Corrective Action Plans

Finding 522454 (2024-002)

Significant Deficiency 2024

PA

Allowable Costs / Cost Principles Subrecipient Monitoring

#2024-002 – Allowable Costs/Cost Principles – Time and Effort Certifications Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be review...

#2024-002 – Allowable Costs/Cost Principles – Time and Effort Certifications Corrective Action Planned: The District has reviewed and revised its controls to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records will also be reviewed, approved, and maintained by administrative personnel. A written plan has been developed to guide the process. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year. Contact Person Responsible: Cory Hoffman, Business Manager/Board Secretary If the Department of Education has questions regarding this plan, please contact Cory Hoffman, Business Manager/Board Secretary. Sincerely, Cory Hoffman Business Manager/Board Secretary

View Audit 341731

Finding 522420 (2024-001)

None 2024

Food for Kids, Inc.

TX

Subrecipient Monitoring Cash Management Significant Deficiency

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Oper...

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Operation will make monitoring visit assignments for the month. Step 2: Each Compliance Officer is to submit the monitoring form to the Director of Operation no later than the last day of the month the visit was due to be performed. Step 3: The Director of Operation will follow up with each Compliance Officer to ensure forms were received, review the form, and enter the date the visit was completed into the data base to ensure visits are made as TDA requires. Step 4: The Executive Director will review the final report of all visits conducted for the month to sensure forms are accounted for. Step 5: The Director of Operation and the Office Clerk will perform random binder checks to see if forms are filed correctly. Step 6: The Director of Operation will oversee the labiling and thinning process of forms and binders before sending boxes to storage. This will ensure stored files can be easily located. The Executive Director has final responsibility for the implementation and maintenance of this procedure.

View Audit 341706

Finding 522409 (2024-001)

Significant Deficiency 2024

Atlantic States Marne Fisheries Commission

VA

Subrecipient Monitoring § 200.332

Funding Agency: Department of Commerce Assistance Listing Number: 11.469, 11.472 Finding: Reporting - The Commission did not provide timely Federal Funding Accountability and Transparency Act (FFATA) reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Correct...

Funding Agency: Department of Commerce Assistance Listing Number: 11.469, 11.472 Finding: Reporting - The Commission did not provide timely Federal Funding Accountability and Transparency Act (FFATA) reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Corrective Action Plan: The Commission agrees with the finding. The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024

View Audit 341683

Finding 522370 (2024-002)

Material Weakness 2024

Catholic Charities Maine

NH

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.329

Corrective Action Plan Response to Finding 2024-001 and Finding 2024-002: Management agrees with the recommendations and will implement the following changes: 1. On a monthly basis the Controller will review and approve all financial reporting submitted to programs to allow finance department t...

Corrective Action Plan Response to Finding 2024-001 and Finding 2024-002: Management agrees with the recommendations and will implement the following changes: 1. On a monthly basis the Controller will review and approve all financial reporting submitted to programs to allow finance department to capture and record missing information. This will be implemented by January 31, 2025. 2. A member of the finance department will participate in the sub-recipient monitoring to provide the monitoring team with oversight and ensure compliance with accounting best practices. This will be implemented by February 28, 2025. 3. The “Budgeting, Contracts, and Grants Manager” within the OMRS program will be responsible for notifying the Chief Financial Officer of any non-compliance from Sub-recipient grants and agreements within ten business days. This will be implemented by January 31, 2025. 4. The two sub-recipients with late invoicing will be issued corrective actions plans by Office of Maine Refugee Services for timely submittal of financial reports and invoicing. This will be completed by January 31, 2025. Estimated completion date for all items above: February 28, 2025 Responsible party: Reed L. Westgate, Chief Financial Officer

View Audit 341646

Finding 522361 (2024-002)

None 2024

Community Services and Employment Training, Inc.

CA

Subrecipient Monitoring Reporting

Management's Response/Planned Corrective Action: Management acknowledges the finding and accepts the recommendation. Management is committed to reporting accurate data and has implemented steps to support validation. Lola Balandran/Assistant Director for the Expanded Subsidized Employment Program wi...

