334391 Questioned Costs: $1

Finding 516480 (2023-002)

Material Weakness 2023

Wahkiakum County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-002 Finding caption: The County did not have adequate controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of County contact person: Chuck Beyer, PO Box 97, 360-795-3301 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Process Checklist has been completed and is in the Prosecuting Attorney’s office for review. We have written into the Process Checklist to maintain the documentation required when obtaining Professional Bids. Anticipated date to complete the corrective action: September 30, 2024

View Audit 334391

Finding 516473 (2023-010)

Material Weakness 2023

Academy of America

MI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness § 200.501 § 200.512 § 200.514

View of Responsible Officials and Corrective Action Plan – The Academies will develop a reliable system that will lead to the timely processing of the financial records by reviewing existing procedures to identify bottlenecks and areas of improvement. Feedback will be gathered from team members invo...

View of Responsible Officials and Corrective Action Plan – The Academies will develop a reliable system that will lead to the timely processing of the financial records by reviewing existing procedures to identify bottlenecks and areas of improvement. Feedback will be gathered from team members involved in the financial record keeping process so that standard procedures can be development and implemented. Furthermore, opportunities to automate processes and use software to assist with data entry, record reconciliation, and reporting can be used. This will significantly decrease manual workload and improve accuracy and timeliness.

View Audit 334382

Finding 516472 (2023-009)

Material Weakness 2023

Academy of America

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

View of Responsible Officials and Corrective Action Plan – Management will monitor the review and approval procedures for reporting to ensure that reports are signed off to indicated and document that review and approval has been made.

View Audit 334382

Finding 516326 (2023-003)

Significant Deficiency 2023

All Nations Health Center, Inc.

MT

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

The Business and Finance Department at ANHC has mandated, from all departments at ANHC, an approval form for all “Autopay” transactions to be signed by the ED immediately.

View Audit 334164

Finding 516325 (2023-002)

Material Weakness 2023

All Nations Health Center, Inc.

MT

Subrecipient Monitoring Eligibility Material Weakness

All Nations Health Center has switched EHR systems that allows for intake coordinators to suspend/pause eligibility status until all proper documentation has been obtain from the client, scanned into the system, and filed appropriately.

View Audit 334164

Finding 516134 (2023-002)

Material Weakness 2023

Kalama School District

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District No. 402 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Fed...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District No. 402 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: James Capen Director of Business Services 360-673-5282 Corrective action the auditee plans to take in response to the finding: The Kalama School District has taken the following steps to ensure that we are currently in compliance, and will continue to stay in compliance, with the Davis-Bacon Act; 1. All new contractors and existing contractors covered by the Davis-Bacon Act will submit certification attesting to compliance of prevailing wage requirements. 2. District staff will review the State Labor and Industries prevailing wage and certification website on a weekly basis when work is performed or collect a certified payroll record from the contractor on a weekly basis. 3. All new staff that have purchasing or financial oversight will be trained on these procedures when hired and on an ongoing basis. Anticipated date to complete the corrective action: 7-26-24

View Audit 333974

Finding 516078 (2023-001)

Significant Deficiency 2023

Chesapeake Hospital Authority

VA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.512

2023-001 – Reporting – Submission of the Data Collection Form Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 Management acknowledges that the reporting package and dat...

2023-001 – Reporting – Submission of the Data Collection Form Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 Management acknowledges that the reporting package and data collection form for the year ended June 30, 2023, was not filed with the Federal Audit Clearinghouse on or before the deadline of March 31, 2024. Management maintains that appropriate schedules and notes thereto were prepared accurately and timely, and that the delay was due primarily to the unique nature of Provider Relief Funds being reported, which resulted in evolving compliance requirements over the funding and reporting periods. Management will file the reporting package and data collection form immediately upon completion and will continue to monitor and adhere to future Federal compliance updates to prevent such delays in the future.

View Audit 333892

Finding 515975 (2023-004)

Significant Deficiency 2023

The National Judicial College

NV

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.213

Personnel changes, including the introduction and the departure of a new Director of Grants, led to a vulnerability in the debarment step of the processes for contracting with consultants under federal grants in isolated circumstances. In this particular instance, a long-term consultant entered into...

