Corrective Action Plans

Finding 390504 (2023-016)

Material Weakness 2023

NH

Reporting Subrecipient Monitoring

The Department underwent turnover and medical issues during the reporting period. The Department has hired additional program staff and arranged for annual training through a federal contractor to assist in reporting requirements. The Department is also in the process of procuring a new weatherizat...

The Department underwent turnover and medical issues during the reporting period. The Department has hired additional program staff and arranged for annual training through a federal contractor to assist in reporting requirements. The Department is also in the process of procuring a new weatherization and fuel assistance system which will assist in providing timely and accurate reporting data. The Department is also reviewing and updating policies and procedures, to include cross training and turnover contingencies.

View Audit 301259

Finding 390502 (2023-015)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.332 § 200.414 § 200.521

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department ...

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department concurs with paragraph B - The finding was a result of personnel turnover and medical issues. The Department has hired and trained additional program staff and updated policies to ensure programmatic monitoring and subsequent reports are done in a timely manner. The Department partially concurs with paragraph C. Fiscal monitoring was done for all 3 subrecipients during the federal program year. However, 1 subrecipient monitoring fell outside the state fiscal year so was not covered during the audit period. The Department has changed the wording on its risk assessment procedures to ensure no misinterpretation of the timeframe each subrecipient will be monitored in accordance with its risk assessment. The Department has also changed the requirements of the frequency of fiscal monitoring in each of the risk assessment categories. The Department Concurs with paragraph D – The Department is reviewing policies and procedures and will update them to ensure compliance with 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.521. The Department also created a tracking mechanism to ensure we receive, review, and issue management decisions (if required) in a timely manner. The Department concurs with Paragraph E - The Department is reviewing policies and procedures for both reporting and subrecipient monitoring to ensure data is tested and verified. The Department has already gained increased access to data in current software and is in the process of selecting a vendor for new software that will provide more testing and enhanced internal controls.

View Audit 301259

Finding 390494 (2023-011)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the ...

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the requested subrecipient monitoring. The Department provides annual training on the Subrecipient Monitoring Policy. We will reinforce the requirements of the Policy and the ramifications for the Department for the non-compliance in this year’s annual training. Regarding the incomplete Risk Assessment Tool, we will update the Subrecipient Monitoring Policy to include a secondary review of the Tool prior to implementation, as part of our internal controls. Condition B: DHHS does not concur. The Department employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. The Department’s review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system Standard language for the submission of expenditure detail is included in all templates for legal agreements. These subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient monitoring. Subrecipient monitoring activities are memorialized in the legal agreements. The Risk Assessment Tool provides a space for the monitoring activities to be selected, however, the Subrecipient Monitoring Policy does require the memorialization of the activities on the Tool for compliance, only to be memorialized in the legal agreement. Condition C DHHS partially concurs. As the subrecipient’s audit report had no findings, we are not required to issue a management decision letter. However, we will be updating our procedures to include contacting the vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

View Audit 301259

Finding 390492 (2023-010)

Material Weakness 2023

State of New Hampshire

NH

Reporting Subrecipient Monitoring Material Weakness § 200.303

This function (FFATA reporting) has now been designated to our Federal Reporting Group, which will allow for redundancy in personnel. A new policy and procedure, which will include internal controls, will be developed and implemented.

View Audit 301259

Finding 390480 (2023-008)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring Reporting Material Weakness § 200.303

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission a...

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission and a secondary certification for accuracy verification, and a division wide process for FFATA filing and verification. Division wide training occurred on October 26, 2023. Due to grant award notification (GAN) changes and development within our grants management system (GMS), the FFATA process has also been developing and shifting; therefore the FFATA process will be revisited annually and updated as needed. A revised procedure for FFATA reporting will be completed prior to additional training being offered. To ensure that processes are being followed, newly hired staff is trained appropriately, and updates to the GAN process are considered within the FFATA process we will hold another training this spring, March 14th, 2024, prior to new subawards being issued.