Management's Response/Planned Corrective Action: Management acknowledges the finding and accepts the recommendation. Management is committed to reporting accurate data and has implemented steps to support validation. Lola Balandran/Assistant Director for the Expanded Subsidized Employment Program will provide staff training on the importance of entering data accurately and will use a checklist to ensure key data points are captured accurately. The Assistant Director for the ESE Program and Marlene Acosta/Sr. Program Coordinator will monitor staff data entry activities for accuracy, ensuring alignment with activities and calculation of participation hours. The Expanded Subsidized Employment Program will complete a two-phase validation process, where both the first and second reviewers will validate the report before it is submitted to the funding source. This process will reduce or eliminate data entry errors and confirm hours of participation are accurately calculated. The documentation compiled (for that point intime) will be used and saved as the underlying data that supports the outcomes. CSET's Compliance Director will review reports quarterly to ensure compliance with reporting requirements. On November 14, 2024, CSET began implementing the above-outlined corrective action plan.

View Audit 341640

Finding 522353 (2024-002)

Significant Deficiency 2024

Catskill Central School District

NY

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

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84....

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84.425D) ARP Summer Enrichment (Assistance Listing# 84.425U) ARP Comprehensive After School (Assistance Listing# 84.425U) ARP ESSER III (Assistance Listing# 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria - Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. ( d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context - We haphazardly sampled five COVID-19 - Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor's review prior to payment. Cause - Management override of established controls. Effect - Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs - None. The improper payment was subsequently adjusted out of expenditures. Recommendation - We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action - The Business Office will review and adhere to all cash disbursements procedures and protocols. Completion Date - Effective immediately. Respectfully Submitted, Dr. Brett Miller, Assistant Supt. for Business

View Audit 341608

Finding 522347 (2024-004)

Significant Deficiency 2024

Region One Education Service Center

TX

Subrecipient Monitoring § 200.332

2024-004 Subaward Agreements The Center is the recipient of GEAR UP awards based on prior grant applications submitted with its related program partners which include local educational agencies and other partners. While the audit revealed that no formal agreement was in place during the audit year, ...

2024-004 Subaward Agreements The Center is the recipient of GEAR UP awards based on prior grant applications submitted with its related program partners which include local educational agencies and other partners. While the audit revealed that no formal agreement was in place during the audit year, the Center did have documentation in place with each partner that included a detailed budget, program operating procedures manual, partner commitment form signed by each partner’s superintendent of schools, program monthly meetings, onsite visits, and other activities stipulated in the grant. A new program requirement was published on August 29, 2024, as amended in 34 CFR 75.127 through 75.129 for future Partnership Grants Application and includes language related to a binding agreement. The Center will ensure all future grant applications comply with this new requirement. Proposed Completion Date: February 1, 2025 Name of contact person: Rumalda Ruiz, Deputy Director - Business, Operations, & School Finance Support Contact: (956) 984-6290

View Audit 341604

Finding 522344 (2024-003)

Significant Deficiency 2024

Region One Education Service Center

TX

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

2024-003 Matching The GEAR UP program will update its review and approval process for in-kind documentation submitted by partners to ensure correct and accurate data is submitted in the annual grant close out process which includes the Annual Performance Report (APR) due to USDE in April 2025. Hourl...

2024-003 Matching The GEAR UP program will update its review and approval process for in-kind documentation submitted by partners to ensure correct and accurate data is submitted in the annual grant close out process which includes the Annual Performance Report (APR) due to USDE in April 2025. Hourly values for teachers and other professionals will be updated on an annual basis. The identified rate has been adjusted to ensure the correct rate is used during final submission of in-kind data for teacher hours in the APR. Proposed Completion Date: April 1, 2025 Name of contact person: Rumalda Ruiz, Deputy Director – Business, Operations, & School Finance Support Contact: (956) 984-6290

View Audit 341604

Finding 522305 (2024-002)

Significant Deficiency 2024

School District of the City of Hazel Park

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

See Corrective Action Plan for Chart/Table

View Audit 341580

Finding 522298 (2024-003)

Significant Deficiency 2024

New Mexico Human Services Department

NM

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment

2024-003 Reporting (original finding 2021-001) (Significant Deficiency in Internal Controls over Compliance) What Action(s) Will be Done: ASD staff form the Contracts and Procurement and Grant Management Bureau will work together to monitor any new activity that will need to be reported on the Feder...

