Corrective Action Plans

Finding 399004 (2023-004)

Significant Deficiency 2023

CA

Subrecipient Monitoring Reporting Significant Deficiency

Due to a change in personnel the format and procedures for reporting were not followed during the period of the personnel vacancy. Going forward proper procedures will be followed to ensure accurate reporting and a plan will be put into place to continue these procedures even in the event of personn...

Due to a change in personnel the format and procedures for reporting were not followed during the period of the personnel vacancy. Going forward proper procedures will be followed to ensure accurate reporting and a plan will be put into place to continue these procedures even in the event of personnel vacancies.

View Audit 307640

Finding 398994 (2023-001)

Material Weakness 2023

Northshore School District No. 417

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Going forward we will ensure federally funded items are designated as such and are tracked separately. The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider r...

Going forward we will ensure federally funded items are designated as such and are tracked separately. The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy “unmet” need in would have been hard to meet even if the District hadn’t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC.

View Audit 307598 Questioned Costs: $1

Finding 398990 (2023-001)

Significant Deficiency 2023

Lakeshore Regional Entity

MI

Subrecipient Monitoring Internal Control / Segregation of Duties Significant Deficiency § 200.332

2023-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 – ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332,...

2023-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 – ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation. Planned corrective action: FY2024 contracts with subrecipients have been updated with all the required language. Responsible party: Chief Financial Officer Anticipated completion date: September 30, 2024

View Audit 307591

Finding 398975 (2023-001)

Material Weakness 2023

Edmonds School District No. 15

WA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management

As communicated in the District’s response to the prior audit finding, the District does not concur with the SAO’s interpretation of unmet need in the 2021-2022 audit nor does it concur with the same finding for the audit of the 2022-2023 fiscal year. We believe all Chromebook purchases were allowab...

As communicated in the District’s response to the prior audit finding, the District does not concur with the SAO’s interpretation of unmet need in the 2021-2022 audit nor does it concur with the same finding for the audit of the 2022-2023 fiscal year. We believe all Chromebook purchases were allowable and devices were only provided to those with an unmet need. We concur with SAO that we did not retain adequate documentation indicating which staff and students received hotspots and appreciate that SAO noted that there was an urgent need to distribute hotspot internet services to students in order that they could participate in remote learning, and that this urgency and extenuating circumstances resulted in this situation. We recognize there was an error associated with vendor credits in the amount of $2,751.10 but did not claim reimbursement for the other credits totaling $8,898.90 as indicated in the audit finding. We will work to improve our process regarding credits on future invoices. The District will continue to work with the FCC to resolve this finding.

View Audit 307577 Questioned Costs: $1

Finding 398971 (2023-002)

Significant Deficiency 2023

College of the Muscogee Nation

OK

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to und...

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand calculation and timing of returns. It should also be noted that in the current award year, CMN has moved to a model where attendance taking is not required, so staff is working with faculty and students to ensure timely notification of withdrawal and reviewing final grades at the end of the term in order to ensure all students needing a R2T4 calculation have one performed.

View Audit 307558

Finding 398970 (2023-001)

Significant Deficiency 2023

College of the Muscogee Nation

OK

Student Financial Aid Subrecipient Monitoring Eligibility

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects ...

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects of calculating awards, as well as staying up to date on regulatory changes through our student information system. In addition to more training in this area, priority will be placed on rechecking and auditing Pell awards so that they are reviewed during the award year. Staff has already begun reviewing fall 2023 Pell awards for accuracy and will continue to review awards as terms move forward.

View Audit 307558

Finding 398920 (2023-002)

Significant Deficiency 2023

Public Counsel

CA

Allowable Costs / Cost Principles Subrecipient Monitoring

Date: May 28, 2024 Cognizant or Oversight Agency: U.S. Department of the Treasury Public Counsel respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Armani...

