Corrective Action Plans

Finding 375800 (2023-001)

Significant Deficiency 2023

WY

Subrecipient Monitoring

Corrective actions: In response to the previous Corrective Action Plan, the following have been implemented and are in progress: - Enrollment rates have increased by 29 students from January 2023, showing improvement in recruiting and retention. - EWC GEAR UP lost its director in April 2023, ...

Corrective actions: In response to the previous Corrective Action Plan, the following have been implemented and are in progress: - Enrollment rates have increased by 29 students from January 2023, showing improvement in recruiting and retention. - EWC GEAR UP lost its director in April 2023, which impacted the push for recruitment and retaining students. - As of June 19, a new Director was hired for GEAR UP. - Since hiring the new Director, three additional schools have agreed to participate in GEAR UP services. This will increase student enrollment and engagement by an estimated 25 students by the end of 2023. - Two additional Coordinators will be hired at EWC. Coordinators will serve EWC GEAR UP freshmen as well as local schools without GEAR UP advisors (Torrington High School and Lingle/Ft. Laramie Middle and High School), which will increase enrollment and engagement by an estimated 25 students by the end of 2023. - Coordinators will attend parent-teacher conferences to aid staff in recruiting and retaining students and families in the GEAR UP Program. - Coordinators will be able to assist with events and family programs. - Current advisors have agreed to return for the year of September 2023-September 2024. This will decrease hiring and orientation times and allow for more recruiting from those school advisors. Anticipated completion date: June 2024 Contact person: GEAR UP Director - Chelsea Ballard

View Audit 294893

Finding 375760 (2023-005)

Material Weakness 2023

Penn-Harris-Madison School Corporation

IN

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

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be e...

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. 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 to be prepared and submitted by the School Principal and reviewed by the Executive Business Director; however, no evidence of this review or oversight process could be provided. As such the annual data reports were prepared and submitted to IDOE without an oversight or review process to prevent or detect and correct errors. In addition, five of the six reports submitted during the audit period were not supported by the School Corporation’s records. The following errors were identified:  The ESSER I, Year 2 report, which had an applicable reporting period of October 1, 2020 through June 30, 201, reported $534,761 in expenditures. However, actual expenditures for the applicable reporting period totaled $478,883.  The ESSER 1, Year 3 report which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $243,814.67.  The ESSER II, Year 1 report, which had an applicable reporting period of July 1, 2020 to June 30, 2021, reported $733 in expenditures. However, actual expenditures for the applicable reporting period totaled $322,539.  The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $276,642.  The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,315,208. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports and reimbursement requests. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

View Audit 294813

Finding 375744 (2023-002)

Material Weakness 2023

Kamalani Academy

HI

Subrecipient Monitoring Reporting § 200.328 § 200.329

Finding 2023 - 002 Reporting - Native Hawaiian Education – Assistance Listing 84.362A KA concurs with the Recommendation. In conjunction with the search and seating of a permanent School Director (in progress), the Reconstituted Governing Board (“RGB”) as a whole, intends to prioritize the: A) Updat...

Finding 2023 - 002 Reporting - Native Hawaiian Education – Assistance Listing 84.362A KA concurs with the Recommendation. In conjunction with the search and seating of a permanent School Director (in progress), the Reconstituted Governing Board (“RGB”) as a whole, intends to prioritize the: A) Updating and/or creation of policies (that either don’t exist or aren’t documented); B) Cascading policies to related processes and procedures; and C) Training appropriate staff; and D) Monitoring the practices, to ensure the day to day practices are consistent with and aligned to the policies, processes and procedures. Policy Focus: Grant Management (e.g., accounting, reporting, budgeting, compliance, authorized procurement, inventory, federal draws, federal progress report, communication with federal program office, utilization of curriculum, supplies, equipment in compliance with the specific grant). Any questions regarding this response may be directed to Aumoana Kanakaole-Lato, Reconstituted Governing Board Chair at aumoana.kanakaole@kamalaniacademy.org.

View Audit 294807

Finding 375725 (2023-001)

Material Weakness 2023

Herron High School, Inc.

IN

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

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2023-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2022-001) Material Weakness Recommendation: The Auditor reco...