2024-003 Reporting (original finding 2021-001) (Significant Deficiency in Internal Controls over Compliance) What Action(s) Will be Done: ASD staff form the Contracts and Procurement and Grant Management Bureau will work together to monitor any new activity that will need to be reported on the Federal Funding Accountability and Transparency Act (FFATA). ASD established and implemented a new contract/agreement system called Bonfire in January 2024. This system is an automated system that includes all the information that was entered on the Contract Request Form (CRF) that was previously used in the Contracts and Procurement Bureau and a copy of the proposed contract/agreement. Now, there is a specific field that can be used to track if any new contact/agreement must be reported on the FFATA. These contracts/agreements are reviewed and pre-approved in Bonfire by many HSD staff which include the Contract and Procurement Bureau Chief and the ASD Director/CFO. We can monitor the FFATA field as we review and provide information to the Grants Management Bureau Chief in real time. We can also run monthly reports to review and track this field to ensure that any new contracts/agreements were not missed to ensure timely FFATA reporting. Who Will Act: Grants Bureau Chief & Contracts and Procurement Bureau Chief When Will Action(s) be Completed: ASD will ensure that a FFATA sub-award report is submitted by the of the month following the month in which HSD awards any sub-grants greater than or equal to $30,000.

View Audit 341573

Finding 522263 (2024-003)

Material Weakness 2024

Hall County Housing Authority

NE

Subrecipient Monitoring Eligibility HUD Housing Programs

Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper do...

Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper documents are retained in the tenant files. Finding 2024-002 Management will familiarize themselves with the requirements and guidelines of their ACOP to better ensure that the Authority is operating and maintaining its policies. Finding 2024-003 See Finding 2024-001.

View Audit 341542

Finding 522229 (2024-001)

Material Weakness 2024

The Halifax - Warren Smart Start Partnership for Children, Inc.

NC

Questioned Costs Eligibility Subrecipient Monitoring

Going forward, all initial rosters submitted to HWSS will be reviewed by at least two different HWSS staff and compared to eligibility results to verify eligibility prior to entering rosters into NCPK KIDS. Any changes to a roster during the year will also be verified by at least two HWSS staff.

View Audit 341479 Questioned Costs: $1

Finding 522215 (2024-003)

Significant Deficiency 2024

Lee County

NC

Subrecipient Monitoring Eligibility Reporting

Finding 2024-001 Name of contact person: Corrective Action: Proposed completion date: Finding 2024-002 Name of contact person: Corrective Action: Proposed completion date: Finding 2024-003 Inaccurate Information Entry Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Acti...

Finding 2024-001 Name of contact person: Corrective Action: Proposed completion date: Finding 2024-002 Name of contact person: Corrective Action: Proposed completion date: Finding 2024-003 Inaccurate Information Entry Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Action: Proposed completion date: 10/9/2024 6/30/2025 Section III - Federal Award Findings and Questioned Costs Training has been conducted on the Inaccurate Information Entry topic with staff specifically concerning the finding areas and ensuring all verified information is appropriately updated in the NC FAST evidence. Second party reviews will be enhanced to ensure those conducting the review verify that proper procedures are being followed with regard to these policies. Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings 6/30/2025 Candace Iceman, Finance Director Budget amendments will be prepared to properly account for lease and subscription principal payments and required reporting. In addition, the budget will be closely monitored going forward to ensure budget availability. Candace Iceman, Finance Director A full review of the existing lease and subscription agreements will be done to ensure accurate data is being tracked and terminations are being removed from all reporting schedules in a timely manner. Additionally, any existing agreements that have a change of terms will be terminated instead of modified to provide accurate and transparent information. Reviews of these documents will be conducted quarterly to make timely adjustments and corrections. 169

View Audit 341449

Finding 522208 (2024-001)

Significant Deficiency 2024

Hibiscus Childrens Center, Inc.

FL

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

Staff at Hibiscus Children's Center are required to complete training curriculums on an annual basis. All Full-Time staff that work directly with children, supervisors and directors must complete a minimum of 40 hours of training annually. All Part-Time staff that work directly with children must ...

Staff at Hibiscus Children's Center are required to complete training curriculums on an annual basis. All Full-Time staff that work directly with children, supervisors and directors must complete a minimum of 40 hours of training annually. All Part-Time staff that work directly with children must complete a minimum of 20 hours of training annually. Program Directors and Supervisors are responsible to monitor their staff to ensure that they successfully complete their annual training requirements. The Program Directors will compile information for each of their staff that identifies the required training, and the dates that they successfully completed each training session. The Program Directors will be responsible for collecting the training certificates and submitting them to Human Resources so they can be placed in the individual personnel files. To better manage the completion and tracking of the required trainings, staff will be required to complete their designated training requirements during the period of July 1 to December 31st. This will allow for the trainings to be logged in time for our annual re-licensing and audits. If the staff do not meet the required training hours, and/or do not meet the required time frame, the Program Directors will take necessary action to ensure compliance and appropriate disciplinary measures.