Date: May 28, 2024 Cognizant or Oversight Agency: U.S. Department of the Treasury Public Counsel respectfully submits the following corrective action plan for the year ended August 31, 2023. Name and address of independent public accounting firm: Armanino, LLP 11766 Wilshire Blvd. 9ᵗʰ Floor Los Angeles, CA 90025 Audit period: August 31, 2023 The finding from the August 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2023-002 The Uniform Guidance Cost principles require consistency in treatment of costs and, specifically, that compensation costs be consistent. In addition, the Uniform Guidance requires that there be a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and conform to the established accounting policies and practices of the Organization. Recommendation: Management should ensure that new processes reflect all compliance requirements, including the ability to produce evidence of the execution of relevant controls. Action Taken: We agree with the auditors' recommendations, and we have and will be taking the following actions within the current fiscal year: We have updated the payroll allocation methodology to ensure that we are making allocations for employees on a fully pro rata basis and that there is a validation process to ensure that 100% of an employee's time is appropriately allocated across Federal and non-Federal funding sources. The supporting documentation is saved in our shared network folders and attached to the journal entries within our financial system. For any future process or system changes, we will ensure that we have thoroughly assessed the impact of any change before we implement it and vet it in through our internal grant compliance team. We have already made changes to involve our Legal Data Manager to implement a reporting process to ensure that we have complete timeslips that reflect both employee and supervisor approvals for every pay period. We will maintain this approach in Legal Server, the Organization's case management and timekeeping system, and will attach these timeslips as support for each of our allocation entries. We will continue to assess our procedures and internal controls relevant to our Federal funding to ensure compliance with the requirements of Uniform Guidance. We will do a thorough review of our internal control system and update it as necessary to align with best practices as recipients of Federal funding. The Finance team will actively seek training related to Uniform Guidance and other Federal rules and requirements. We will share and discuss this information across departments to maintain organization-wide compliance. Name of responsible person: Steven Godoy VP, Finance & CFO Anticipated completion date: August 31, 2024 If the U.S. Department of Treasury has questions regarding this plan, please call Steven Godoy, VP, Finance & CFO at (213) 393-1055. Sincerely yours, Steven Godoy VP, Finance & CFO

View Audit 307522

Finding 398756 (2023-001)

Material Weakness 2023

Lyle School District No. 406

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lyle School District No. 406 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 Feder...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lyle School District No. 406 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: 2023-001 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: Susan Carabin, Business Manager PO Box 368 Lyle, WA 98635 (509) 365-2191 Corrective action the auditee plans to take in response to the finding: Since learning of the requirement regarding payroll reports, the District immediately asked our contractor to build a shared file that contains the certified weekly payroll reports. We now download and document the reports once per week. Anticipated date to complete the corrective action: 3/28/2024

View Audit 307516

Finding 398697 (2023-003)

Material Weakness 2023

Heartland International Health Center and Subsidiary

IL

Subrecipient Monitoring § 200.332

Tapestry’s Finance team will correct noncompliance with Subrecipient Monitoring by updating the policies and procedures and educating the Finance and Grants team regarding the necessary steps to achieve proper compliance. Furthermore, Tapestry teams will store evidence of monthly meetings with grant...

Tapestry’s Finance team will correct noncompliance with Subrecipient Monitoring by updating the policies and procedures and educating the Finance and Grants team regarding the necessary steps to achieve proper compliance. Furthermore, Tapestry teams will store evidence of monthly meetings with grantees, and ensure we receive proper monitoring documentation to accompany suspended & debarred searches, audits, etc. Tapestry will share these requirements with grantees and ensure our policies and contract language are updated to reflect the CFR rules. The anticipated completion date to correct the Finding 2023-003 is August 15th, 2024.

View Audit 307469

Finding 398686 (2023-001)

Material Weakness 2023

Montesano School District No. 66

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Montesano School District No. 66 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 F...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Montesano School District No. 66 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: 2023-001 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: Sheila Baker, 502 E Spruce Avenue, Montesano, WA 98563, (360)249-3942 Corrective action the auditee plans to take in response to the finding: The district has recently participated in a training provided by the Department of Labor & Industries regarding prevailing wage requirements. In the coming months, the Superintendent and Business Manager will be creating a checklist for district use when we hire contractors to perform work for our district as well as a standard contract with language relating to prevailing wage requirements and source of funding. Under normal operations we do not hire contractors using federal funds and our ESSER funds have now been totally expended. Anticipated date to complete the corrective action: May 2024

View Audit 307436

Finding 398635 (2023-001)

Material Weakness 2023

Soap Lake School District No. 156

WA

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

Finding caption: The District did not have adequate controls for ensuring compliance with federal wage rate requirements. ...

Finding caption: The District did not have adequate controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Nikkie Maceda, External Business Manager, P.O. Box 1389, Soap Lake, WA 98851 (509) 223- 6941 Corrective action the auditee plans to take in response to the finding: For future federal prevailing wage projects, the district will review and update contracts to include language regarding Davis Bacon wages and contractor’s responsibility to file weekly certified payroll. The district will verify the filing of weekly certified payroll reports. Anticipated date to complete the corrective action: May 2024

View Audit 307408

Finding 398607 (2023-003)

None 2023

Underwriters Laboratories Inc.

