Corrective Action Plans

Finding 370722 (2023-003)

Material Weakness 2023

South Putnam Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Reli...

FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct errors. Contact Person Responsible for Corrective Action: Hilarie Logan Contact Phone Number and Email Address: 765-653-3119 hlogan@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation has a new Grants Coordinator who will participate in Internal Controls Training and sign off that they have done so. We will also incorporate dual signatures on documents as an additional means of approval/oversight. Anticipated Completion Date: 3/2024

View Audit 292410

Finding 370702 (2023-001)

Material Weakness 2023

Lamprey Health Care, Inc. and Friends of Lamprey Health Care, Inc.

NH

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: 2023-001 Condition: In a sample of three of nine cash draw downs from PMS, each of the three transactions tested were drawn in a proportion in excess of the Federal Percentage Share as required by the terms and conditions of the award. Individual(s) Responsible for Corrective Action: Eli...

Finding: 2023-001 Condition: In a sample of three of nine cash draw downs from PMS, each of the three transactions tested were drawn in a proportion in excess of the Federal Percentage Share as required by the terms and conditions of the award. Individual(s) Responsible for Corrective Action: Elidoro Primero, CFO Planned Corrective Action: Management will provide additional training to individuals for monitoring grant compliance, reinforcing the importance of grant provisions and implementing a system of processes and controls for tracking compliance with all specific grant terms and conditions. Management will also solicit guidance/best practice from designated HRSA grant management officer for voluntary correction action steps to resolve finding. Anticipated Completion Date: June 30, 2024

View Audit 292390

Finding 370573 (2023-001)

Material Weakness 2023

Unified School District #457

KS

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management

Finding 2023-001 Planned Corrective Action: The District’s management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate and timely, with a planned implementation date by the Financial Officer of December 15, 2023.

View Audit 292263

Finding 370527 (2023-001)

Significant Deficiency 2023

Colton Joint Unified School District

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the...

The District will conduct a regular review of substitute activity charged under Title I, with audits for allowability performed every pay period. Departments within the Educational Services and Business Services Rivision will oversee this review, engaging in outreach to sites for confirmation of the rationale behind charging a substitute to Title I. Additionally, backup documentation will be collected to bolster the support for the allowability of these activities. This proactive plan aims to maintain continuous compliance with Title I guidelines.

View Audit 292192 Questioned Costs: $1

Finding 370508 (2023-001)

Significant Deficiency 2023

Logan University

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. ...

Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. At the start of each trimester, the calendar will be reviewed to verify any break of 5 days or more are accounted for within the R2T4 calculation setup.

View Audit 292105 Questioned Costs: $1

Finding 370507 (2023-003)

Material Weakness 2023

Metropolitan School District of Decatur Township

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-003 Finding Subject: Emergency Connectivity Fund – Suspension and Debarment Summary of Finding: The School Corporation had not implemented a system of internal controls to ensure procedures were in place to verify that the contracted entity selected for the project was not suspended or ...

FINDING 2023-003 Finding Subject: Emergency Connectivity Fund – Suspension and Debarment Summary of Finding: The School Corporation had not implemented a system of internal controls to ensure procedures were in place to verify that the contracted entity selected for the project was not suspended or debarred. The School Corporation did not include the appropriate provisions for suspension and debarment in the contract, require a certification, or check the EPLS to ensure the entity was not suspended or debarred. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures, including adding contract language when appropriate, to ensure searches verifying vendors paid from federal funds have not been Suspended or Debarred. Documentation of the searches will be printed off then filed with the contract and submitted with the original purchase request. Anticipated Completion Date: March 1, 2024

View Audit 292091

Finding 370490 (2023-001)

None 2023

Riordan School Housing Development Fund Company, Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Bessie Riordan Senior Apartments agrees w...

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Bessie Riordan Senior Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

View Audit 292056

Finding 370489 (2023-001)

None 2023

Mercy Housing Development Fund Company, Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Mercy Apartments agrees with the auditor’...

