Corrective Action Plans

Finding 386396 (2023-001)

Material Weakness 2023

Galva Community Unit School District No. 224

IL

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

Condition - The District does not have internal controls in place to prevent expenditure reports being submitted that include expenditures that have not been spent, committed, or obligated. Plan - Management will implement internal controls to ensure proper expenditure reports are being submitted. ...

Condition - The District does not have internal controls in place to prevent expenditure reports being submitted that include expenditures that have not been spent, committed, or obligated. Plan - Management will implement internal controls to ensure proper expenditure reports are being submitted. Anticipated date of Completion - June 30, 2024. Name of Contact Person - Jerry Becker, Superintendent. Management Response - There is no disagreement. The District will implement internal controls to ensure expenditure reports are being submitted accurately.

View Audit 298743

Finding 386320 (2023-002)

Material Weakness 2023

Grand Valley State University

MI

Subrecipient Monitoring Material Weakness Reporting

When the University is unable to access the FFATA system, University staff will capture a screen snip of the error message and save it to the secure shared drive and follow-up with an email to the system’s help desk prior to the 30-day reporting requirement.

View Audit 298711

Finding 386303 (2023-002)

Significant Deficiency 2023

Marymount University

VA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement wi...

Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Acquired Isora GRC, a software tool to facilitate and document compliance with GLBA requirements and the corresponding NIST 800-171 information security framework. Management has also created an Enterprise Risk Management Committee which will incorporate compliance with GLBA as a top priority. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan by June 1, 2024, including decision regarding use of a third party or in-house resources to perform the risk assessment. Completion of 90% of action plan items within one year.

View Audit 298705

Finding 386302 (2023-002)

Significant Deficiency 2023

Calaveras County Water District

CA

Subrecipient Monitoring Period of Performance Reporting § 200.344

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to th...

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to the pass-through agency within 90 days of the end of the period of performance so the pass-through agency could prepare the closeout reporting within 120 days of the end of the period of performance. Criteria: The Notice of Funding Opportunity indicates: “In addition, pass-through entities are responsible for closing out their subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials within 90 calendar days of the period of performance end date. When a subrecipient completes all closeout requirements, pass-through entities must promptly complete all closeout actions for subawards in time for the recipient to submit all necessary documentation and information to FEMA during the closeout of the prime award.” Cause: The District’s staff were waiting for a requested extension for the period of performance from the pass-through agency and assumed the closeout reporting would not be necessary. Effect: The District is not in compliance with the terms and conditions of the federal award. Recommendation: We understand the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Views of Responsible Officials and Planned Corrective Actions: As indicated in the recommendation, the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Furthermore, on March 22, 2024, the District heard from the pass-through agency that FEMA received the requested extension, and it is in the queue for final approval and signature. The corrective action has been completed.

View Audit 298704

Finding 386296 (2023-001)

Significant Deficiency 2023

Fullerton Joint Union High School District

CA

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management § 200.303 § 200.439

Recommendation: We recommend the District design procedures and controls to ensure adequate prior approval of construction related expenditures charged to the Education Stabilization Fund program. Explanation of disagreement with audit findings: There isno disagreement with the audit finding. Distri...

Recommendation: We recommend the District design procedures and controls to ensure adequate prior approval of construction related expenditures charged to the Education Stabilization Fund program. Explanation of disagreement with audit findings: There isno disagreement with the audit finding. District Response: Name of the contact person responsible for corrective action: Ruben Hernandez, Assistant Superintendent, Business Services. Planned completion date for corrective action plan: Immediate.

View Audit 298701 Questioned Costs: $1

Finding 386267 (2023-002)

Significant Deficiency 2023

Hugo Public School District No. I-39, Choctaw County, Ok

OK

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

Hugo Schools will communicate to and require that construction contracts provide proof of compliance such as payroll documents or other certifying records. Hugo schools administration will ensure that construction companies under contract will abide by all rules mandated by the Davis Bacon Act

View Audit 298674

Finding 386244 (2023-004)

Material Weakness 2023

Lansing Housing Commission

MI

Subrecipient Monitoring HUD Housing Programs Material Weakness § 200.334

Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commis...

Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commission reviewed its policies and procedures and revised as needed to comply with federal regulations. The policies were presented and approved at the August 2023 board meeting. The Commission has sent revised policies to HUD for their review and approval. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666

Finding 386243 (2023-003)

Material Weakness 2023

Lansing Housing Commission

MI

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.306

Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, m...

Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, management was notified by HUD after completion of an on-site monitoring visit that the Commission's claimed matching expenses that were not adequately supported by source documentation. In response, management has placed in service additional controls to ensure the compliance requirements are being monitored and in place for the new program. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666 Questioned Costs: $1

Finding 386239 (2023-001)

None 2023

Upper Iowa University

IA

Subrecipient Monitoring

UIU has acknowledged the issues presented and will be working with Columbia Advisory group to address them. This contract began January of 2024, UIU commits to having the Executive Director of Information Technology Systems monitor requirements.

View Audit 298663

Finding 386233 (2023-001)

Significant Deficiency 2023

Ecological Society of America, INC

DC

Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Officials and Corrective Action: Vendors who are paid for grant funded activities will be checked on the SAM website to be sure they are not disbarred from doing business with the Federal government. A copy of the SAM check will be submitted as part of the check request process....

Views of Responsible Officials and Corrective Action: Vendors who are paid for grant funded activities will be checked on the SAM website to be sure they are not disbarred from doing business with the Federal government. A copy of the SAM check will be submitted as part of the check request process. No payments will be approved unless the paperwork includes a SAM verification check. This applies to vendors, subcontractors, hotels and other partners. It does not apply to travel reimbursements to individuals participating in workshops or other grant funded activities under the participant support line item.Program directors will complete the SAM check and submit the proof with each check request. The CFO and Executive Director will not approve or process check requests that do not include the SAM check. This has been added to the ESA Grant Accounting Policy and Procedures document.

View Audit 298659

Finding 386223 (2023-001)

Significant Deficiency 2023

Rockingham Nutrition and Meals on Wheels Program

NH

Subrecipient Monitoring Reporting Significant Deficiency § 200.328 § 200.329

Audit Finding Reference: 2023-001 Improve Controls Over Reporting Planned Corrective Action: 1. Request a list from DHHS of definitions of income types by program in the Quarterly Reports. Ensure that this list provides clarity on how to report income that is not explicitly tied to a single progr...

Audit Finding Reference: 2023-001 Improve Controls Over Reporting Planned Corrective Action: 1. Request a list from DHHS of definitions of income types by program in the Quarterly Reports. Ensure that this list provides clarity on how to report income that is not explicitly tied to a single program. 2. Review AFY23 and AFY24-to-date reports against these criteria (once received), and re-submit any reports which may need to be modified to comply with the guidance. 3. Going forward, the Quarterly Reports will be generated differently. The Client Services Manager will prepare actuals by program for number of clients and units. The Director of Administration will prepare actuals by program for income and expense. The Executive Director will compile the final report, which will not be submitted until both the Client Services Manager and Director of Administration have both checked the reports and electronically signed them. In the absence of specific guidance from DHHS to the contrary, any non-program-specific income will be allocated to programs by share of service units delivered. Planned Implementation Date of Corrective Action: 1. 3/29/24. 2. 6/30/24. 3. 4/15/24. Person Responsible for Corrective Action: Tim Diaz, Executive Director

View Audit 298652

Finding 386211 (2023-001)

Significant Deficiency 2023

Puerto Rico Traffic Safety Commission

PR

Subrecipient Monitoring Reporting

SEE THE AUDIT FINDING FOR CHART/TABLE

View Audit 298638

Finding 386210 (2023-002)

None 2023

Lebanon Valley College

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2023-002 – Enrollment Reporting Condition: The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with a status change out of a sample of 25 tested. Management Response: Management concurs with the finding. Views of Responsible Officials and...

Finding 2023-002 – Enrollment Reporting Condition: The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with a status change out of a sample of 25 tested. Management Response: Management concurs with the finding. Views of Responsible Officials and Corrective Action Plan: Lebanon Valley College uses the National Student Clearinghouse (NSC) to transmit enrollment information to the National Student Loan Data System (NSLDS). The College has verified that the student status changes were correctly submitted to the NSC, however the campus and program level information was not properly reflected in NSLDS and did not appear on the error report. This appears to be connected to the outages experienced by NSLDS. The College’s Financial Aid Office, along with the Registrar’s office will begin verifying the number of students on the NSLDS student roster each semester. The roster number will be compared to the number of students expected to be on the roster per Financial Aid data. Any discrepancies in this number will be researched and the discovery of any that did not reach NSLDS will be corrected in conjunction with the NSC and NSLDS. Anticipate Completion Date: April 1, 2024 Name of Responsible Person: Christopher Hanlon, Director of Financial Aid chanlon@lvc.edu

View Audit 298636

Finding 386208 (2023-001)

Significant Deficiency 2023

Lincoln County Board of Education

GA

Subrecipient Monitoring Reporting Special Tests & Provisions § 200.303

FA 2023-001 Strengthen Controls over Wage Rate Requirements Compliance Requirement: Special Tests and Provisions Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Departmen...

