Corrective Action Plans

Finding 528884 (2024-010)

Significant Deficiency 2024

PA

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing...

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing the following from the list: - Those who registered for work. - Those exempt for other reasons. - Those denied benefits for other reasons. - Those with no payments for weeks beyond the 4th week of the claim. - The remaining individuals’ payments for the fifth week of the claim and later were totaled in January 2025: - 3,481 individuals - $22,597,596.92 - These amounts are described as “maximum” because only an individual review of each claim would reveal if the person was truly not properly registered and if weeks of benefits should be overpaid. - The Department is choosing to waive these individuals’ requirement to register based on UC law section 401(b)(6): The department may waive or alter the requirements of this subsection in cases or situations with respect to which the secretary finds that compliance with such requirements would be oppressive or which would be inconsistent with the purposes of this act. Since the individuals would currently be told of requirements they needed to meet in the past and, as a result, given debts to repay, this is oppressive in nature and inconsistent with the purpose behind the registration requirement. Anticipated Completion Date: Completed Contact Names: Stacy Walter, Management Analyst 2, Special Projects, Office of UC Service Centers; Rick Plesnarski, Management Supervisor, Special Projects Unit & Quality Assurance, Office of UC Service Centers

View Audit 346904 Questioned Costs: $1

Finding 528881 (2024-012)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

BWPO acknowledges that these errors were made, and the indicated accounts were updated immediately. The following steps will be taken to prevent this from happening again. 1. Desk Guides and Training Manuals for Central Offices CWDS Access Administrators will be updated to clearly define what ro...

BWPO acknowledges that these errors were made, and the indicated accounts were updated immediately. The following steps will be taken to prevent this from happening again. 1. Desk Guides and Training Manuals for Central Offices CWDS Access Administrators will be updated to clearly define what roles are restricted to state staff. Completed February 2025. 2. The Access Forms will be updated with the AdministratorLO role being in the restricted roles section and marked as only available to state staff. Completed February 2025. 3. During future reviews of restricted roles CWDS Users with these roles will be checked against staffing lists to confirm their employment status and availability for these roles. To be completed at the next Annual Review of Restricted Roles. A supplementary Annual Restricted Role Audit being completed currently for Restricted Roles. Completed March 2025. Anticipated Completion Date: Completed Contact Name: Jeremy Bender, Customer Service Unit Workforce Development Supervisor BWPO acknowledges that these errors occurred. The accounts were immediately deactivated upon discovery that the staff were no longer with the Commonwealth. The following steps will be taken to prevent a re-occurrence of this issue. 1. Three of the accounts in question were originally BWPO staff who moved to ATO, still needing CWDS Access, and then left state employment at a later date. There is currently not a system in place to review ATO staff separations. Going forward, Monthly Account Deactivation reviews will be expanded to BWDA and ATO with those Bureaus having to attest to all separations during the prior month. This should help ensure the Customer Service Unit is notified timely of staff separations in the other Bureaus. To begin March 31, 2025. 2. During periodic review of deactivations, the Customer Service Unit will compare CWOPA accounts against state staffing lists provided by HR, to ensure separated staff have their accounts deactivated timely. This will likely have to be quarterly or semi-annually as it is unfeasible for HR to have to generate full staff complements monthly for the multiple Bureaus whose CWDS Access BWPO’s Customer Service Unit manages. This will catch any issues that step 1 doesn’t resolve. To begin March 31, 2025. Anticipated Completion Date: 03/31/2025 Contact Name: Jeremy Bender, Customer Service Unit Workforce Development Supervisor

View Audit 346904

Finding 528878 (2024-006)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.405 § 200.406

1. All offices will ensure timely and effective communication. The WIC Finance staff will meet with Budget Office (BO) Analysts monthly to review SAP forms, expenditure adjustments, Grant Status Reports and other fiscal items for accuracy and action. Program, budget and comptroller staff will meet a...