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2023-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2022-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compliance to review federal award provisions and requirements, evaluate risks of noncompliance, and respond to such risks through internal controls. The process should include methods to identify and communicate changes to federal award requirements to all key individuals within the Organization and to verify internal controls are implemented correctly and are operating effectively. Planned Corrective Action: As the organization has grown, compliance of federal programs has become decentralized. We agree that additional resources need to be added to ensure compliance with all state and federal awards. The Organization has added additional capacity to the Business Office to assume the compliance and reporting responsibilities. Michelle Krauter, the Director of Accounting & Finance, is responsible for ensuring fiscal compliance and will coordinate program compliance activities with the Heads of School at each campus and the Directors of Academic Accountability. Through the monitoring activities conducted by the Indiana Department of Education during 2023, staff gained a better understanding the compliance requirements and are implementing processes to ensure ongoing adherence to the requirements. Evaluation of these processes will continue through 2024. 43

View Audit 294798

Finding 375720 (2023-001)

Significant Deficiency 2023

State Center Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 speciali...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 specialist in financial aid will review student accounts that require R2T4 calculations on a weekly basis. The students will be posted to the shared database between Financial Aid and the Business Office. The dedicated weekly time will expedite the calculation process. The Business Office, as part of the updated process will continue to treat the R2T4 award adjustments as a priority. In addition to the existing process of end of month reconciliation and return of funds, a mid-month returning of funds was added and implemented. The dedicated weekly timeline to calculate, as well as the added mid-month return of funds, will ensure that we meet the required return of funds within the 45-day window. The offices will meet to review this updated process and make any additional changes should they be necessary to maintain compliance. Calculations - To ensure compliance with calculations processed timely, we will relieve the R2T4 specialist of other responsibilities so he can dedicate 100% of his time to calculate within the required timeframe. In addition, there will be additional staff assisting with calculations because the institution closes for a 10- day period which impacts the 30-day timeframe. This will ensure that all calculations are done. Implementation Date: 11/15/2023

View Audit 294788

Finding 375715 (2023-014)

Material Weakness 2023

El Paso County School District #22

CO

Reporting Subrecipient Monitoring

Reporting for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: As an LEA, the LEA is required to submit certain annual financial reports...

Reporting for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: As an LEA, the LEA is required to submit certain annual financial reports to the SEA on an annual basis. Condition: While the Organization submitted the required annual financial reports, these reports did not tie back to the accounting records in a material amount. Management Response and Planned Corrective Actions Criteria: Management agrees with this finding and is working on implementing an annual financial report reconciliation process as staffing allows. Responsibility for Corrective Action: Christina Vetromile, Business Manager Anticipated Completion Date: Unknown

View Audit 294777

Finding 375714 (2023-013)

Material Weakness 2023

El Paso County School District #22

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Activities Allowed or Unallowed, and Allowable Costs and Cost Principles for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: A non-fede...

Activities Allowed or Unallowed, and Allowable Costs and Cost Principles for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: A non-federal grant recipient should set reasonable budgets for programs to minimize incentives to miscode expenses. The recipient should compare budgeted and actual allowable costs and investigate variances where applicable. Condition: While the Organization created a budget for overall activities, they did not input the budget into their accounting system or create an outside tool to track actual grant expenditures with the budget. Management Response and Planned Corrective Actions Criteria: Management agrees with this finding and is working on implementing a budget to actual reporting process as staffing allows. Responsibility for Corrective Action: Christina Vetromile, Business Manager Anticipated Completion Date: Unknown

View Audit 294777

Finding 375693 (2023-002)

Significant Deficiency 2023

Marian University, Inc.

WI

Subrecipient Monitoring Significant Deficiency Equipment & Real Property Management

Recommendation: We recommend that the University work to formally document the policy as a part of the University's 'Information Security Plan' as included in the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...

Recommendation: We recommend that the University work to formally document the policy as a part of the University's 'Information Security Plan' as included in the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged a consultant in FY 2022-23 to conduct a cyber security review and assist the University in establishing policies to ensure compliance with 16 CFR 314©(1) through (8). The unintentional omission of a policy specific to applications resulted because the University does not have applications developed by the institution. The University will develop a policy specific to institution developed applications. Additionally, the University will conduct an annual review with the assistance of our security consult to ensure ongoing compliance.