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Mercy Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

View Audit 292055

Finding 370488 (2023-001)

None 2023

Hawley-Winton Housing Development Fund Company, Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Hawley-Winton Apartments agrees with the ...

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Hawley-Winton Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

View Audit 292054

Finding 370486 (2023-001)

None 2023

St. David's Housing Development Fund Company, Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: St. David’s Court agrees with the auditor...

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: St. David’s Court agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

View Audit 292053

Finding 370481 (2023-006)

Material Weakness 2023

East Porter County School Corporation

IN

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

Finding 2023-006 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Acti...

Finding 2023-006 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the Davis-Bacon Act. We will collect weekly payroll documentation for any constructions projects where Federal Grant money is used. Anticipated Completion Date: February 2024

View Audit 292036

Finding 370453 (2023-008)

Material Weakness 2023

One City Schools, Inc.

WI

School Nutrition Programs Subrecipient Monitoring Internal Control / Segregation of Duties

Recommendation: Internal controls for accounting for nonprofit school food service funds should be implemented. A separate class in the accounting software for the program could be utilized. Action Taken: One City Schools developed a new financial class for School Nutrition, and all grant funds and ...

Recommendation: Internal controls for accounting for nonprofit school food service funds should be implemented. A separate class in the accounting software for the program could be utilized. Action Taken: One City Schools developed a new financial class for School Nutrition, and all grant funds and expenditures will be classed to School Nutrition so these funds are clearly segregated from others. One City Schools implemented these new class designations as of January 1, 2024. Additionally, OCS added relevant tasks in our monthly accounting procedures to check for miscodes and ensure grant funds and expenditures are correctly coded.

View Audit 292020

Finding 370449 (2023-007)

Material Weakness 2023

One City Schools, Inc.

WI

Questioned Costs Subrecipient Monitoring School Nutrition Programs § 200.302 § 200.334

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for retaining support for claims in accordance with federal requireents. Action Taken: One City Schools has developed a new process to document meal counts per month, attendance and enrollment numbers pe...

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for retaining support for claims in accordance with federal requireents. Action Taken: One City Schools has developed a new process to document meal counts per month, attendance and enrollment numbers per month, submission of claims, and the signature of a designated second approver, the COO. As each claim is made, the associated backup documentation will be presented to the second approver for their review and signature. Once approved, the entire packet of information will be retained. This process was initiated in December 2023.OCS completed the second designated approver review retroactively for all claims in the months of July, September, October, and November 2023.

View Audit 292020 Questioned Costs: $1

Finding 370445 (2023-006)

Material Weakness 2023

One City Schools, Inc.

WI

Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December...

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December 2023, however OCS also completed this second approver review retroactively for all claims in July 2023, September 2023, October 2023, and November 2023.

View Audit 292020

Finding 370441 (2023-005)

Material Weakness 2023

One City Schools, Inc.

WI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.327

Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Action Taken: All purchases at One City Schools already require a second approver before invoices are paid. At the November 2023 Board meeting, One City Schools adopte...

Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Action Taken: All purchases at One City Schools already require a second approver before invoices are paid. At the November 2023 Board meeting, One City Schools adopted new procurement policies that meet the federal requirements including effective internal controls.

View Audit 292020 Questioned Costs: $1

Finding 370437 (2023-004)

Significant Deficiency 2023

One City Schools, Inc.

WI

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management § 200.300 § 200.302 § 200.303 § 200.318 § 200.430

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved...

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

View Audit 292020

Finding 370424 (2023-002)

Significant Deficiency 2023

Pacific University

OR

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.332 § 200.501

Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). Howe...

Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). However, the University will enhance controls related to tracking such compliance

View Audit 291993

Finding 370421 (2023-001)

Significant Deficiency 2023

Pacific University

OR

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring § 200.303 § 200.403

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The ap...

Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The approval requirement will also be added to Pacific’s mandatory annual compliance training for supervisors.

View Audit 291993

Finding 370412 (2023-002)

Significant Deficiency 2023

Central Virginia Partnership for Economic Development

VA

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Segregation of Duties: The Organization concurs with the findings. The Organization has determined it is staffed appropriately given the resources available and will continue to look for new opportunities to address these findings.

View Audit 291991

Finding 370363 (2023-009)

Significant Deficiency 2023

City of Detroit, Michigan

MI

Subrecipient Monitoring Significant Deficiency

Finding Number: 2023‐009 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Condition: Original Finding Description: The City did not provide a formal report on monitoring performed for three of their subrecip...

Finding Number: 2023‐009 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Condition: Original Finding Description: The City did not provide a formal report on monitoring performed for three of their subrecipients. Contact Person Responsible for Corrective Action: Denise Fair Razo (DHD) and Angelique Tomsic (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review its subrecipient monitoring policy during the AFCAP process and implement additional controls to ensure an end to end process is in place that includes timely communication of the reports.

View Audit 291959

Finding 370359 (2023-008)

Material Weakness 2023

City of Detroit, Michigan

MI

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303

Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate...

Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), Cynthia Saxton (OGA) and Julie Schneider (HRD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional reporting controls that includes verification of expenditures, retention of supporting documentation and a timely final reconciliation of the CAPER Report to the general ledger.

View Audit 291959

Finding 370355 (2023-007)

Material Weakness 2023

City of Detroit, Michigan

MI

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

Finding Number: 2023-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing...

Finding Number: 2023-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified. Contact Person Responsible for Corrective Action: Denise Fair Razo (DHD) and Angelique Tomsic (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps which includes the use of eligibility templates to help ensure accurate rental assistance calculations. In addition, the City will review during the AFCAP process to ensure the required process improvements and procedures are in place for accurate rental assistance calculations.

View Audit 291959 Questioned Costs: $1

Finding 370340 (2023-006)

Material Weakness 2023

City of Detroit, Michigan

MI

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

Finding Number: 2023‐006 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Condition: Original Finding Description: The payroll costs that were reported as incurred on four CSLFRF projects were...

Finding Number: 2023‐006 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Condition: Original Finding Description: The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period October 1, 2022, through December 31, 2022 (Quarter 4). Contact Person Responsible for Corrective Action: Terri Daniels (ODG) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional controls to ensure the quarterly Treasury reports align with the expenses as stated on the general ledger.

View Audit 291959

Finding 370339 (2023-005)

Material Weakness 2023

City of Detroit, Michigan

MI

Subrecipient Monitoring § 200.303

Finding Number: 2023‐005 Federal Program, Assistance Listing Number and Name: ALN 20.507, Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Condition: Original Finding Description: The City did not have adequate controls in place to ensure payroll costs charged to...

Finding Number: 2023‐005 Federal Program, Assistance Listing Number and Name: ALN 20.507, Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Condition: Original Finding Description: The City did not have adequate controls in place to ensure payroll costs charged to the program were accurate in relation to underlying payroll records. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), James George (ODFS) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will implement required controls to ensure accurate payroll costs are charged to the program and completeness of the supporting documentation. The City will review during the AFCAP process to ensure policies, procedures and additional trainings are put in place.

View Audit 291959

Finding 370335 (2023-004)

Material Weakness 2023

City of Detroit, Michigan

MI

Subrecipient Monitoring Period of Performance Material Weakness § 200.344

Finding Number: 2023‐004 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City did not have adequate controls in place to ensure obliga...

Finding Number: 2023‐004 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Contact Person Responsible for Corrective Action: Terri Daniels (ODG), Regina Greear (ODFS), Denise Fair Razo (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: During the AFCAP process, the OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved and processed timely and accurately for payment prior to the 60 liquidation requirement period.

View Audit 291959

Corrective Action Plans

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