Corrective Action Plans

Finding 387592 (2023-002)

Significant Deficiency 2023

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the neces...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the necessary procedures for returning Title IV funds. Implementation Date: 6-23-23

View Audit 299712

Finding 387564 (2023-001)

None 2023

Edward Waters University

FL

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2023-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: a) Seven (7) out of 25 students had credit...

Finding 2023-001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: a) Seven (7) out of 25 students had credit balances created by Title IV funds that were not refunded to the student or a Title IV program within the allotted 14 days. All seven (7) students were later refunded shortly after the allotted 14 days. b) Two (2) students were not paid Federal Work-study funds according to the total hours worked and the correct amount paid per hour. Questioned costs were $490. The two (2) students were subsequently paid the correct amounts. Corrective Action – We concur with the auditor’s finding. EWU’s student subsidiary ledger has been fully converted into our newly purchased global ERP system, Colleague, for fiscal year 2024. In the past, there were several manual processes amongst various departments to ensure the disbursement of student refunds. Our new system integrates all the student financial information allowing us to streamline our process for more efficiency. This process digitizes our student refund disbursements allowing for students to receive eRefunds. In addition, the new system allows for the Office of Student Accounts to exercise full oversight of the student refund process. Subsequently, our new system greatly enhances the University’s ability to provide more timely disbursements of student refunds. In addition to the newly adopted student refund process, the business office has since updated the Business and Finance organizational structure to provide an additional oversight over payroll disbursement to ensure students are receiving timely and accurate disbursements from the Federal work-study program. The business office reconciles with the financial aid department monthly on all financial aid awards.

View Audit 299677 Questioned Costs: $1

Finding 387563 (2023-003)

None 2023

Trinity Health

MI

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.403

We agree with the recommendation that expenses should have been reviewed not only in total but should also been reviewed under the two categories of expenses (1) General and Administrative Expenses and (2) Health Care-Related Expenses and the additional subcategories of expenses as defined in HRSA’s...

We agree with the recommendation that expenses should have been reviewed not only in total but should also been reviewed under the two categories of expenses (1) General and Administrative Expenses and (2) Health Care-Related Expenses and the additional subcategories of expenses as defined in HRSA’s Post-Payment Notice of Reporting Requirements for PRF grants to ensure that individual expenses were not double counted. While management will attempt to see if we can refile expenses in the HRSA PRF portal to clearly show that more than enough qualified expenses exist to apply to funding received under both PRF grants and FEMA awards, our understanding is that the PRF portal is closed and restatements cannot be made. Management believes while expense reporting was duplicated for both of these funding sources, because more than enough expenses exist in total to be applied to both sources of funding, this is a reporting matter only and no funds need to be returned under either program. Further, there was numerous and changing guidance from HRSA as to whether expenses needed to be applied to PRF grants prior to applying lost revenue to these grants. Effective with PRF Reporting Period 2, lost revenue was first applied to PRF grants. Fresno did not apply expenses incurred to PRF grants after the date of June 30, 2021, thus this issue does not exist for costs incurred during periods subsequent to June 30, 2021.

View Audit 299676 Questioned Costs: $1

Finding 387491 (2023-002)

Material Weakness 2023

Wake Forest University

NC

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

The organization has assigned a full-time employee with prior experience in subrecipient monitoring to own this process and will make additional resources available as necessary. Organizational leadership has reviewed the subrecipient monitoring policy to verify the proper steps and processes are in...

The organization has assigned a full-time employee with prior experience in subrecipient monitoring to own this process and will make additional resources available as necessary. Organizational leadership has reviewed the subrecipient monitoring policy to verify the proper steps and processes are in place to ensure compliance.

View Audit 299671

Finding 387471 (2023-003)

Material Weakness 2023

Community Partners

CA

Questioned Costs Subrecipient Monitoring Material Weakness § 200.332 § 200.501

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient...

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

View Audit 299626 Questioned Costs: $1

Finding 387470 (2023-002)

Significant Deficiency 2023

Community Partners

CA

Questioned Costs Subrecipient Monitoring § 200.332

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient...

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

View Audit 299626 Questioned Costs: $1

Finding 387452 (2023-008)

Material Weakness 2023

Lewis Cass Schools

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, pre...

FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows:  The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain expenditures for the reporting period, however according to the School Corporation's records there were expenditures for ESSER I and ESSER II during this period.  The ESSER I, Year 3, ESSER II, Year 2, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To address and ensure Education Stabilization Funds are properly reported by the treasurer the treasurer will print out the form that was completed by the treasurer and must be signed by the superintendent or department head for review before submittal and filed for record keeping. Anticipated Completion Date: 3/11/2024

View Audit 299602

Finding 387446 (2023-007)

Material Weakness 2023

Lewis Cass Schools

IN

Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313

FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or...

FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or the pass-through entity. In addition, with prior approval by the ED or the passthrough entity, recipients and subrecipents may use ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. The School Corporation had not established policies or procedures to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirements. The School Corporation purchased two servers and completed a HVAC project using ESF funds however those items were not included on property records that included all the required information (including a description, source of funding, percentage of federal participation, location, and use and condition of the property). In addition, a physical inventory was not completed after the equipment was purchased. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure property records are maintained for equipment and real property purchased with federal funds and a physical inventory to be completed at least every two years. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Lewis Cass does have an asset management documentation but it has not been updated since October 2020. Lewis Cass has been actively pursuing an asset management vendor to perform a thorough review and update our current property. The items listed on this finding have been add to the property records. Lewis Cass has the task of finding a new asset management firm and update property records. This task will be completed by fiscal year 2025. Anticipated Completion Date: 6/30/2024

View Audit 299602

Finding 387438 (2023-005)

Material Weakness 2023

Lewis Cass Schools

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly de...

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly designed and implemented internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles. There was not an oversight or review to ensure that the vendor claims were properly approved. The vendor claims were reviewed and approved by the department head and the Treasurer. However, during our review of the 40 vendor claims, there were 17 Accounts Payable Vouchers that were not approved by the department head and the Treasurer. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. To address and ensure vendor claims are properly approved by the department head and treasurer Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To ensure the internal control process is currently being followed, several vendor claims were pulled and reviewed. This review found there to be no vendor claims that were not verified by the department head and treasurer. Anticipated Completion Date: July 1, 2023V

View Audit 299602

Finding 387435 (2023-004)

Material Weakness 2023

Lewis Cass Schools

IN

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

FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured...

FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. Prior to entering subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non‐procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the audit period, sufficient internal controls were deficient in specific areas which prevented comprehensive program compliance. To address and rectify the issues as presented, vendor verification will be completed on an annual basis. The Food Service Director and Treasurer will confirm through documentation that vendors are not suspended or debarred using resources available. Documentation representing oversight and compliance will be retained and referenced as needed for verification. Anticipated Completion Date: Q2 2024 (6/30/2024)

View Audit 299602

Finding 387425 (2023-023)

Material Weakness 2023

Upshur County Board of Education

WV

Questioned Costs Equipment & Real Property Management Subrecipient Monitoring § 200.313 § 200.439

Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United State...

Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the requirements applicable to the ESSER program.

View Audit 299573 Questioned Costs: $1

Finding 387421 (2023-022)

Material Weakness 2023

Upshur County Board of Education

WV

Questioned Costs Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.334 § 200.403

Finding # 2023-022 Title of Finding Activities Allowed or Unallowed Contact Person Jody Johnson, Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board has developed procedures to ensure that all purchase orders are approved before ord...

Finding # 2023-022 Title of Finding Activities Allowed or Unallowed Contact Person Jody Johnson, Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

View Audit 299573 Questioned Costs: $1

Finding 387390 (2023-001)

Significant Deficiency 2023

Women in Safe Homes, Inc.

AK

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expe...

Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expenditure approval process, as well as the process for maintaining records supporting all transactions. The policies in place require WISH management to approve all expenditures utilizing a requisition request form which includes a signature field for the initiator, a supervisor, and the Executive Director. WISH management will mandate that all requisition forms are signed (physically or digitally) to ensure compliance with the policy. In order to ensure compliance, WISH will conduct sessions to review the policies with staff and assign a team member to monitor adherence to the policies. Additionally, WISH policies require expenditure support for each transaction including physical and digital receipts and invoices. WISH management will conduct sessions to ensure knowledge of the existing procedures with staff. WISH will assign a team member to review compliance on a monthly basis to ensure compliance. Proposed Completion Date: June 30, 2024

View Audit 299565

Finding 387378 (2023-005)

Material Weakness 2023

Union-North United School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.328

Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a time...

Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Superintendent, Dr. Angela Piazza and the Director of Grants, Eric Knebel. The corrective action will be implemented starting immediately.

View Audit 299547

Finding 387370 (2023-003)

Material Weakness 2023

Union-North United School Corporation

IN

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to...

Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to track the ESF activity for each year. The Treasurer will use the underlying funds ledgers to then determine the amount of ESF draws to request in each respective period. This will ensure that funds are not drawn in advance of expenditures taking place. Employee contracts will be maintained on file and when applicable, timecards will be completed and reviewed timely to ensure the time recorded to the ESF grant is accurate. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel and Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.

View Audit 299547 Questioned Costs: $1

Finding 387353 (2023-001)

None 2023

Georgian Court University

NJ

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.414 § 200.502 § 200.510

Contact Person: Kristen Nagle, Assistant VP Finance/Controller Corrective Action: The University Finance department has updated their policies and procedures to ensure that the SEFA is being prepared in accordance with required guidelines. We will work closely with our grants department to ensure al...

Contact Person: Kristen Nagle, Assistant VP Finance/Controller Corrective Action: The University Finance department has updated their policies and procedures to ensure that the SEFA is being prepared in accordance with required guidelines. We will work closely with our grants department to ensure all required elements are properly identified and disclosed. Anticipated Completion Date: July 1, 2024

View Audit 299541

Finding 387349 (2023-003)

Material Weakness 2023

The Pennsylvania State University

PA

Questioned Costs Student Financial Aid Subrecipient Monitoring

Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented ...

Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists. Contact person responsible for corrective action: Melissa J. Kunes, Assistant Vice President for Enrollment Management and Executive Director for Student Aid Anticipated Completion Date: 03/31/2024

View Audit 299535 Questioned Costs: $1

Finding 387303 (2023-001)

Significant Deficiency 2023

Southwestern Illinois College Community College District #522

IL

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the Col...

2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the College has updated the WISP with all required elements and will incorporate into board policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name(s) of the contact person(s) responsible for corrective action: Linda Andres Planned completion date for corrective action plan: 6/30/24

View Audit 299518

Finding 387183 (2023-001)

Significant Deficiency 2023

Pontifical Catholic University of Puerto Rico

PR

Subrecipient Monitoring § 200.303

Management has already written the basic Security of Information Plan as required by 16 C.F.R. 313.3 and 313.4. A framework for personnel training is being developed, as well as a reporting dateto the Board of Trustees has been set before the end of the current fiscal year. A risk assessment plan is...

Management has already written the basic Security of Information Plan as required by 16 C.F.R. 313.3 and 313.4. A framework for personnel training is being developed, as well as a reporting dateto the Board of Trustees has been set before the end of the current fiscal year. A risk assessment plan isbeing developed and the University is in the process of contracting an independent third party to conductmonitoring and risk assessment of the data security plan, reporting at least four times per year. Correctionsor modifications to the plan or the established safeguards will be implemented based in said monitoring processes. The person designated to be in charge is Dr. Edgardo Aviles Garay, director of the Information Tecnologies and Telecomunications Department, under the guidance of the Vicepresident of Administrative Affairs. The corrective plan should be completed by June 30, 2024.

View Audit 299450

Finding 387169 (2023-006)

Significant Deficiency 2023

Fresno Pacific University and Subsidiaries

CA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: A CIS Risk Assessment, Implementation Goup 1 (IG I), has been completed and a detailed plan with 25 Action Items is being worked on which includes a step-by-step plan to obtain full GLBA compliance. The estimated schedule for addr...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: A CIS Risk Assessment, Implementation Goup 1 (IG I), has been completed and a detailed plan with 25 Action Items is being worked on which includes a step-by-step plan to obtain full GLBA compliance. The estimated schedule for addressing the GLBA compliance items specifically called out in the finding is as follows:  Written Information Security Program - Q2 2024  Risk Assessment and safeguards - Risk Assessment is complete, Q2 2025 to address 25 Action Items  Vendor management policies - Q3 2024  Incident response plan - Q2 2024  Written Annual Report to the board - Q4 2024 Person Responsible for Corrective Action Plan: Brad Barker, Chief Information Officer Anticipated Date of Completion: Q2 2025 for Full GLBA Compliance

View Audit 299440

Finding 387162 (2023-003)

Material Weakness 2023

Fresno Pacific University and Subsidiaries

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Ins...