View Audit 301259

Finding 390477 (2023-005)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.303 § 200.332 § 200.414 § 200.521

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 20...

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 2022-002, the DAS had strengthened internal controls related to the review and validation of amounts reported by individual state agencies as pass through expenditures. This included an additional control specifically verifying SLFRF pass through expenditures reported by each agency. The DAS will offer additional training relative to identification and reporting of subaward expenditures in its annual statewide Single Audit training and re-evaluate the precision of execution of controls over the validation of pass through reporting in assembling the SEFA for fiscal year 2024. Corrective Action Planned (Conditions B through E): The State largely concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. The State has already begun this corrective action plan with the agencies. With regards to condition C, for a. and b. for payments by agencies, there are standard procedures for review and authorization of invoices and payments and those payments are documented. For c. The State has already implemented an agency wide framework for subrecipient monitoring. The State will provide re-training for those agencies that had not properly documented monitoring as outlined by the subrecipient risk assessments and ensure monitoring reports are documented. With regards to condition D, The State has already implemented an agency wide framework to help ensure policies and procedures are in place concerning Uniform Guidance Reports. We will work those agencies that had not documented the date received and the review of the Uniform Guidance Reports to ensure written documentation occurs. Where findings have been reported in the Uniform Guidance Report, ensure timely Management Letters are documented and provided with the summary review of Uniform Guidance Report.

View Audit 301259

Finding 390476 (2023-004)

Material Weakness 2023

State of New Hampshire

NH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts,...

Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts, including contracts deemed subawards, greater than $10,000 are subject to legislative and executive branch approval prior to final execution. The resulting contracts are managed within the State’s financial system using purchase orders which in turn encumber funds. To support the testing of procurements, the State provided a detailed listing of purchase orders initiated during the audit period and in doing so clearly expressed the resulting population would include contracts considered subawards. Accordingly, the State deems the portion of selections identified as subawards to be reasonable and appropriate given the population sampled. However, the DAS will re-evaluate the precision of execution of controls over the validation of the subrecipient population in fiscal year 2024. Corrective Action Planned (Condition B): The State concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies maintain and document the search of SAM.gov for suspension and debarment.

View Audit 301259

Finding 390438 (2023-001)

Significant Deficiency 2023

Oregon Tech

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting i...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390428 (2023-004)

Material Weakness 2023

Delaware State University

DE

Reporting Subrecipient Monitoring Material Weakness § 200.303 § 200.502 § 200.510

2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: ...

2023-004 Student Financial Aid Cluster – Schedule of Expenditure of Federal Awards (SEFA) Recommendation: We recommend that the University reevaluate its policies and controls related to the preparation of the SEFA to ensure its complete and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director will reevaluate the controls and set in place policies and procedures for SEFA completion. Name(s) of the contact person(s) responsible for corrective action: Director of Restricted Funds Accounting, Symone Merritt Planned completion date for corrective action plan: October 2024

View Audit 301226

Finding 390416 (2023-009)

Material Weakness 2023

Delaware State University

DE

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation o...

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Information Technology is reviewing the written policies and procedures needed to safeguard the University’s applications and data. This includes all 3rd party developed/ implemented applications as well. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russel Weaver & VP/ Chief Information Officer, Darrell McMillion. Planned completion date for corrective action plan: June 2024

View Audit 301226

Finding 390385 (2023-001)

Significant Deficiency 2023

Fresno Madera Area Agency on Aging

CA

Subrecipient Monitoring § 200.332

The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon a...

The Agency agrees with the finding. It has been seeking qualified fiscal staff to address the staffing needs. A new fiscal staff member has been hired and will start employment on 4/2/24. The requisite fiscal reviews of subrecipients has been initiated with the intention of completing them as soon as practical.

View Audit 301199

Finding 390372 (2023-001)

Material Weakness 2023

Collins Career Center

OH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.320 § 200.327

At the beginning of the project the Center did not plan on using federal grant funds. At the conclusion of the project, it was determined that the project could be paid for by federal funds.