FA 2023-001 Strengthen Controls over Wage Rate Requirements Compliance Requirement: Special Tests and Provisions Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year: 2021) Questioned Costs: None Identified Prior Year Finding: Not Applicable Description: A review of construction-related expenditures charged to the Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating to ensure that Wage Rage Requirements were followed properly. Corrective Action Plans: The School District will review and update the current procedures to ensure that the Wage Rate requirements are met. Estimated Completion Date: June 30, 2024 Contact Person: Dr. Samuel P. Light, Superintendent Telephone: (706) 359-3742 Email: slight@lcboe.us

View Audit 298629

Finding 386170 (2023-004)

None 2023

Municipality of Culebra

PR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

The quarterly reports mentioned in the findings were prepared and submitted to the Puerto Rico Housing Department for review and evaluation.

View Audit 298592

Finding 386151 (2023-002)

Significant Deficiency 2023

Bayaud Enterprises, Inc.

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.333

We will review processes uon termination to ensure all necessary documentation is maintained.

View Audit 298562

Finding 386135 (2023-002)

Significant Deficiency 2023

Delta Research and Educational Foundation

DC

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.309 § 200.461

Views of Responsible Officials: Grant funds received pursuant to a period of performance or an approved drawdown or reimbursement request will be expended as specified in the request. When Federal grants are funded in advance, rather than on a reimbursement basis, the Foundation will minimize the ti...

Views of Responsible Officials: Grant funds received pursuant to a period of performance or an approved drawdown or reimbursement request will be expended as specified in the request. When Federal grants are funded in advance, rather than on a reimbursement basis, the Foundation will minimize the time elapsing between the receipt of Federal grant funds and disbursement of such funds for their approved purpose. We will implement procedures to ensure that expenses are recorded or accrued properly.

View Audit 298546 Questioned Costs: $1

Finding 386118 (2023-001)

Material Weakness 2023

Hydro-Eakly Independent School District #11

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

The School Superintendent will review all projects funded by Federal funds to determine if any projects are considered construction projects. The Superintendent will require all such contracts to include prevailing wage clauses to ensure that federal wage rates and fringe benefits, are met, as requ...

The School Superintendent will review all projects funded by Federal funds to determine if any projects are considered construction projects. The Superintendent will require all such contracts to include prevailing wage clauses to ensure that federal wage rates and fringe benefits, are met, as required by the Davis-Bacon Act. The Superintendent will review weekly payroll reports provided by the contractor to ensure adherence to the contract clauses. The Superintendent will survey the job site weekly to ensure that required work site notices are posted.

View Audit 298524

Finding 386110 (2023-002)

Significant Deficiency 2023

Des Moines Independent Community School District

IA

Subrecipient Monitoring Cash Management Reporting

Corrective Action: After the Food and Nutrition Director reviews the monthly claims, she will send an email noting her approval, before the claim is submitted to the state. This email approval will be attached to the journal entry support that is posted in the financial system when recording the rev...

Corrective Action: After the Food and Nutrition Director reviews the monthly claims, she will send an email noting her approval, before the claim is submitted to the state. This email approval will be attached to the journal entry support that is posted in the financial system when recording the revenue. Contact Person: Amanda Miller, Director of Food & Nutrition Services and Logistics / Ray Serrano - Accountant Anticipated Completion Date: June 30, 2024

View Audit 298501

Finding 386108 (2023-003)

Material Weakness 2023

Madison County, Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

The County is aware of the above finding and has adjusted our procedures related to disbursing federal funds to subrecipients. We have changed to a cost reimbursement basis for disbursing the federal funds to subrecipients. We currently receive supporting documentation prior to payment.

View Audit 298495 Questioned Costs: $1

Finding 386104 (2023-001)

Significant Deficiency 2023

Northwest Mississippi Community College

MS

Student Financial Aid Subrecipient Monitoring Internal Control / Segregation of Duties

Name Connie Joseph Title Controller Phone (662) 562-3292 Email cjoseph@northwestms.edu Finding 2023-001: U.S. Department of Education-Student Financial Assistance Management is in the process of developing a written information security program. Anticipated Completion Date: Prior to June ...

Name Connie Joseph Title Controller Phone (662) 562-3292 Email cjoseph@northwestms.edu Finding 2023-001: U.S. Department of Education-Student Financial Assistance Management is in the process of developing a written information security program. Anticipated Completion Date: Prior to June 30, 2024

View Audit 298492

Finding 386101 (2023-002)

Significant Deficiency 2023

Wellspace Health

CA

Subrecipient Monitoring Internal Control / Segregation of Duties

Corrective Action Plan: The Organization will strengthen procedures to ensure discounts for sliding fee is applied consistently and accurately. Immediately, the Organization will conduct monthly application audits. An audit of 25 sliding fee application forms completed in the month prior will be exa...