Personnel changes, including the introduction and the departure of a new Director of Grants, led to a vulnerability in the debarment step of the processes for contracting with consultants under federal grants in isolated circumstances. In this particular instance, a long-term consultant entered into a new contract with the College while an existing contract for related activities was outstanding. The College will formalize a policy requiring that all new contracts under federal grants, even for previously established contractors, be reviewed and processed according to the updated procedures. Patrick Grimes is the individual responsible for oversight of this corrective action plan.

View Audit 333783

Finding 515705 (2003-001)

Significant Deficiency 2023

Biostl

MO

Subrecipient Monitoring Reporting Significant Deficiency

Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Taylor McCabe, Director of Grants Management, and Finance Lead, Tia Newcom Anticipated Completion Date: Expected completion by December 31, 2024Corrective Action Plan: The audit identified that FFATA (Federal F...

Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Taylor McCabe, Director of Grants Management, and Finance Lead, Tia Newcom Anticipated Completion Date: Expected completion by December 31, 2024Corrective Action Plan: The audit identified that FFATA (Federal Funding Accountability and Transparency Act) subaward reports were not submitted properly or on time for first-tier subawards of $30,000 or more. The deficiency was attributed to a lack of awareness of this requirement and the absence of specific internal controls to ensure timely reporting to the Federal Subaward Reporting System (FSRS). To address this finding and establish compliance with 2 CFR Part 170, BioSTL has implemented additional measures and expanded policies and procedures to ensure timely reporting to the FSRS. To ensure the highest compliance, BioSTL has incorporated the standard federal FFATA form as an exhibit within the subawardee contracts, ensuring timely collection of necessary data. This incorporation not only enables the direct gathering of general information within the contract but also includes the requirement for subawardees to complete and sign the standard FFATA form. This approach is paired with additional training and education for both BioSTL’s Grant Management personnel, Program Directors, and the leadership team within subawardee organizations, ensuring that all parties are fully aware of the initial and any ongoing reporting requirements. Through the formalized contractual process, BioSTL has implemented enhanced internal controls by requiring supervisory review and approval at multiple levels. Submitted FFATA documentation will undergo review by the Program Director managing the grant, the Director of Grants Management, and the Vice President of Development, ensuring thorough oversight and compliance at each step. To support this process, BioSTL has implemented an Airtable-based compliance reminder system to automate notifications related to FFATA form submissions. Automated reminders will be sent to both pass-through partners and relevant program staff, reminding them to complete the annual FFATA form submission. Notifications will be issued on September 1st as a 30-day advance notice and again on September 15th, with a final submission deadline to BioSTL set for September 30th of each year. These reminders ensure proactive follow-up and help maintain annual compliance. BioSTL will also ensure that both Program Directors and the Grants Department thoroughly review all submitted FFATA documents, reinforcing accuracy and adherence to reporting timelines.

View Audit 333569

Finding 515573 (2023-008)

Significant Deficiency 2023

Unity Health Care, Inc.

MD

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Management Response #2023-008: Due to staff turnover, the Corporation did not consistently enforce segregation of duties between the individual responsible for determining income eligibility and the one completing the medical risk assessment. The Corporation also failed to provide sufficient support...

Management Response #2023-008: Due to staff turnover, the Corporation did not consistently enforce segregation of duties between the individual responsible for determining income eligibility and the one completing the medical risk assessment. The Corporation also failed to provide sufficient support to verify that the applicant signed the Rights and Obligations statement. Corrective Action Plan: • All eligibility verification data, including screenshots and signed Rights and Obligations statements, will be stored in a centralized, secure shared drive maintained and managed by the WIC Director to ensure it is protected with limited access and password protection. The drive will be organized using a de-identified naming convention to ensure privacy while maintaining ease of access for authorized staff. • To maintain a robust system of checks and balances, tasks related to eligibility verification and documentation will be divided among different team members. This separation will prevent any one individual from having full control over the process, reducing the risk of oversight or potential errors. • The WIC Department’s policy and procedure manuals will be revised and updated to include the new eligibility verification process. • To ensure adherence to the new protocols, periodic audits and review sessions will be conducted by the WIC Director or designated compliance staff to verify that documentation is being properly maintained and that all procedures are followed. Staff will be required to undergo refresher training sessions as needed to reinforce the updated protocols and best practices. Responsible Party: Tracy Harrison, COO