IL

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding Number: 2023-003 – Procurement/Full and open competition Anticipated Completion Date: April 2024 Responsible Contact Person: Jocelyn Lombardozzi Planned Corrective Action: In response to this finding, an analysis of 2023 labor charged to awards was conducted. The results of the analysis ...

Finding Number: 2023-003 – Procurement/Full and open competition Anticipated Completion Date: April 2024 Responsible Contact Person: Jocelyn Lombardozzi Planned Corrective Action: In response to this finding, an analysis of 2023 labor charged to awards was conducted. The results of the analysis revealed that a net amount of $35,238 more could have been charged to the awards which the Company will not pursue charging to the awards. An analysis of labor charged to awards active in the first quarter of 2024 has also been performed to ensure that active awards are being charged according to employee’s actual pay. As of April 1, 2024, the Company has transitioned to a new accounting system. This system is configured to require employees working on sponsored projects to utilize percentage of effort and effort certification functionality for tracking actual time and actual labor costs to awards. Budgeted labor rates are no longer being used as of April 1, 2024.

View Audit 307361 Questioned Costs: $1

Finding 398597 (2023-001)

Material Weakness 2023

Okanogan School District No. 105

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Okanogan School District No. 105 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal R...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Okanogan School District No. 105 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported 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 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: Klancy Allen, Director of Finance P.O. Box 592 Okanogan, WA 98840 (509) 422-3629 Corrective action the auditee plans to take in response to the finding: The District will implement internal control procedures around the monitoring of third party contract managers in order to facilitate adequate internal controls for ensuring compliance with the federal wage rate requirements in any contracts for future federally funded projects. Anticipated date to complete the corrective action: May 2024

View Audit 307342

Finding 398591 (2023-002)

Significant Deficiency 2023

Southern Minnesota Regional Legal Services Inc.

MN

Subrecipient Monitoring

Management agrees with the auditor's finding and will take immediate action to revise the Organization's accounting manual to align with the regulatory requirements. The director of Finance (Vannam Khen) will work directly with the Organization's assigned Fiscal Compliance Analyst from Legal Service...

Management agrees with the auditor's finding and will take immediate action to revise the Organization's accounting manual to align with the regulatory requirements. The director of Finance (Vannam Khen) will work directly with the Organization's assigned Fiscal Compliance Analyst from Legal Services Corporation (LSC) to ensure policies and procedures are aligned with LSC's Financial Guide. The Director of Finance (Vannam Khen) will review the Organization's accounting manual annually and will notify the CEO (Jessie Nicholson) and the Finance and Audit Committee of any updates to any policy and procedures.

View Audit 307340

Finding 398583 (2023-001)

Material Weakness 2023

Everett School District No. 2

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The district does not concur with the audit finding or the $3.5 million of questioned costs. According to FCC bulletin/order #6.16 states “the applicant is not required to perform a new unmet need survey at the time of submitting the request for reimbursement if the applicant already performed a sur...

The district does not concur with the audit finding or the $3.5 million of questioned costs. According to FCC bulletin/order #6.16 states “the applicant is not required to perform a new unmet need survey at the time of submitting the request for reimbursement if the applicant already performed a survey at the time of submitting the application.” The district believes the unmet need requirements have been met as outlined: Determining Need: • The district determined its need based on its inventory of devices supporting remote learning and did not have enough RAM to have district and learning platforms operating at the same time. • Students and staff need a District device for safety, installed software for instruction, technical support and equity as explained in above reasoning and attached mobile access for student laptop handbook. • The district conducted a survey that determined that over 6,500 students required devices. Between the survey and the lack of RAM, the district determined that over 12,000 devices were needed to support learning. In addition, the district has no intention of applying for other Emergency Connectivity Funds.

View Audit 307321 Questioned Costs: $1

Finding 398580 (2023-001)

Material Weakness 2023

Sunnyside School District No. 201

WA

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

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district progr...

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district program director should receive weekly certified payroll reports to ensure compliance. On the next project that requires Prevailing Wage Rates, the District will make sure to receive weekly certified payroll reports to ensure compliance.

View Audit 307312

Finding 398554 (2023-003)

Significant Deficiency 2023

First Housing Corporation D/b/a Cathedral Manor

CT

HUD Housing Programs Eligibility Subrecipient Monitoring

4. Finding 2023-003 – Major Federal Award Programs Audit c. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with our lease files review we noted the following deficiencies: • 1 out of 1 move-outs tested did not have the inspection signed by t...