View Audit 341419

Finding 522144 (2024-003)

Significant Deficiency 2024

United Way of Greater Cleveland

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.329

UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Management’s Corrective Action Plan: UWGC has developed a procedure as outlined below in “Payroll Allocation Grants”...

UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Management’s Corrective Action Plan: UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce.

View Audit 341351

Finding 522142 (2024-002)

Significant Deficiency 2024

United Way of Greater Cleveland

OH

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.403

2024-002 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged to federal programs. Management’s Corrective Action Plan:UWGC has develope...

2024-002 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged to federal programs. Management’s Corrective Action Plan:UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce. PROCEDURE: Payroll Allocation Grants Purpose UWGC requires the practice of responsible and reasonable procedures related to methods of allocated staff time and costs to 211 grants and/or contract funded initiatives/programs which is effective as of April 15, 2024. This procedure describes the steps that will be implemented and adhered to when allocating staff salary costs to 211 programs. The goal of this process is to ensure that consistent, adequately documented, and all appropriate materials are generated and reviewed monthly. Procedure 211 Call Logs: at the end of each month the 211 Manager will generate a monthly call log which tracks 211 calls by categories that coincide with specific programs and/or geographic area for services. The report is then emailed monthly to the Finance Senior Director who then utilizes the report to create a percentage of time spent on each program and then attributes staff salaries and benefits in line with the percentage of calls for each month. Staff who work on isolated call programs, for example 311, Utilities,OHIZ programs, will be excluded from the call log allocation method as the calls for these teams are specifically driven. Supervisors who oversee more than one program will perform a time allocation study at least annually or when there is a change in program supervision responsibility. Program Billing: The Finance Manager and/or responsible Program Billing Manager will utilize the call log percentages journal to allocate time to programs for reporting information in the appropriate monthly, quarterly, or annual report to the funding source.

View Audit 341351

Finding 522136 (2024-001)

Significant Deficiency 2024

Jewish Federation of Metropolitan Chicago

IL

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305

Identifying Number: 2024-001 Condition: Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Corrective Actions Taken or Planned: Federatio...

Identifying Number: 2024-001 Condition: Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Corrective Actions Taken or Planned: Federation typically receives vouchers from 14 subrecipient organizations approximately ten days after the end of each month. The number of vouchers per agency depends on the number of programs they provide. Staff reviews the vouchers for allowability and accuracy and submits them to the Illinois Department of Human Services (IDHS) within 24 days of month end. During fiscal year 2024, the IDHS remitted payment to Federation anywhere from 48 to 124 days after the month end. Upon receipt of the cash, Federation pays subrecipient organizations within thirty days. In the instances identified by the auditors, the IDHS remitted payment over 30 days after Federation submitted the vouchers for reimbursement. Federation’s longstanding policy has always been to reimburse each subrecipient agency after it has received payment from the IDHS. Prior to fiscal year 2024, the IDHS usually provided payment within 15 days of receipt of our voucher and therefore Federation was able to comply with the 30-day requirement. However, reimbursement delays from IDHS occurred during fiscal year 2024 resulting in the findings describe herein. To ensure compliance with the 30-day reimbursement requirement, Federation will formally request an advance from the IDHS. Kyu Kim, Director of Finance and Contract Compliance, Refugee Services will be responsible for the oversight of the reimbursement payments and will ensure the Federation adheres to the 30 day requirement going forward. Responsible Person: Kyu Kim Anticipated Completion Date: July 2025

View Audit 341343

Finding 522064 (2024-002)

Significant Deficiency 2024

Town of Hudson

NH

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

Audit Finding Reference: 2024-002 Management’s Response and Planned Corrective Action: The Town acknowledges the need to formalize written policies and procedures to comply with Uniform Guidance requirements. We are in the process of developing and implementing comprehensive policies addressing ...

Audit Finding Reference: 2024-002 Management’s Response and Planned Corrective Action: The Town acknowledges the need to formalize written policies and procedures to comply with Uniform Guidance requirements. We are in the process of developing and implementing comprehensive policies addressing allowable costs, employee travel, cash management, equipment and inventory, procurement, and subrecipient monitoring. Name of Contact Person and Completion Date: Name 1: Beth McKee Anticipated Completion Date – 6/30/2025

View Audit 341291

Finding 522011 (2024-003)

None 2024

Carolina College of Biblical Studies

NC

Subrecipient Monitoring Student Financial Aid

Corrective Action Plan: The College will review its information security policy during FY 2025 and will make the required changes. Anticipated Completion Date: The corrective action will be completed by June 30, 2025. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

View Audit 341279

Finding 522008 (2024-004)

Material Weakness 2024

City of Lincoln Park, Michigan

MI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

Condition: The City could not provide evidence that it complied with 2 CFR 200.214, which states that nonfederal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. Planned Corrective Action: The c...