1. All offices will ensure timely and effective communication. The WIC Finance staff will meet with Budget Office (BO) Analysts monthly to review SAP forms, expenditure adjustments, Grant Status Reports and other fiscal items for accuracy and action. Program, budget and comptroller staff will meet at least quarterly to review expenditures, processes and needed actions for federal grants. BO and program office staff have agreed to the following verbally: Program staff will submit a final federal report three months after the end of the grant period. Program staff will monitor all active federal grant internal orders paying careful attention to expenditures that post after the close of federal grant budget period. If there is a late expenditure, program staff will revise the final report and submit it to the DOH BO for review using the BO workflow. The DOH BO will also monitor all active internal order numbers and alert the program office of any unusual transactions. The DOH BO will inform the program office of unusual transactions and add them to regular meeting agendas for further discussion and planning. DOH will create a bulletin to outline federal grant management policies and procedures and disseminate to all DOH program offices. 2. BO staff that made the error were notified and counseled on ways to minimize errors. BO shall update the workflow and expenditure adjustment instructions in coordination with the program office. 3. The credit was largely due to overcharges of costs for a Software License Agreement that was not allowed to be charged to the grant. The IT staff that initiated the overcharge and directed the program office to make the adjustment has been counseled on policy and procedures for charging expenditures to a federal source. All fiscal transactions for IT expenditures are reviewed by program staff as well as BO staff via the BO workflow. Policies and procedures specific to IT expenditures charged to a federal fund will be reviewed and updated to ensure information and instructions are robust and clear. Updated policies and procedures will be disseminated to all DOH staff with a responsibility in the process. Anticipated Completion Date: 05/31/2025 Contact Names: Steven Marsden, Audit Resolution Manager; Andrea Race, Chief Financial Officer

View Audit 346904

Finding 528865 (2024-015)

Material Weakness 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.208 § 200.332 § 200.339 § 200.501 § 200.505

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applic...

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applicable findings will be issued and tracked. 3. Improvements have been made with regards to regularity in reporting to more effectively monitor activities of subrecipients consistently with respect to Federal statutes and regulations. 4. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracking single audit submissions on a Commonwealth-wide basis since the Aging Cluster program is material and has material sub-granted expenditures in NSIP and Title III. 5. It is PDOA’s impression that having increased oversight of the SEFA will allow for timely dissemination of management decision letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Discussions have started regarding considerations to take enforcement action against noncompliance by building language into the terms and conditions of the Cooperative Block Grant Agreements to exercise ability to withhold funding as approved in the Cost Allocation Plan. 7. PDOA has reached out to the BAFM to verify all outstanding audit items for PDOA since action is required within six months of receipt. 8. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison PDA: PDA has added a Financial Management Specialist 1 (FMS1) to its complement with the primary duty of agency audit liaison. The FMS1 will report to the PDA’s Budget Office. This is a new position and role within the department and has training and certification requirements to complete which will allow the position to: 1. Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. 3. Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. The new FMS1 will help ensure effective and efficient audit resolutions. This newly created position will also be responsible for the department wide audit tracking log that is in development. Anticipated Completion Date: 06/30/2025 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDE: The PDE Audit Section is working with divisions to develop processes to ensure timely responses. A training will be conducted by April 2025 on audit procedures, best practices, and federal regulations governing single audit management decisions. Anticipated Completion Date: 04/30/2025 Contact Names: Clayton P. Carroll II, Audit Coordinator; Jessica Sites, Director, Bureau Financial Operations DEP: DEP has updated the concur subrecipient letter to include the specific language related to the management decision that was previously in our non-concur letters. This ensures whichever template is used, the management decision and related finding information will be included in the subrecipient letter. Revised letters were sent to both subrecipients, in which DEP was the lead agency and had findings for in the audited timeframe. Staff are reviewing all the steps of our standard operating procedures to ensure we will be in compliance regardless of whether DEP is or is not the lead agency and regardless of whether we are preparing a concur or non-concur letter for the subrecipient. Anticipated Completion Date: 06/30/2025 Contact Names: Jennifer Brandt, Senior Fiscal Mgmt. Specialist; Kristen Szwajkowski, Lead Fiscal Mgmt. Specialist DHS: As stated in the DHS finding response, this was the result of human oversight, and not a systemic issue with internal controls. We have reminded staff to make sure that a management decision is timely communicated to subrecipients at the time of making the management decision. Anticipated Completion Date: Completed Contact Names: David Bryan, Mgr., Audit Res. Section; Alexander Matolyak, Dir., Div. of Audit & Rev.