View Audit 301193

Finding 390303 (2023-001)

Significant Deficiency 2023

Office of Hawaiian Affairs State of Hawaii

HI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.319 § 200.320 § 200.327

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This ...

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This procedure was implemented on a go forward basis on March 13, 2024.

View Audit 301164

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390269 (2023-004)

Significant Deficiency 2023

Commonspirit Health

IL

Subrecipient Monitoring § 200.303

REFERENCE: 2023-004 – Subrecipient Monitoring Research and Development Cluster (Assistance Listing Nos. 12.420, 93.394, 93.650, 93.853, 93.866) Federal Grantor: U.S. Department of Defense, U.S. Department of Health and Human Services Facility: St. Joseph’s Hospital and Medical Center Finding: Whil...

REFERENCE: 2023-004 – Subrecipient Monitoring Research and Development Cluster (Assistance Listing Nos. 12.420, 93.394, 93.650, 93.853, 93.866) Federal Grantor: U.S. Department of Defense, U.S. Department of Health and Human Services Facility: St. Joseph’s Hospital and Medical Center Finding: While St. Joseph’s Hospital and Medical Center has controls in place to review and approve invoices prior to payment, the review was not precise enough to ensure duplicate invoices are not paid to subrecipients. St. Joseph's Hospital and Medical Center approved and paid duplicate invoices for 2 out of 35 selections. This error was identified by St. Joseph's and they are actively working on getting a refund from the subrecipient. The duplicate payments charged to the grant were $5,514. Corrective Action Plan: St. Joseph’s Hospital and Medical Center research administration identified the duplicate invoice request from the subrecipient and have been actively working with the subrecipient to receive a refund and adjust the federal reimbursement request. New procedures have been implemented for research administration to notify research finance of any incorrect payments and research finance will accrue for the adjustment. Person Responsible: Tomas Cortez, Grant Accounting Manager – St. Joseph’s Hospital and Medical Center Expected Completion: June 2024

View Audit 301158

Finding 390267 (2023-004)

None 2023

The Houston Food Bank and Subsidiaries

TX

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule. In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance depar...

Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule. In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance departments, one in Accounting and one in Partner Services, have been fully established to monitor compliance.

View Audit 301154

Finding 390261 (2023-102)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Eligibility Student Financial Aid § 200.303 § 200.513 § 200.521

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and...

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025 P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $5,612 Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Anticipated completion date: June 30, 2024 The District is aware of the importance of maintaining effective internal control over federal awards and ensuring compliance with applicable federal regulations. The District will work with the TRIO project directors at each college to review and revise existing procedures to require an independent and knowledgeable employee review and approve student eligibility determinations prior to awarding program services to them. The District will enhance communication and training efforts to ensure that the TRIO project directors and all staff administering the TRIO programs understand all eligibility requirements and related district-wide policies and procedures. As of March 21, 2024, the questioned costs for the program have been resolved.

View Audit 301142 Questioned Costs: $1

Finding 390260 (2023-103)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

Assistance Listing number and name: 84.031 Higher Education – Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096 and P031S200081, October 1, 2020 through September 30, 2025 P031C2...

Assistance Listing number and name: 84.031 Higher Education – Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096 and P031S200081, October 1, 2020 through September 30, 2025 P031C210057 and P031C210077, October 1, 2021 through September 30, 2026 P031S220015 and P031S220179, October 1, 2022 through September 30, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Reporting and special tests and provisions Questioned costs: Unknown Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Diana Aguirre-Rosales, Fiscal Director, Maricopa Community Colleges Foundation Anticipated completion date: December 31, 2024 The District is aware of the importance of ensuring that reports submitted are reviewed for accuracy prior to submission and implemented new processes for report review and submission in November 2023. On February 7, 2024, after multiple requests, the U.S. Department of Education (ED) provided the District with access to ED’s reporting system, which will allow the District to timely submit reports. The District will coordinate with the Maricopa Community Colleges Foundation to ensure that the endowment contracts include all necessary federal regulation information and that the investment and disbursement of funds are in accordance with federal regulations.