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Institution Required to Take Attendance to an Institution Not Required to Attendance in May 2023. Additional reports were created to accommodate this change and identify withdrawals. Staff attended the NASFAA R2T4 training course. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: November 2023

View Audit 299440

Finding 387148 (2023-004)

Significant Deficiency 2023

City of Bell, California

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2023-004 Procurement and Suspension and Debarment – Internal Control and Compliance over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City staff...

Finding 2023-004 Procurement and Suspension and Debarment – Internal Control and Compliance over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City staff will access SAM.Gov to check for possible party ineligibility following receipts of an offer or proposal and again, immediately before making the award. For every CIP project that is advertised for bids, the Engineering Division’s is currently preparing a detailed analysis of the bid amounts received that includes a check of the low-bid contractor’s license, insurance, and references prior to the award of contract. In addition, staff verifies that neither the contractor nor any of its key personnel appear on the Federal or State debarment lists. All of this documentation is then typically compiled in the project file in both hardcopy and electronically. However, to ensure consistency that all pre- and post-construction documentation is properly filed for each project, staff will utilize a project checklist modeled after Caltrans’ “Exhibit 19 - Construction Review Checklist” from its Local Assistance Program Manual as applicable. Responsible Person: Director of Public Works Expected Implementation Date: July 1, 2024

View Audit 299436

Finding 387110 (2023-003)

Material Weakness 2023

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Subrecipient Monitoring Cash Management

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 ...

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: OSFP was notified of the error in reporting the correct cost of attendance to the Common Origination and Disbursement (COD) system and the code was changed to prevent the error from reoccurring. The correct cost of attendances are now being reported to COD. A testing plan has been developed that includes confirmation that all system start and end dates align with the University’s published academic calendar. Anticipated Completion Date: Completed

View Audit 299417

Finding 387083 (2023-001)

Material Weakness 2023

Housing Authority of the City of Everett

WA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We starte...

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We started the process on 6/29/2022 to replace our Housing Inspector that left EHA 5/04/2022. The person that filled this Housing Inspector position started at EHA on 1/05/2023, completed training and began taking on an inspection workload in February 2023. • In March 2023, twenty-five (25) staff in EHA’s Housing Management Department attended an HQS inspections training. EHA Housing Management staff began completing initial and annual HQS inspections at EHA PBV properties on 7/01/2023. • EHA budgeted for a second Housing Inspector position in EHA’s FYE2023 budget. We started the process to hire the second Housing Inspector on 7/13/2023. The person that filled this second Housing Inspector position started at EHA on 9/19/2023, completed training and began taking on an inspection workload at the end of October 2023. • EHA budgeted for an Inspections Coordinator position in EHA’s FYE2023 budget. We started the process to hire the Inspections Coordinator on 8/14/2023. The person that filled the Inspections Coordinator position started on 11/06/2023. • On 10/30/2023, EHA’s Executive Director decided to add a third Housing Inspector to the EHA inspections team to assist with the backlog of biennial inspections. We started the process to hire the third Housing Inspector on 10/31/2023. The person that filled this third Housing Inspector position started in the position on 1/16/2024, completed training and began taking on an inspection workload in February 2024. • On 2/23/2024, an HCV Manager was appointed to supervise the inspections team (three Housing Inspectors and one Inspections Coordinator), to provide increased oversight over EHA’s inspections workload. The HCV Manager is responsible for monitoring progress towards addressing the biennial inspections backlog, delegating inspections workload to the inspections team, and providing guidance and support to the inspections team. The HCV Manager meets with the inspections team on a weekly basis as well as conducts individual check-ins with all inspections team members. Our increased inspections capacity has allowed us to make significant progress on addressing the pandemic-caused backlog of biennial inspections. Based on our expanded internal staffing resources, we expect to complete all late biennial inspections by 12/31/2024.

View Audit 299403

Finding 387043 (2023-006)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Subrecipient Monitoring Eligibility Matching / Level of Effort / Earmarking § 200.303

2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities particip...

2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for the Youth program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth (Youth In or Youth Out) is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison. For the Adult Program, the Board has implemented internal controls to ensure each applicant completes the applications and to determine if they are eligible for the programs the Board offers. Our Business Services Manager reviews each application taken by the Board’s Career Services Coordinator and ensures they are in the correct program by the application.

View Audit 299385

Corrective Action Plans

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