Corrective Action Plan: The Organization will strengthen procedures to ensure discounts for sliding fee is applied consistently and accurately. Immediately, the Organization will conduct monthly application audits. An audit of 25 sliding fee application forms completed in the month prior will be examined for accuracy, along with their supporting data. All information from these applications will be cross‐verified in NextGen. The results from the sliding fee monthly audits will be monitored and reported quarterly at the Quality Assurance and Quality Improvement meetings. This has continued to occur monthly. We will be implementing a workflow adjustment stating all Slide applications will be noted in the system with a 30day expire date. This will ensure the staff will be able to notify the patient they would need to begin the process over and present the supporting documentation. Once the documentation is received the timeframe will extend to the one year. Furthermore, the Organization will continue the practice of conducting skills assessments at the start of the year and once more in July. These assessments are crucial as they help pinpoint staff members who might benefit from refresher training. Moreover, a meeting has been scheduled to finalize the days and times for virtual sliding fee application training. This training, aimed at all staff who handle a sliding fee form, will be spread out over four weeks, with one session per week lasting an hour. Additionally, the Organization will introduce a sliding fee training video to the new employee orientation. After completing their NextGen training, staff will receive this training video via email. Furthermore, this video will also be sent to all health center leadership to be utilized at the health center level. Estimated completion date: September 30, 2024 Contact person: Shannon Potter, Deputy Chief of Business Service

View Audit 298487

Finding 386098 (2023-001)

Significant Deficiency 2023

Granite United Way

NH

Reporting Subrecipient Monitoring

Granite United Way will establish additional policies and procedures to ensure that all Federal awards are identified and reported accurately on the SEFA and that subrecipient amounts are reconciled with the expenditures in the general ledger. The Chief Impact Officer will now prepare the initial dr...

Granite United Way will establish additional policies and procedures to ensure that all Federal awards are identified and reported accurately on the SEFA and that subrecipient amounts are reconciled with the expenditures in the general ledger. The Chief Impact Officer will now prepare the initial draft of the SEFA, including federal agency assistance listing numbers, pass-through entities, program names and subrecipient information. This draft will be reviewed by the Contracts Specialist for accuracy and comparison with the existing contracts for accurate information. The Chief Financial Officer will review the draft SEFA and compile the general ledger transactions, which will have already been reconciled with the invoice submissions to the state of NH. Cover sheets for check requests will differentiate between Subawards/Subrecipients and Procurement Contracts/Contractors when designated to the line item names Subcontracts/Agreements to ensure that procurement contracts/contractor expenses are not misclassified on the SEFA as Subawards/Subrecipient expenses.

View Audit 298472

Finding 386097 (2023-001)

Significant Deficiency 2023

City of Portsmouth

NH

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting

The City of Portsmouth, New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with th...

The City of Portsmouth, New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2023-001 Community Development Block Grant - Assistance Listing Number 14.218 Recommendation: We recommend the City enhance internal controls and procedures to comply with all FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Some FFATA reports were not entered timely into FSRS in FY 23. This was due to an incomplete understanding about the requirement as well as no FFATA reporting requests by the federal granting agency (HUD) to the City. All required FFATA reports were entered into the FSRS after the deadlines, and City staff responsible for FFATA reporting have completed additional training on the requirements. We do not anticipate untimely reports to the FSRS in the future. Name(s) of the contact person(s) responsible for corrective action: Elise Annunziata, Community Development Director Planned completion date for corrective action plan: All required FFATA reports were already entered into the FSRS, and City staff responsible for FFATA reporting have completed additional training on the requirements. We do not anticipate untimely reports to the FSRS in the future.

View Audit 298471

Finding 386093 (2023-003)

Significant Deficiency 2023

Municipality of Rio Grande

PR

Subrecipient Monitoring Reporting Significant Deficiency

As an internal control, the accountant in charge of the program will keep monthly reports of the expenditures to expedite the collection of information and submit timely and complete reports. The documentation of the reports will be physically filed and digitally saved in the accounting files. Impl...

As an internal control, the accountant in charge of the program will keep monthly reports of the expenditures to expedite the collection of information and submit timely and complete reports. The documentation of the reports will be physically filed and digitally saved in the accounting files. Implementation Date: Fiscal Year 2023-2024 Responsible Person: Mr. Ángel L. Reyes Matos, Finance Director

View Audit 298462

Corrective Action Plans

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