View Audit 346904 Questioned Costs: $1

Finding 528864 (2024-014)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring § 200.1 § 200.332

DHS: TANF – Child Care All applicable federal Notice of Awards (NOAs), which include the Federal Award Identification Number, will be emailed to the grantees both prior to the spending period and as they become available for the spending as indicated on the NOA. They will also be included in the an...

DHS: TANF – Child Care All applicable federal Notice of Awards (NOAs), which include the Federal Award Identification Number, will be emailed to the grantees both prior to the spending period and as they become available for the spending as indicated on the NOA. They will also be included in the annual Audit Guidelines. Anticipated Completion Date: Completed Contact Names: Nia Harris, Dir, Bur. of Early Learning Res. Center Ops.; Adrienne Smyth, Human Service Prgm. Executive; Paula Piasecky, Human Serv. Prgm. Rep. TANF – Other The DHS Office of Policy Development (OPD) will perform risk assessments for all grantees annually. Anticipated Completion Date: 06/30/2025 The DHS Office of Income Maintenance (OIM) reestablished the completion of risk assessments in the fall of 2024 and has provisionally completed them for all subrecipients, including TANF – Other, for FY23-24. The risk assessments seek to test various financial controls of subrecipients based on their risk assessment scores and will also assist in ranking subrecipients across the risk continuum. Anticipated Completion Date: Completed Contact Names: Louie Marven, OPD, Exec. Policy Splst.; Sheldon Marcus, OIM, Dir., Div. of Mgmt. & Bgt.; Ron Seliga, OIM, Mgr., Fin. Planning; Judy Alfaro, OIM, Mgr., Financial Accountability; Laura Schlagnhaufer, OIM, Dir., Div. of Contr. Progs. & Sys. Social Services Block Grant (SSBG) OPD will provide all grantees receiving federal funding with a letter identifying federal award information and applicable requirements. OPD will provide this letter annually. Anticipated Completion Date: Completed Contact Name: Louie Marven, OPD, Exec. Policy Specialist DOH: DOH planned to develop and implement a robust subrecipient monitoring program which included establishing a new section within the Budget Office. The PA Legislature did not approve a budget with funding that could accommodate a new section. Alternatively, a consulting firm was engaged to perform a review of policies and procedures across the agency, including providing a gap analysis to determine compliance. A recommendation report is to be provided to DOH by March 31, 2025. DOH will initiate a comprehensive training plan for department staff based on the recommendation report. DOH will then develop training materials with an anticipated completion of June 30, 2025, with a goal to conduct training across the department by September 30, 2025. Anticipated Completion Date: 09/30/2025 Contact Name: Andrea Race, CFO PDA: PDA’s Bureau of Food Assistance (BFA) will develop a process to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The evaluation will be based on Key Performance Indicators, such as leadership tenure; prior incidents of food spoilage; or qualitative feedback from clients served. If the evaluation determines that additional monitoring tools beyond the routine performance of on-site reviews of the subrecipient’s program operations are necessary, such conditions will be laid out in a separate letter communication to the sub-awardee. PDA will also develop and implement a system to document the evaluation of each subrecipients risk of noncompliance. Anticipated Completion Date: 09/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: Concerning the evaluation of each Subrecipient’s Risk of Noncompliance, PDOA has developed a new monitoring component, consisting of fifteen measurable elements, to actively monitor compliance of the 52 Area Agencies on Aging (AAA) subrecipients through a revised Phase IX monitoring tool. The revised tool, used by three Fiscal Field Representatives, includes a review of Program and Procurement, Contract Monitoring, Record Retention and Environmental Modifications. • Timelines have been established to evaluate each subrecipients risk of noncompliance with Federal statutes, regulations and the terms and conditions of their subaward. - The Bureau of Finance coordinated with the Bureau of Quality Assurance to ensure schedules do not conflict and become burdensome to the AAA network. - The Fiscal Representatives plan to follow-up on any Performance Issues identified within the succeeding 6-9 months as identified in the approved Cost Allocation Plan. - Prior to the start