4. Finding 2023-003 – Major Federal Award Programs Audit c. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with our lease files review we noted the following deficiencies: • 1 out of 1 move-outs tested did not have the inspection signed by the tenant or an employee at the property. • 1 out of 1 move-outs tested did not have the inspection dated by an employee at the property. • 1 out of 1 move-ins tests did not have the tenant’s Enterprise Verification Form (“EIV”) performed timely within the 90 days HUD requires. d. Action(s) Taken or Planned on the Finding Management Agent Management has hired a new Compliance Manager and engaged a 3rd party compliance monitoring company to review all files and EIV processes effective 5/1/2024. Regards Kimalee Williams

View Audit 307266

Finding 398515 (2023-001)

Significant Deficiency 2023

City of Haverhill

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 10...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

View Audit 307261

Finding 398514 (2023-001)

Material Weakness 2023

Seattle School District No. 1

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attenti...

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attention until 10 months into the 22/23 audit period, leaving no time for discussion or changes in interpretation and process. The audit’s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that our internal controls were ineffective for demonstrating per location and per user limitations. Based on guidance from the Federal Communications Commission (excerpted below), the District contends we have spent all funds for allowable costs, that those costs were reasonable and necessary, and for students and staff with unmet needs. Districts were able to determine whether students and staff had unmet needs. For our district this meant addressing instances where students may have shared a home device with other siblings; student or staff devices were too old or slow to function properly when running multiple required applications; and / or student owned devices did not have the appropriate security in place to protect students during remote learning (especially from unauthorized websites). Home drives, where all educational digital resources were stored, couldn’t be accessed unless using a district issued device. Additionally, the district’s technical support could not access personally owned devices to provide for thousands of trouble tickets and support issues students faced during remote learning. Based on these factors, unmet need was defined broadly, but within allowed parameters and inventory records were kept, albeit, not perfectly. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by the health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. Seattle Public Schools followed guidance from the Federal Communications Commission outlined in a document titled: . “Emergency Connectivity Fund Common Misconceptions”, “Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus is eligible for Emergency Connectivity Fund Support.” Additionally, from the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: “We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.” And from question 51: “…we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students…with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.” Finally, SAO did not apply any reasonable measure to reduce questioned costs but did state they know that at least some of the equipment addressed unmet needs, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance. There are no corrective actions to take at this time as the funding source has been exhausted and the timeline has passed.

View Audit 307259 Questioned Costs: $1

Finding 398502 (2023-001)

Significant Deficiency 2023

The Women's Home

TX

Subrecipient Monitoring Cash Management Reporting

Corrective Action Plan: We have held recent discussions with the City of Houston regarding the Fiscal Report. As a result, it has been agreed that we will submit the Fiscal Report within the required timeframe. The Home will develop a process to ensure that once the Board of Directors has approve...

Corrective Action Plan: We have held recent discussions with the City of Houston regarding the Fiscal Report. As a result, it has been agreed that we will submit the Fiscal Report within the required timeframe. The Home will develop a process to ensure that once the Board of Directors has approved the quarterly financial information, the previously submitted Fiscal Reports will be reviewed for consistency. If differences exist, The Home will submit an amended Fiscal Report to the City of Houston for the applicable quarter. Contact Person Responsible for Corrective Action: Ms. Anna Coffey, Chief Executive Officer. Anticipated Completion Date: This was completed in conjunction with the filing of the Fiscal Report for March 31, 2024.

View Audit 307245

Finding 398497 (2023-002)

Material Weakness 2023

Kalamazoo Youth Development Network

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.212 § 200.318

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all A...

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all ARPA funded organizations have not been debarred, suspended, or otherwise excluded from receiving federal funds prior to receiving ARPA summer program funds. The results of the search will be included in the ARPA spreadsheet. Responsible Person: Viridiana Carvajal, Co-Executive Director, and American Rescue Plan Act (ARPA) Compliance Contractor Anticipated completion date: May 10, 2024. This action already has been implemented for the 2024 ARPA summer program.

View Audit 307230

Finding 398482 (2023-001)

Material Weakness 2023

Crazy Horse School

SD

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking

2023-001 FINDING: Deficit Fund Balances Questioned Costs: None noted. Recommendation: We recommend the School continue to implement their plan to liquidate all remaining debt from the general fund. We also recommend they continue a vigilant oversight of all budgets of the School. Response: The curre...