View Audit 294773

Finding 375642 (2023-001)

Material Weakness 2023

Cheney Care Community

WA

HUD Housing Programs Reporting Subrecipient Monitoring

Finding 2023-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review...

Finding 2023-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the financial reporting and close processes to determine whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Action Taken: Cheney Care Community will review their internal controls over the financial reporting and close processes to determine whether additional controls need to be implemented going forward.

View Audit 294723

Finding 375640 (2023-001)

Significant Deficiency 2023

Fielding Graduate University

CA

Subrecipient Monitoring Student Financial Aid Eligibility

Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm...

Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm‐Leach Bliley Act (GLBA). Corrective Action: At the time that we replied to the question, our former Qualified Individual responsible for implementing and monitoring the Institution's information security program had left the organization a month previously. Upon reflecting on the significance of this position, I have elevated this role to a higher priority in the organization and named Darrin Burns, Director of ERP and IT, as Fielding’s Qualified Individual. In collaboration with Darrin and CIO Solutions, our MSP, we will draft the written information security program using the cybersecurity assessment results and recommendations as a starting point. In addition, we will ensure that the final document will include all six required minimum elements per Title IV regulations (16 CFR 314). Person Responsible For Corrective Action: Darrin Burns, Director of IT and ERP Anticipated Completion Date: December 31, 2024

View Audit 294714

Finding 375603 (2023-005)

Material Weakness 2023

Randolph Central School Corporation

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporatio...

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. 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 the Assistant Superintendent and reviewed by the Treasurer prior to submission. However, this review process was not effective and did not detect and allow correction of errors prior to submission. All six of the submitted reports were selected for testing. Four of the reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy of the reports. The lack of controls was systematic throughout the audit period. The noncompliance was isolated to the four reports identified above. The auditors recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are supported by the ledgers or reports used to complete the report Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation is required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted includes, but is not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The annual data reports will be complied/prepared by the Treasurer and the Assistant Superintendent to ensure the reports are supported by the corporation’s financial data. The JotForm will be reviewed by the Superintendent prior to submission. Anticipated Completion Date: 2/21/2024

View Audit 294679

Finding 375588 (2023-003)

Significant Deficiency 2023

Louisiana Delta Service Corps

LA

Subrecipient Monitoring Eligibility Period of Performance

Management Response: Management will ensure an individual who does not perform the adjudication will review and document whether information was entered correctly and whether the adjudications are proper and documented prior to a member’s start date. Responsible Person: Lisa Moore, Executive Direc...

Management Response: Management will ensure an individual who does not perform the adjudication will review and document whether information was entered correctly and whether the adjudications are proper and documented prior to a member’s start date. Responsible Person: Lisa Moore, Executive Director Anticipated Remediation Date: Fiscal year ended August 31, 2024

View Audit 294676

Finding 375578 (2023-003)

Material Weakness 2023

Morton College Community College District No. 527

IL

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Reporting – The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - January 31, 2024; ...

Reporting – The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - January 31, 2024; Responsible Contact Person for Planned Corrective Action - Carissa Davis, Director of Financial Aid

View Audit 294656

Finding 375551 (2023-001)

Significant Deficiency 2023

Community Health and Wellness Center of Greater Torrington, Inc.

CT

Subrecipient Monitoring Eligibility HUD Housing Programs

January 24, 2024 United States Department of Health and Human Services Community Health and Wellness Center of Greater Torrington, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended September 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 0610...

January 24, 2024 United States Department of Health and Human Services Community Health and Wellness Center of Greater Torrington, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended September 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: September 30, 2023 The findings from the September 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCIES Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID - 19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), and Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 2023-001 Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken Education was provided to the staff who complete the applications, this included a quiz to measure the staff's knowledge of the process and mathematical calculations. Management developed a tool "How to Calculate Household Income for Processing Financial Assistance Applications" which includes step by step instructions for calculating household income. Prevention strategies have been implemented to prevent future occurrences of adverse events. Monthly audits of the calculation of annual income for a minimum of 10% of the total number of patients who have completed a financial assistance application are being performed. The manager of the population health department will report audit results quarterly at the continuous quality improvement (CQI) committee meeting. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Joanne Borduas, CEO at (860) 387-0425. Sincerely yours,

View Audit 294590

Finding 375459 (2023-003)

Significant Deficiency 2023

Reading Muhlenberg Career & Technology Center

PA

Subrecipient Monitoring Reporting

Condition During the year ended June 30, 2023, the Center submitted a report for the funds used during the year ended June 30, 2022. The report submitted by the Center contained expenditure amounts that did not agree to the amounts reported on the schedule of expenditures of federal awards for the y...