of a new State Fiscal Year, the Risk Assessment surveys are distributed to adequately evaluate each subrecipient’s risk of noncompliance timely. • PDOA has drafted a AAA Fiscal Monitoring process map to formally document the monitoring process which highlights the requirement to disseminate Risk Assessments. • PDOA has been working with the AAAs to correct reporting in preparation of the next round of monitoring to ensure accuracy of Financial Reporting requirements and Line-Item Budgets on record. • To avoid future deficiencies in compliance, revised risk assessments have been developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over Federal programs. • Despite PDOA recognizing time and insufficient staffing as a barrier to achieving the goal of performing a risk assessment for every AAA, we have surpassed our expectation of reaching half at a minimum by conducting a full assessment of all 52 for fiscal year ending June 30, 2024. • PDOA confirmed the Comprehensive Aging Performance Evaluation (CAPE) approach to evaluations of aging services provided by AAAs a success and shifted it out of pilot status which features a fiscal component. • To best review internal controls for financial issues concerning the Aging Cluster, a fiscal component will be administered since multiple Federal funding streams are involved. • This finding has aided in our approach to the subrecipient section of contract language as the Cooperative Block Grants are actively being developed. The proposed policy addresses Subrecipient requirements in the Admin Chapter as opposed to the appendix as a result. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DDAP: DDAP understands the need to develop policies to ensure all required federal award information is disseminated to all subrecipients at the time of the subaward. DDAP currently includes the following federal award information in its grant agreements to subrecipients: • Subaward Period of Performance Start and End Date • Total amount of Federal funds obligated to the subrecipient • Total amount of the Federal award committed to the subrecipient • Name of Federal awarding agency, pass-through entity, and contact information for awarding official of pass-through entity • Assistance Listings Number (ALN) and title However, not all the required information is available at the time the grant agreements are executed, such as the Federal Award Identification Number (FAIN) and the Federal award date. To ensure subrecipients are compliant with the Uniform Guidance in 2 CFR Section 200 and other applicable federal regulations, DDAP will develop policies to ensure notification is sent to all subrecipients that includes all required federal award information once the information has been received through the Notice of Award from the Substance Abuse and Mental Health Services Administration (SAMHSA). • First draft of P&P and proposed letter to subrecipients: Person responsible - Ellie Stache and Tia Roebuck: Anticipated completion date - 03/28/2025 • Review of first draft and letter by Bureau Director: Person responsible - Marie Plumer, Director, Bureau of Administration: Anticipated completion date - 04/11/2025 • Revision to first drafts: Person responsible - Ellie Stache: Anticipated completion date - 04/25/2025 • Review of second drafts by Executive staff: Person responsible - Kelly Primus, Deputy Secretary: Anticipated completion date - 05/09/2025 • Revisions to second drafts: Person responsible - Ellie Stache: Anticipated completion date - 05/23/2025 • Final review by Bureau Director and Executive staff: Person responsible - Marie Plumer and Kelly Primus: Anticipated completion date - 06/06/2025 • Submission to auditor: Person responsible - Tia Roebuck: Anticipated completion date - 06/30/2025 Anticipated Completion Date: 06/30/2025 Contact Names: Tia Roebuck, Director, Division of Budget and Procurement; Ellie Stache, Section Chief, Fiscal Planning and Contractual Operations L&I: Once L&I’s Bureau of Workforce Development Administration (BWDA) identified that the incorrect funding source was listed on the Notice of Obligation (NOO) associated with the TANF Youth Development Program contract, BWDA updated the list of funding sources in the Commonwealth Workforce Development System to encompass ALN 93.558. This update was implemented on February 20, 2025, and the updated NOOs were disseminated through CWDS. This change ensures that all NOOs created under ALN 93.558 now and in the future will have the correct funding source listed for the subrecipient. Anticipated Completion Date: Completed Contact Names: Brenda Duppstadt, Director; Gordon Zook, Division Chief