2023-001 FINDING: Deficit Fund Balances Questioned Costs: None noted. Recommendation: We recommend the School continue to implement their plan to liquidate all remaining debt from the general fund. We also recommend they continue a vigilant oversight of all budgets of the School. Response: The current Business Manager is enforcing the CHS Policies that do not permit expenditures in excess of the approved budget without Board approval. In addition, the current Business Manager does not include any carryover from prior budgets in the existing budget until the audit is completed and the financial statements are reconciled. The Business Manager has restricted use of General Fund revenues to remedy the deficit, including income received by the School that is non-program income, and the School Board is responsible for monitoring expenditures monthly. ANTICIPATED COMPLETION DATE: June 30, 2025 PERSON(S) RESPONSIBLE: Leslie Cuny, Business Manager

View Audit 307206

Finding 398463 (2023-001)

Significant Deficiency 2023

YWCA of Southern Arizona

AZ

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.326

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implemen...

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implement formal procurement procedures aligned with federal regulations, including thresholds for prior‐purchase authorization and vendor checks for suspension and debarment. Staff training will be conducted to ensure competency, and oversight mechanisms will be strengthened through regular monitoring and integration of SAM verification processes. Comprehensive documentation and record‐keeping practices will be established, with periodic reviews to facilitate continuous improvement. Through these actions, the YWCA aims to enhance compliance with federal procurement standards and ensure transparent and accountable procurement practices.

View Audit 307188

Finding 398461 (2023-002)

Significant Deficiency 2023

Texas Council on Family Violence, INC

TX

Subrecipient Monitoring § 200.332

Policies and procedures will reflect the Program lead prepares sub-grants and CFO will review to ensure correct fund source/CFDA is noted. This approach creates a check and balance. A committee involving program staff and finance staff will review all documentation including application, and post aw...

Policies and procedures will reflect the Program lead prepares sub-grants and CFO will review to ensure correct fund source/CFDA is noted. This approach creates a check and balance. A committee involving program staff and finance staff will review all documentation including application, and post award documentation.

View Audit 307186

Finding 398460 (2023-001)

Material Weakness 2023

Mount Vernon School District No. 320

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services ...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services Supervisor 124 E. Lawrence Street, Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: Concern: The district failed to maintain sufficient documentation proving that the equipment provided to students matched their actual unmet needs. Reimbursement was sought based on estimated unmet needs rather than documented, actual unmet needs. Response: The Mount Vernon School District mandates that students use districtassigned devices for remote learning. According to grant training provided to the district, if students are required to use district-owned devices for remote learning, Chromebooks could be distributed to any student who did not have a district-assigned device that meets hardware standards. The standards used to assess the hardware included Chromebooks that were older than four years, unable to support the necessary software and digital learning tools, and devices at their end-of-life stage, meaning they no longer received automatic updates from Google. We assessed our inventory and supplied new Chromebooks to students based on our understanding of their needs. Chromebooks were only provided to students who lacked a device that met our hardware standards. Resolution: During this audit, the district learned that its understanding was inaccurate. However, we are confident our need exceeded our request. In May 2020, Page 71Office of the Washington State Auditor sao.wa.gov as directed by OSPI, the district conducted a survey which revealed that only 38% of our families had access to a device at home suitable for online learning. Given our students in poverty population was 4,365 during the 2022-23 school year, the 1,869 devices for which funding was requested only partially met our overall device needs. This audit has improved our understanding of the requirements related to verifying unmet needs. Moving forward, we will directly contact families and collect signatures to confirm their needs. These records will be attached to student profiles within our asset management system (Destiny) before ECF funded Chromebooks are assigned to them. Concern: Inventory records were incomplete, missing the names of 273 students assigned laptops funded by the ECF, thus failing to fully meet FCC documentation requirements. Response: The district acknowledges challenges related to student device assignment. Staff reductions and changes in our inventory and check-out processes necessitate updates and training, which is ongoing. We are committed to ensuring accurate and timely updates to our records. Resolution: A list of inventory discrepancies has been distributed, and action is being taken to update our records. To strengthen our existing systems, we will implement additional biannual training sessions with our inventory managers. These trainings will cover best practices for record keeping and emphasize the importance of maintaining accurate inventory records. We will conduct monthly audits of our records, and correction requests will be sent to individual sites to promptly address any information inaccuracies. Concern: MVSD lacked documentation to show that it only provided one device per student or location, leading to possible over-issuance of equipment. Response: While the district acknowledges the need to improve its student assignment inventory within Destiny, we have confirmed that only one device is assigned per student through the use of our additional inventory system (Google Workspace). Resolution: The district will enhance its inventory practices and explore additional redundancies to ensure effective contingencies if future data issues arise. Anticipated date to complete the corrective action: ● Unmet Needs Documentation: May 31, 2024 ● Inventory Update: June 20th, 2024 ● Staff Training: June 20th, 2024 (Ongoing)

View Audit 307176 Questioned Costs: $1

Corrective Action Plans

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