Condition During the year ended June 30, 2023, the Center submitted a report for the funds used during the year ended June 30, 2022. The report submitted by the Center contained expenditure amounts that did not agree to the amounts reported on the schedule of expenditures of federal awards for the year ended June 30, 2022. Recommendation We recommend the Center update its report filing procedures to include comparing the expenditures entered on the annual performance report to the audited schedule of expenditures of federal awards. In addition, the report should also be reviewed by an individual separate from the person compiling the information. Management Response The report referenced was for FY 2021-22, and the data available at the time of reporting was minimal and incorrect. There were items that were purchased that were incorrectly coded to other grants or items purchased and charged to this grant that should have been charged to another. I have now instituted a procedure where each year’s spending per grant is maintained in a separate folder with the proper financial reports included as well as copies of invoices.

View Audit 294522

Finding 375418 (2023-003)

Material Weakness 2023

Community Chest, Inc.

NV

Subrecipient Monitoring

Finding Summary: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time o...

Finding Summary: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. Subawards did not contain all the required information and assistance listing numbers were not communicated at disbursement. Responsible Individuals: Erik Schoen, CEO Corrective Action Plan: Management agrees with this finding and will comply with this requirement going forward. We do, however, believe this was an isolated event. Anticipated Completion Date: June 30, 2024

View Audit 294476

Finding 375417 (2023-002)

Material Weakness 2023

Community Chest, Inc.

NV

Reporting Subrecipient Monitoring Material Weakness

Finding Summary: Part of the Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to $30,000 (or $25,000 ...

Finding Summary: Part of the Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to $30,000 (or $25,000 for federal agencies that have not yet adopted amendments effective November 12, 2020). Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Responsible Individuals: Erik Schoen, CEO Corrective Action Plan: Management agrees with this finding and will comply with this requirement going forward. Staff are currently creating a process in relation to this finding to accurately report needed information monthly. Anticipated Completion Date: June 30, 2024

View Audit 294476

Finding 375402 (2023-003)

Significant Deficiency 2023

Western Wayne School Corporation

IN

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

Finding 2023-003 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Peggy Huesman Contact Phone Number: 765-478-5375 Views of Responsible Official: We concur with the finding. Description of Corrective Action...

Finding 2023-003 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Peggy Huesman Contact Phone Number: 765-478-5375 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will work with the Maintenance Department to make sure that any contractor paid with Federal Funds has a “Davis Bacon Clause” in their contract. Anticipated Completion Date: April 1, 2024

View Audit 294472

Finding 375386 (2023-001)

Material Weakness 2023

Sunman-Dearborn Community School Corporation

IN

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

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2023 Finding 2023-001 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilizatio...

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2023 Finding 2023-001 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Noncompliance Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included playground equipment. As of June 30, 2023, $75,190 was disbursed related to this capital project. The construction payments represented approximately 2.7% of the Education Stabilization Fund expenditures for the audit period. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The construction contracts did not include clauses for federal wage rate requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: Mary Ann Baines, Director of Financial Operations/Treasurer, will oversee the corrective action plan which will be implemented immediately and steps will be taken to collect on wage reports for work performed since July 1, 2023.

View Audit 294451

Finding 374738 (2023-003)

Significant Deficiency 2023

Saunders County

NE

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

The County Attorney is writing up a policy.

View Audit 294434

Finding 374718 (2023-001)

Significant Deficiency 2023

Westminster College

MO

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.317 § 200.327

Finding Reference Number: 2023-001 Description of Finding: Written Procurement Policy (significant deficiency) Statement of Concurrence: Management concurs with the finding and had implemented a written procurement policy that complies with the requirements of the Uniform Guidance. Corrective Action...