View Audit 346904 Questioned Costs: $1

Finding 528863 (2024-005)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Questioned Costs Eligibility

PDA, BFA has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. Upon identification of this finding, BFA directed our Field Representatives to immediately complete reviews of the 47 identified soup kitchens. As of 2/20/25, 18 of these soup kitc...

PDA, BFA has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. Upon identification of this finding, BFA directed our Field Representatives to immediately complete reviews of the 47 identified soup kitchens. As of 2/20/25, 18 of these soup kitchen reviews have been completed and 8 of these reviews are in-process or pending final review approval. 2. BFA Field Representatives have been advised that Soup Kitchen reviews must be completed once every four years, just like other TEFAP agencies with which we have direct agreements. This requirement is also being added to the Field Representative work manual. Anticipated Completion Date: 06/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

View Audit 346904 Questioned Costs: $1

Finding 528851 (2024-007)

Material Weakness 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Office of Income Maintenance (OIM) Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card ...

Office of Income Maintenance (OIM) Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties. 2. The BOO will ensure offices know EBT cards are only to be made during business hours. BOO will work with the EBT Project Office to update the OIM EBT Procedure Manual for clarification. This will occur by April 1, 2025. 3. All CAOs and district offices will be reminded to update the EBT card tracking database within 24 hours of an individual’s status change. Clarification will be sent to the Area Managers to distribute to staff. This will occur by April 1, 2025. 4. All EBT Coordinators will be reminded to review the updates/changes to the OIM EBT Procedure Manual quarterly. Anticipated Completion Date: 04/01/2025 Contact Name: Jeanette Coulston, Staff Assistant to Director of Bureau of Operations OIM Bureau of Program Support (BPS)/EBT Project Office: BPS will take the following actions to address the finding: 1. The EBT Project Office will provide clarification and make updates to the OIM EBT Procedure Manual, in the Staff Security Section, for removing individuals from the EBT card tracking database. The updates will include screenshots for easier comprehension. This is expected to be completed by April 1, 2025. 2. The EBT Project Office will make updates to the OIM EBT Procedure Manual, in the EBT Security for Over the Counter (OTC) Card Mailing Section, to include “CAOs should not print OTC EBT Cards outside of normal business hours”. This is expected to be completed by April 1, 2025. 3. The OIM EBT Procedure Manual is updated quarterly. An email notification is sent to all EBT Coordinators, via a distribution list, notifying them of the updates/changes. This is expected to be completed by April 1, 2025. Anticipated Completion Date: 04/01/2025 Contact Name: Tonya Holloway, Division Director OIM Bureau of Program Evaluation (BPE)/Division of Corrective Action (DCA): BPE will take the following actions to address the finding: The Bureau of Program Evaluation, Division of Corrective Action conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a three-year rotation to ensure compliance in the execution of documented policies and procedures. When needed, BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the OIM EBT Procedure Manual. Annually, BPE/DCA EBT Headquarters staff provide training to DCA Income Maintenance Examiners in both field offices, to ensure awareness of any policy or procedure changes, prior to the start of the EBT reviews. The current rotation schedule spans FFY 2025- FFY 2027. The new three-year schedule began October 2024. Anticipated Completion Date:Completed Contact Name: Amira S. Milikin, Division Director

View Audit 346904 Questioned Costs: $1

Finding 528827 (2024-003)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

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

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context : The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY22 time period ($230,281) did not agree to the underlying expenditure records ($4,290 for the period of July 1, 2021 through June 30, 2022). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Finance will review financial statements and ensure they agree to amounts reported on the annual data reports. Reviews will be documented with a signature. FTE documentation will be retained. Anticipated Completion Date: When the next report is due

View Audit 346885

Finding 528777 (2024-002)

Material Weakness 2024

The Salvation Army Golden State Division

CA

Equipment & Real Property Management Special Tests & Provisions Subrecipient Monitoring

Corrective Action Plan: The Division will implement a review process to ensure the accuracy of the inventory management and reporting process. Anticipated Date: April 2025 Name of Person Responsible for Implementation: Al Agpoon, Controller

View Audit 346837

Finding 528724 (2024-003)

Material Weakness 2024

North Miami Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Context: For the two projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the fed...

Context: For the two projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have contracts with the company that included the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $447,034 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: 765-985-3891 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: If NMCS enters into contractual agreements where Davis-Bacon rules will apply we make arrangements before the contract is signed to meet all of the necessary requirements. Anticipated Completion Date: 3/1/2025

View Audit 346755

Finding 528686 (2024-003)

None 2024

Hoover-Schrum Memorial School District 157

IL

Reporting Subrecipient Monitoring

Condition: The School District did not comply with the requirements of filing period and quarterly reports by the due date set by ISBE. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion...

Condition: The School District did not comply with the requirements of filing period and quarterly reports by the due date set by ISBE. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Dr. Dwayne E. Evans, Superintendent of Schools. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 346693

Finding 528676 (2024-003)

Material Weakness 2024

Central Noble Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING: 2024-003 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Baumgartner Contact Phone Number and Email Address: 260-636-2175 baumgartnerk@centralnoble.k12.in.us Views of Responsible Officials: We concur with the fin...