View Audit 301142 Questioned Costs: $1

Finding 390234 (2023-001)

Material Weakness 2023

National University

CA

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we c...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we continue to refine our R2T4 processes, we’ve had two key challenges we are addressing: Timeliness of R2T4 calculations: In FY22, NU identified an issue with how it was identifying unofficial withdrawals at the institution. To assist in rectifying the issue, we implemented a 35-day attendance policy that resulted in a significant amount of students being attritted from the University. We were working with a third-party firm to help us complete all the R2T4 calculations, which proved challenging; between our internal staffing and external support, we did not have the ability to do all of the calculations timely. As we’ve analyzed the needed manpower, we’ve expanded our Processing and Quality Assurance teams. The establishment of two additional teams within the Processing team in 2024 underscores our commitment to ensuring the timely completion of necessary calculations. Simultaneously, the increased Quality Assurance team is poised to support the enhanced internal controls, conducting weekly reviews of R2T4 calculations to verify their accuracy and timeliness. Missing students for R2T4 calculations who were withdrawn: We have established precise and accurate criteria for the development and execution of report queries. This initiative aims to ensure the comprehensive identification of students who discontinue attendance before the end of a payment period, thereby mitigating the risk of oversight. To bolster the reliability of these refined processes, NU is committed to implementing regular testing of the attendance queries. By conducting these tests at established intervals, the institution seeks to verify that the queries consistently identify the correct cohort of students. This approach serves as a crucial mechanism to maintain the accuracy of our withdrawal determination processes and underscores our dedication to continuous improvement. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390202 (2023-003)

None 2023

St. Lukes Health Network, Inc. and Controlled Entities

PA

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

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal ...

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The Network agrees with the finding, and will make the following enhancement to the process: A review of the R2T4 calculation will be evidenced to ensure the calculation is prepared completely and accurately to determine whether a refund is required as well as to verify any post-withdrawal disbursements. The Network is implementing this process beginning in Q4 of FY2024. For inquiries regarding this finding, please contact Lisa Storck, Senior Associate Dean, and Joe Zelasko, Senior Financial Aid Coordinator, who are responsible for the corrective action.

View Audit 301103

Finding 390170 (2023-001)

Significant Deficiency 2023

Prince William Sound Science and Technology Institute

AK

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting....

Lack of Internal Control over Reporting and Noncompliance Name of Contact: W. Scott Pegau Corrective Action Plan: A new section on contracts was added to our accounting manual that describes the steps to be taken when a new contract is established. It identifies the need for the FFATA reporting. A second procedure outlines how to complete the required reporting. All existing subcontracts over $30,000 were reported as required. Proposed completion date: December 15, 2023.

View Audit 301086

Finding 390168 (2023-002)

Material Weakness 2023

Altus Independent School District #18

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390167 (2023-001)

Material Weakness 2023

Altus Independent School District #18

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390155 (2023-001)

Significant Deficiency 2023

City of Daly City

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federa...

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2686 68-0281986 Name of Pass-Through Entity: California State Water Resources Control Board • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Cheresa Wang, Financial Services Manager • Corrective Action Plan: City staff will better comply with this rule going forward by either checking the exclusions list for suspensions or debarments for proposed contractors and subrecipients or by including suspension and debarment language in contracts. Finance staff communicated this new procedure to the appropriate project managers in April 2023. In addition, Finance staff developed a new Suspension and Debarment Policy, dated 12/4/23, to provide guidance to project managers on how to comply with this rule. • Anticipated Completion Date: 06/30/24

View Audit 301060

Finding 390146 (2023-002)

Material Weakness 2023

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subreci...

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subrecipient disbursements. Moving forward, management will ensure that it properly allocate expenses in accordance with Uniform Guidance Regulations. In addition, management plans to work closely with the federal passthrough entity to ensure that overbilled amounts are returned during the fiscal year ending June 30, 2024

View Audit 301052 Questioned Costs: $1

Corrective Action Plans

Filters