View Audit 333283

Finding 515487 (2023-120)

Significant Deficiency 2023

State of Arizona

AZ

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid

Assistance listing number and program name: 93.658 Foster Care—Title IV-E 93.658 COVID-19 - Foster Care—Title IV-E Agency: Arizona Department of Child Safety (DCS) Name of contact person and title: Emilio Gonzales, DCS Audit Administrator Anticipated completion date: Fiscal Year 2025 Agency’s Respo...

Assistance listing number and program name: 93.658 Foster Care—Title IV-E 93.658 COVID-19 - Foster Care—Title IV-E Agency: Arizona Department of Child Safety (DCS) Name of contact person and title: Emilio Gonzales, DCS Audit Administrator Anticipated completion date: Fiscal Year 2025 Agency’s Response: Concur The Department will comply with the Federal Funding Accountability and Transparency Act (FFATA) and Federal Uniform Guidance regulations in accordance with the Department’s Grant policies and procedures. As of November 2024, the Department worked with the federal agency to resolve the inability to submit outstanding subaward information prior to January 2024. The FFATA reporting was completed for fiscal years 2024, 2023, 2022 and 2021. The Department will also continue to follow its policies and procedures for reporting subaward actions, as required.

View Audit 333243

Finding 515480 (2023-121)

Material Weakness 2023

State of Arizona

AZ

Reporting Subrecipient Monitoring

Assistance listing number and program name: 93.268 Immunization Cooperative Agreements 93.268 COVID-19 - Immunization Cooperative Agreements 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323 COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ...

Assistance listing number and program name: 93.268 Immunization Cooperative Agreements 93.268 COVID-19 - Immunization Cooperative Agreements 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323 COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Agency: Arizona Department of Health Services (ADHS) Name of contact person and title: Lora Andrikopoulos, ADHS Grants Administrator Anticipated completion date: June 30, 2025 Agency’s Response: Concur ADHS will continue to work with the CQI Team, Financial Services - Assurance Team, Procurement, Finance Managers, Other internal partners, and Grants to update the process of FFATA. The process moving forward will include a communication plan, updates to the current standard work, the creation of new standard work if necessary for the subaward communication process, and additional training.

View Audit 333243

Finding 515447 (2023-112)

Material Weakness 2023

State of Arizona

AZ

Subrecipient Monitoring Matching / Level of Effort / Earmarking Reporting

Assistance listing numbers and program names: 93.575 Child Care and Development Block Grant 93.575 COVID-19 - Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund 93.596 COVID-19 - Child Care Mandatory and Matching Funds of the ...

Assistance listing numbers and program names: 93.575 Child Care and Development Block Grant 93.575 COVID-19 - Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund 93.596 COVID-19 - Child Care Mandatory and Matching Funds of the Child Care and Development Fund Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Martha Franquemont, DES Business Administrator Anticipated completion date: June 30, 2025 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department will immediately report the required missing information for its subawards on the FFATA Subaward Reporting System for this cluster. The Department will also follow the State’s accounting manual for reporting subaward actions equaling or exceeding $30,000 no later than month-end of the month following the subaward action. In addition, the Department will redirect and train existing resources to ensure FFATA reports are compiled, reviewed, and submitted timely.

View Audit 333243

Finding 515446 (2023-111)

Significant Deficiency 2023

State of Arizona

AZ

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring

Assistance listing numbers and program names: 93.575 Child Care and Development Block Grant 93.575 COVID-19 - Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund 93.596 COVID-19 - Child Care Mandatory and Matching Funds of the...

Assistance listing numbers and program names: 93.575 Child Care and Development Block Grant 93.575 COVID-19 - Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund 93.596 COVID-19 - Child Care Mandatory and Matching Funds of the Child Care and Development Fund Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Traci Lira, DES Strategic Operations Coordinator Anticipated completion date: September 1, 2024 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department has revised its policies and procedures to ensure a signed receipt is captured for all Payment Disbursed Quickly (PDQ) submitted billings. In addition, the Department will retain all records related to a federal award for a period of 3 years from the final expenditure report submission date. These policies and procedures were implemented effective September 1, 2024.