FINDING: 2024-003 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Baumgartner Contact Phone Number and Email Address: 260-636-2175 baumgartnerk@centralnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review its internal control process for checking if a vendor is suspended or debarred prior to doing business with that vendor. All future expenditures triggering suspension and debarment requirements will include implementing the following procurement policies. The Business Manager will initial the supporting documentation for verifying a vendor to provide proof of compliance. Reference Suspension and Debarment Standards 2 CFR 180.300 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) Anticipated Completion Date: July 2025

View Audit 346685

Finding 528655 (2024-001)

None 2024

Nashville School District

AR

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.344 § 200.502

A. DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t ...

A. DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

View Audit 346638 Questioned Costs: $1

Finding 528655 (2024-001)

None 2024

Nashville School District

AR

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.344 § 200.502

B. In the future, we will wait until buses are on site to write checks.

View Audit 346638 Questioned Costs: $1

Finding 528655 (2024-001)

None 2024

Nashville School District

AR

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.344 § 200.502

C. We do not anticipate any ESSER ARP money to be issued in the near future.

View Audit 346638 Questioned Costs: $1

Finding 528634 (2024-245)

Material Weakness 2024

Willow Springs R-IV School District

MO

Subrecipient Monitoring Internal Control / Segregation of Duties

INTERNAL CONTROL OVER MAJOR FEDERAL PROGRAM COMPLIANCE Program: Education Stabliization Fund (CFDA 84.425) Condition: Lack of policies and procedures for verifying and monitoring Wage Rate Requirements. Material Weakness Corrective Action Plan: The District will adopt policies and implement...

INTERNAL CONTROL OVER MAJOR FEDERAL PROGRAM COMPLIANCE Program: Education Stabliization Fund (CFDA 84.425) Condition: Lack of policies and procedures for verifying and monitoring Wage Rate Requirements. Material Weakness Corrective Action Plan: The District will adopt policies and implement procedures to require previaling wage payments for contractor employees working on federally funded projects. The District will adopt policies and implement procedures requiring contractors on federally funded projects provide certified payroll reports to the District to ensure compliance with Wage Rate Requirements. The District will implement verification procedures to ensure contractor compliance with previaling wage payments to employees. Planned Completion Date: March 31, 2025 Responsible Contact Perosn: Dr Marty Spence, Superintendent (417) 469-3260

View Audit 346599

Finding 528611 (2024-001)

Significant Deficiency 2024

City of Worcester, Massachusetts

MA

Questioned Costs Subrecipient Monitoring Reporting

The City of Worcester, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the...

The City of Worcester, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Housing and Urban Development 2024-001 Community Development Block Grant - Assistance Listing Number 14.218 Recommendation: We recommend procedures be strengthened to ensure all required subaward reports are filed with FSRS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City of Worcester will strengthen its procedures to comply with the FSRS reporting requirements and ensure all subawards are appropriately reported in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Alexis Delgado, Assistant Budget Director – Grants Planned completion date for corrective action plan: April 30, 2025

View Audit 346595

Finding 528561 (2024-003)

Significant Deficiency 2024

Catholic Reflief Services - US Conference of Catholic Bishops

MD

Allowable Costs / Cost Principles Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.309 § 200.403

3.1.Ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

View Audit 346571 Questioned Costs: $1

Finding 528559 (2024-002)

Significant Deficiency 2024

Catholic Reflief Services - US Conference of Catholic Bishops

MD

Allowable Costs / Cost Principles Reporting Questioned Costs § 200.303 § 200.309 § 200.403

2.1 Ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

View Audit 346571

Finding 528557 (2024-001)

Material Weakness 2024

Wa-Nee Community Schools

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Departmen...

Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor installation. The School Corporation did not obtain the weekly payroll reports certifications from vendor installing equipment. Context: The School Corporation had one project during the audit period which included construction or labor installation costs which were charged to the ESSER III (84.425U) grant award. For the vendor selected for testing, the School Corporation did not include federal wage rate requirement clauses in the contract with the vendor and did not have an internal control designed to collect the weekly payroll reports certifications from vendors and its subcontractors, as applicable, to comply with Davis Bacon wage rate requirements. The amount disbursed for the project totaled $192,036. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure all federal funded renovation, remodeling, or construction projects anticipated to incur labor costs greater than $2,000 include a signed contract containing a Davis-Bacon wage rate provision and will monitor the vendor to ensure compliance with certified payroll reporting requirements. Responsible Party and Timeline for Completion: Jessica McFarland, Business Manager, procedures were implemented immediately.