Finding Reference Number: 2023-001 Description of Finding: Written Procurement Policy (significant deficiency) Statement of Concurrence: Management concurs with the finding and had implemented a written procurement policy that complies with the requirements of the Uniform Guidance. Corrective Action: Management has established a written procurement policy and implemented the documented procurement procedures as of August 13, 2022. Name of Contact Person: Steve Tyrell, Senior Vice President, CFO & COO, 518-366-1533, steve.tyrell@WCMO.edu Projected Completion Date: The College’s corrective action plan is completed and in effect at this time.

View Audit 294421

Finding 374715 (2023-003)

Material Weakness 2023

Monroe Central School Corporation

IN

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

Finding 2023-003 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Jessica Cheesman Contact Phone Number: 765-468-6868 Views of Responsible Official: We concur with the finding. Description of Co...

Finding 2023-003 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Jessica Cheesman Contact Phone Number: 765-468-6868 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Superintendent will sign off on all vouchers going forward and all vocuhers from 07/01/2023 to 12/31/2023 Anticipated Completion Date: 04/30/2024

View Audit 294418

Finding 374689 (2023-004)

Material Weakness 2023

Shelbyville Central Schools

IN

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

Finding 2023-004 – Special Tests and Provisions – Wage Rate Requirement Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We now require all fe...

Finding 2023-004 – Special Tests and Provisions – Wage Rate Requirement Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We now require all federal contracts to provide the proper language for Davis Bacon wages. In addition, we require the payroll reports to ensure that the pay rates comply with the federal wage rate requirements. Anticipated Completion Date: July 2023

View Audit 294371

Finding 374650 (2023-003)

Significant Deficiency 2023

Seward County Community College

KS

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

2023-003 – Student Financial Assistance Cluster – Special Tests and Provisions – Student Information Security Condition During testing, it was determined that the College’s written policies did not reflect one of the seven required elements. Recommendation We recommend that the College’s written pol...

2023-003 – Student Financial Assistance Cluster – Special Tests and Provisions – Student Information Security Condition During testing, it was determined that the College’s written policies did not reflect one of the seven required elements. Recommendation We recommend that the College’s written policies be updated to properly reflect all seven elements required. Comments on the Finding Management is aware of the oversite and has enacted the practice of the missing policy in FY24. They have also worked on a policy to take to the SCCC Board of Trustees for approval. Actions Taken The policy has been written, reviewed, and is planned to go to the SCCC Board of Trustees on March 4, 2024.

View Audit 294326

Finding 374628 (2023-002)

Significant Deficiency 2023

School District of Belleville

WI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding #2023-002: ESSER II #84.425D COVID-19 – Education Stabilization Fund and ESSER III #84.425U COVID-19 – Education Stabilization Fund Federal Grantor: U.S. Department of Education Pass-through Award Numbers: 2022-252646-DPI-ESSERFII-163 and 2022-252646-DPI-ESSERFIII-165 Pass-throug...

Finding #2023-002: ESSER II #84.425D COVID-19 – Education Stabilization Fund and ESSER III #84.425U COVID-19 – Education Stabilization Fund Federal Grantor: U.S. Department of Education Pass-through Award Numbers: 2022-252646-DPI-ESSERFII-163 and 2022-252646-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were five Education Stabilization Fund construction projects performed by contractors/subcontractors. None of the contracts included prevailing wage language clauses and certified payrolls were not obtained by the District during the fiscal year expended. Not all contractors/subcontractors were able to provide certified payrolls when requested as part of the compliance testing. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: There was turnover in the business office and the contracts were secured and approved prior to the current business manager. The District was not aware of the applicable requirements related to these projects. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $78,300 (Amount for which certified payrolls were not subsequently provided) Recommendation: Establish procedures and controls to comply with wage rate requirements related to the Education Stabilization Fund. Obtain verification from contractors that prevailing wage rates were paid on the projects submitted for costs reimbursed by the grant. Response: The District became aware of the prevailing wage rate requirements after finishing the projects. Before bidding future construction projects more than $2,000, that may be funded with federal grant dollars, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received from contractors or subcontractors. Additionally, the district has obtained payroll data from all each contractor to provide support for wage rates paid if necessary. Contact Person: Erik Farrar Anticipated Completion: March 15, 2024

View Audit 294304 Questioned Costs: $1

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