View Audit 333243

Finding 515367 (2023-104)

Significant Deficiency 2023

State of Arizona

AZ

Subrecipient Monitoring Reporting § 200.303

Assistance listing number and program name: 84.425C COVID-19 - Education Stabilization Fund –Governor’s Emergency Education Relief (GEER) Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Name of contact person and title: Sarah Brown, Director Anticipated completion...

Assistance listing number and program name: 84.425C COVID-19 - Education Stabilization Fund –Governor’s Emergency Education Relief (GEER) Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Name of contact person and title: Sarah Brown, Director Anticipated completion date: May 1, 2025 Agency’s response: Concur Corrective Action Plan: The Office agrees with this finding and will begin to take corrective action to bring the program fully into compliance with FFATA reporting requirements under federal and state guidelines. The Office previously reported staff turnover for key personnel directly responsible for preparing, submitting, and reviewing FFATA reporting (i.e., 100 percent turnover). After reviewing supporting documentation and consulting with the U.S. Department of Education, the Office has determined that staff misinterpreted the reporting guidance. The Office understood the reporting did not require submissions on subawards made by another state agency. The Office did report the awards made to that respective state agency but did not include the agency subawards. The Office is working with the state agency to collect subaward data required for accurate reporting. During fiscal year 2025, the Office took significant corrective action to improve FFATA reporting. This corrective action plan includes the following: • FFATA Reporting Reconciliation—The Office will review, correct, and/or resubmit any inaccurately reported information, including subawards. • Annual Performance Reporting (APR) Reconciliation—The Office is unable to amend and resubmit the fiscal year 2022 APR per guidance from the U.S. Department of Education - Education Stabilization Fund Reporting Helpdesk. The reporting portal is unable to accept any revisions for fiscal year 2022. The Office will review any current reporting and ensure subaward data is included. • Update Written Procedures—The Office will update its written procedures to incorporate a process for reviewing federal guidance on a schedule aligned with federal reporting windows as applicable. • Ongoing Training—Office staff now attend ongoing internal and external training to improve their understanding of compliance requirements, identify noncompliance, and actively reduce the risks of reporting errors. As of this date, the Office has allocated sufficient resources to comply with the award terms and program requirements by establishing a Grants Compliance and Reporting Team dedicated to performing necessary FFATA reporting procedures. The Office is committed to ongoing staff training, improved internal reporting processes, and ensuring the State’s stakeholders and the public have access to transparent and timely information about all federal award spending decisions on the USAspending.gov website as federal laws and regulations require.

View Audit 333243

Finding 515348 (2023-126)

Material Weakness 2023

State of Arizona

AZ

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Assistance listing number and program name: 84.010 Title I Grants to Local Educational Agencies 84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 84.425D COVID-19 - Education Stabilization Fund-Elementary and Secondary School Emergency Relief (ESS...

Assistance listing number and program name: 84.010 Title I Grants to Local Educational Agencies 84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 84.425D COVID-19 - Education Stabilization Fund-Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425U COVID-19 - Education Stabilization Fund - American Rescue Plan - Elementary and Secondary Schools Emergency Relief (ARP ESSER) Fund Agency: Arizona Department of Education (ADE) Name of contact persons and titles: Nicole Von Prisk, ADE Deputy Associate Superintendent of Grants Management Matt McClary, ADE Compliance Officer Anticipated completion date: October 30, 2024 Agency’s response: Concur Arizona Department of Education has worked in cooperation with our vendor to correct outdated SQL queries that were identified and returning only approved grant award amounts rather than all awarded amounts, regardless of approval status. We will ensure that the original award amounts are being queried and, in return, reported within the FFATA Subaward Reporting System (FSRS). Additionally, through the reconciliation process each month, correct award amounts will align with corresponding Federal Award Identification Number (FAIN). We have implemented an automated monthly reporting workflow/schedule which will help ensure required FFATA reporting is submitted timely. This process automation helps prompt monthly FFATA reporting uploads by leveraging office tools that are readily available and ensures monthly upload deadlines are met by automatically scheduling the task and requiring follow-up by the assignee. In January of 2024 the staff assigned to FFATA uploads changed again (for the fourth time in a year) and at that point a new staff member assumed responsibility for FFATA uploads. As numerous corrections needed were discovered through the reconciliation process, new reports were uploaded. Some of these were original uploads for entities that were missing FSRS information altogether and some were corrections to previously uploaded yet incorrect information. With each monthly upload, a new date was being captured and while some of the information was new entity award information, not all of the information being updated was untimely. This has been a long and arduous process, and we look forward to not having continued FFATA findings, as we are making progress to correcting award information for all federal grants moving forward from this point. Our Compliance Officer reconciles the current FSRS award information monthly with our Lead Grants Coordinator or our Deputy Associate Superintendent. Any missing or duplicate information is corrected prior to the FSRS upload.