View Audit 346562

Finding 528551 (2024-002)

Material Weakness 2024

Southwest Detroit Environmental Vision

MI

Questioned Costs Subrecipient Monitoring Material Weakness § 200.501 § 200.512 § 200.514

To ensure fiscal compliance and operational efficiency, grant activities will undergo enhanced monitoring through the addition of monthly reviews of review revenue and expense recognition, regular comparisons against budget and award terms, and provide targeted training for new grant managers and ac...

To ensure fiscal compliance and operational efficiency, grant activities will undergo enhanced monitoring through the addition of monthly reviews of review revenue and expense recognition, regular comparisons against budget and award terms, and provide targeted training for new grant managers and accounting staff on expenditures to meet grant spend down schedules. This finding relates to one legacy grant.

View Audit 346558

Finding 528541 (2024-007)

Material Weakness 2024

Gary Community School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.77 § 200.78

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of R...

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Gary Community School Corporation has implemented a corrective action plan to strengthen internal controls over Direct Certification data related to food service eligibility and to ensure the accuracy of enrollment and poverty data used in the Title I application process. The Business Services Coordinator will oversee a structured monthly verification process to confirm that student eligibility for free or reduced‐price meals is accurately reflected in Skyward, the district’s student management system. Every month, Direct Certification data will be retrieved from the Indiana Department of Education (IDOE) and cross‐checked against Skyward records. Additionally, Real Time reports, which are used to prepopulate enrollment numbers for reporting and compliance purposes, will be reviewed to ensure consistency with the verified Direct Certification data. Any discrepancies found between these data sources will be promptly investigated, corrected, and documented to maintain compliance with federal and state food service regulations. To enhance accountability, staff responsible for managing student eligibility data will receive training on the verification and reconciliation process. This training will ensure that they understand how to properly retrieve Direct Certification data, compare it to Skyward records and Real Time reports, and document necessary corrections. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by July 2025.

View Audit 346557

Finding 528539 (2024-006)

Material Weakness 2024

Gary Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report/High School Graduation Rate Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email ...

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report/High School Graduation Rate Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: To address the deficiencies related to the accuracy of the Annual Report Card and High School Graduation Rate, the Gary Community School Corporation will implement a structured withdrawal process to ensure proper documentation and verification of student withdrawals. A standardized withdrawal form will be introduced, requiring a parent or legal guardian to complete and sign the document before a student is officially withdrawn from the school. This form will be maintained in the student’s file along with any corresponding records request from the receiving school. As part of the revised withdrawal process, the principal will be required to review and sign off on all withdrawal requests to ensure accuracy and compliance with reporting requirements. This additional level of oversight will help prevent errors and ensure that student withdrawal data is properly documented and accounted for in graduation rate calculations. The School Corporation will also provide training for school administrators and registrars involved in the withdrawal and records management process to ensure proper adherence to the updated procedures. Periodic internal audits will be conducted to assess compliance and identify any areas for improvement. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by July 2025.

View Audit 346557

Finding 528520 (2024-001)

Significant Deficiency 2024

Logan University

MO

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding 2024-001 Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: May 2024 Corrective Action Plan: The funds for the affected student have been retur

View Audit 346554 Questioned Costs: $1

Finding 528518 (2024-007)

Significant Deficiency 2024

Humboldt County

NV

Subrecipient Monitoring

Grant responsibilities have been transferred under the supervision of the Comptroller and will enhance control procedures to monitor the activities of subrecipients to ensure and document that the subaward was used for authorized purposes. Please note, that this was not deemed to be a questioned cos...

Grant responsibilities have been transferred under the supervision of the Comptroller and will enhance control procedures to monitor the activities of subrecipients to ensure and document that the subaward was used for authorized purposes. Please note, that this was not deemed to be a questioned cost as no instances of material non-compliance were noted during the testing of subrecipients grant activities.

View Audit 346533

Corrective Action Plans

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