Condition: The City could not provide evidence that it complied with 2 CFR 200.214, which states that nonfederal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. Planned Corrective Action: The city will ensure that all future contracts awarded under this program are in compliance and will have contractors sign to verify that they are in compliance. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2025

View Audit 341278

Finding 522001 (2024-002)

Significant Deficiency 2024

Battle Creek Unlimited, Inc.

MI

Subrecipient Monitoring § 200.331

Finding: 2024-002 - Subrecipient Monitoring Auditor Description of Condition and Effect: We noted that the Organization did not compile any risk assessments or perform adequate subrecipient monitoring during the fiscal year. The lack of monitoring failed to provide reasonable assurance that the sub...

Finding: 2024-002 - Subrecipient Monitoring Auditor Description of Condition and Effect: We noted that the Organization did not compile any risk assessments or perform adequate subrecipient monitoring during the fiscal year. The lack of monitoring failed to provide reasonable assurance that the subrecipients complied with the provisions of the grant. Auditor Recommendation: We recommend that the Organization create a subrecipient policy to ensure that all subrecipient grant awards are monitored in compliance with the Uniform Guidance requirements. Corrective Action: Management will create and adopt a subrecipient monitoring policy that ensures compliance with the Uniform Guidance requirements by June 30, 2025. Responsible Person: Joe Sobieralski, President and CEO Anticipated Completion Date: June 30, 2025

View Audit 341240

Finding 521479 (2024-007)

Significant Deficiency 2024

Langston University

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.344

Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: $125,03...

Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: $125,035.65 The costs in question were not billed to or collected from the awarding agency. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. The University is strengthening the close-out process of federal awards to halt expenditures thus reducing redistributions and cost-transfers. Name(s) of the contact person(s) responsible for the corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: March 2025

View Audit 341200 Questioned Costs: $1

Finding 521249 (2024-001)

Significant Deficiency 2024

Langston University

OK

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.305

Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: N/A Action taken in response to finding: This is a...

Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: N/A Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. The University is strengthening its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Name(s) of the contact person(s) responsible for the corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: March 2025

View Audit 341200

Finding 521209 (2024-001)

Material Weakness 2024

New American Association of Massachusetts, Inc.

MA

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.331 § 200.332

We acknowledge that the timing of these actions did not fully align with the requirements of Uniform Guidance, which specifies that subaward information must be communicated with the subrecipients in writing at the time the subaward is made. However, the Organization worked diligently to address the...

We acknowledge that the timing of these actions did not fully align with the requirements of Uniform Guidance, which specifies that subaward information must be communicated with the subrecipients in writing at the time the subaward is made. However, the Organization worked diligently to address the issue once identified. To prevent recurrence of this issue, the Organization has taken corrective actions. As soon as we were made aware of the status of the recipients of the awards as subrecipients, we informed them of their status orally and outlined the general terms and compliance requirements associated with their subaward. We formalized this notification process by providing written agreements detailing the subaward terms, as required, in June 2024. These agreements were subsequently signed and returned by the subrecipients in July 2024. To avoid similar compliance challenges, the Organization worked with the Commonwealth of Massachusetts to revise its agreement. Effective September 30, 2024, the Organization no longer serves as a pass-through entity and does not pass federal funds through to subrecipients. For the remaining period during which the Organization acted as a pass-through entity, we implemented procedures to ensure timely and accurate communication of subaward information in writing, aligning with Uniform Guidance requirements. Management believes these actions fully address the cause of the finding and ensure compliance with federal regulations in the future.

View Audit 341176

Finding 521186 (2024-002)

Significant Deficiency 2024

Western Piedmont Regional Transit Authority

NC

Reporting Subrecipient Monitoring Significant Deficiency

Name of Contact Person: Scott Cook Corrective Action/Management’s Response: WPRTA will timely submit the Transportation Asset Management (TAM) inventory report. Proposed Completion Date: Immediately and ongoing

View Audit 341148

Corrective Action Plans

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