View Audit 333243

Finding 515347 (2023-125)

Material Weakness 2023

State of Arizona

AZ

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.332 § 200.513 § 200.521

Assistance listing numbers and program names: 84.010 Title I Grants to Local Educational Agencies 84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Agency: Arizona Department of Education (ADE) Name of contact person and title: Dr. Sarka White, AD...

Assistance listing numbers and program names: 84.010 Title I Grants to Local Educational Agencies 84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Agency: Arizona Department of Education (ADE) Name of contact person and title: Dr. Sarka White, ADE Deputy Associate Superintendent Anticipated completion date: December 15, 2024 Agency’s response: Concur The Arizona Department of Education (ADE) has already begun implementing a program to ensure accurate and quality programmatic monitoring for all ESEA programs which specifically requires LEAs to meet 100% of the requirements of all statutorily required items to be monitored regardless of CMO affiliation. This development of programmatic monitoring will design a system of integrity to allow each LEA to have unique monitoring findings and ensure they are treated as all other LEAs regardless of management status. The Arizona Department of Education (ADE) is finalizing all program policies and procedures along with field training and staff training on how this program is implemented. ADE began providing an assurance document to charters in May 2024 which asks the charters to assure that if they do business with a CMO, the CMO does not have fiscal or operational authority for the LEA. The charter is asked to submit to ADE a copy of their organizational chart, along with the assurances document. Grants Management has created a new user role in the Grants Management Enterprise (GME) system, called the LEA Contracted Update role. This role allows a CMO person the access to perform fiscal tasks for which they have been contracted but does not hold the final submit or approve capacity, that must be reserved for authorized employees of the LEA. Grants Management has provided the placeholder for the assurance and organizational chart in the LEA Document Library, along with the communication to eligible entities (charters in this case). Individual program areas within ADE who review and approve funding applications will be responsible for verifying the assurances have been signed and uploaded and only authorized people at the LEA are actioning funding applications in GME prior to the program area giving director approval to the application.

View Audit 333243 Questioned Costs: $1

Finding 515346 (2023-124)

Material Weakness 2023

State of Arizona

AZ

Subrecipient Monitoring Eligibility Period of Performance § 200.303

Assistance listing number and program name: 84.010 Title I Grants to Local Educational Agencies Agency: Arizona Department of Education (ADE) Name of contact person and title: Tim McCain, ADE Chief Financial Officer Chris Brown, ADE Business Officer of Education Programs Anticipated completion date:...

Assistance listing number and program name: 84.010 Title I Grants to Local Educational Agencies Agency: Arizona Department of Education (ADE) Name of contact person and title: Tim McCain, ADE Chief Financial Officer Chris Brown, ADE Business Officer of Education Programs Anticipated completion date: January 2025 Agency’s response: Concur • ADE is working on standardizing fiscal efficiency by adopting uniform guidelines that monitor obligations and expenditures. These guidelines outline available resources and determine allocation amounts within federal awards and earmark expiration dates within programs. • ADE is also working on standardizing how funds may be reallocated to ensure that no funds are at risk of reverting to USED. Specifically, school improvement funds are now also tracked as part of Title I allocation and reallocation process. This will ensure funds are earmarked and obligated in a timely fashion (i.e., in the period of performance). This item is planned to be completed by January 2025.

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