Corrective Action Plans

Finding 369985 (2023-001)

Material Weakness 2023

KS

Reporting Subrecipient Monitoring Material Weakness § 200.502

January 31, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 458 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 ...

January 31, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 458 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT None. FINDINGS-FEDERAL AWARD PROGRAMS AUDIT 2023‐001 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Education Program Name: Special Education Cluster (IDEA Assistance Listing Numbers: 84.027 and 84.173 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. Contact Name – Tyler Bacon Expected Completion Date -06/30/2024 If the U.S. Department of Education has questions regarding this plan, please call Tyler Bacon at 913-724-1396. Sincerely yours, Tyler Bacon Business Manager/Board Clerk Unified School District No. 458

View Audit 291499

Finding 369983 (2023-001)

Material Weakness 2023

Catholic Charities of the Diocese of Allentown

PA

Questioned Costs Eligibility Subrecipient Monitoring

Finding 2023-001- Eligibility Condition During our audit, 8 out of 40 individual files selected for eligibility testing did not contain evidence that the Organization obtained or reviewed a lease to support the eligibility of the individual who received a direct assistance payment. Further, there ...

Finding 2023-001- Eligibility Condition During our audit, 8 out of 40 individual files selected for eligibility testing did not contain evidence that the Organization obtained or reviewed a lease to support the eligibility of the individual who received a direct assistance payment. Further, there was no evidence of alternative documentation of residence when a lease could not be obtained. Corrective Action Plan Corrective Action Planned: Catholic Charities Diocese of Allentown declined to administer the second round of ERAP funding. Significant leadership changes have been implemented in May 2023, including a new Managing Director. Catholic Charities is in the process of designing an enhanced training program to ensure all programs complete all documentation required to substantiate eligibility under each program administered, whether privately or publicly funded. Name(s) of Contact Person(s) Responsible for Corrective Action: Andrea Kochen Neagle, Managing Director and Susan Mazza, Finance Administrator Anticipated Completion Date: December 2023

View Audit 291476 Questioned Costs: $1

Finding 369874 (2023-002)

Significant Deficiency 2023

Chattanooga Area Reg Council of Governments/se Tn Development District

TN

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

Position has been filled and progress is being made in meeting the monitoring requirements. Management will provide necessary support and follow up to ensure that requirements are met.

View Audit 291381

Finding 369869 (2023-007)

Material Weakness 2023

Harmony Area School District

PA

Questioned Costs Internal Control / Segregation of Duties Equipment & Real Property Management

Education Stabilization Fund – CFDA No. 84.425 Name of contact person – Bradley Brothers, Business Manager Internal Controls over Compliance: Recommendation: We recommend that District personnel responsible for grants management educate themselves on the requirements of the Education Stabiliz...

Education Stabilization Fund – CFDA No. 84.425 Name of contact person – Bradley Brothers, Business Manager Internal Controls over Compliance: Recommendation: We recommend that District personnel responsible for grants management educate themselves on the requirements of the Education Stabilization Funds. We further recommend the implementation of a review process by management to ensure the grants are managed correctly and communications from the oversight agency are monitored and addressed. Action Taken: Management agrees with the recommendations and will have personnel responsible for grant management educate themselves on the requirements of the Education Stabilization Funds. Further, we will resume regular management team meetings to ensure the team is tracking grant progress as well as monitoring and responding to communications from the Pennsylvania Department of Education. Proposed Completion Date: June 30, 2024

View Audit 291376 Questioned Costs: $1

Finding 369864 (2023-006)

Material Weakness 2023

Harmony Area School District

PA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management

Education Stabilization Fund – CFDA No. 84.425 Name of contact person – Bradley Brothers, Business Manager Recommendation: We recommend management contact the Pennsylvania Department of Education to inquire as to how to handle the projects not pre-approved. In addition, personnel responsible fo...

Education Stabilization Fund – CFDA No. 84.425 Name of contact person – Bradley Brothers, Business Manager Recommendation: We recommend management contact the Pennsylvania Department of Education to inquire as to how to handle the projects not pre-approved. In addition, personnel responsible for Education Stabilization Fund programs should become familiar with the grant requirements. We further recommend the implementation of a review process by management to ensure the grants are managed correctly. Action Taken: Management agrees with the recommendations and has contacted the Pennsylvania Department of Education to determine how to handle the projects not pre-approved. PDE has advised that the pre-approvals can still be obtained, and management will do the necessary paperwork to become compliant. Proposed Completion Date: June 30, 2024

View Audit 291376 Questioned Costs: $1

Finding 369758 (2023-004)

Significant Deficiency 2023

New Mexico Department of Homeland Security & Emergency Management

NM

Subrecipient Monitoring § 200.332 § 200.521

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements...

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location, and therefore we recommend standardizing the documentation of such activities. Management Response Corrective Action: We concur with this finding and the auditor’s recommendation. The Department is in the process of implementing policies and procedures to ensure proper monitoring of subrecipients. This will also include training for both the financial and the grants departments. Subrecipient monitoring tools, such as excel worksheets and checklists are being reviewed and modified to fit the Department’s needs. The complete implementation of the subrecipient policies and processes is expected to be completed June 2024. Due Date of Completion: June 30, 2024 Responsible Person(s): Chief Financial Officer, Grants Unit Manager

View Audit 291260

Finding 369751 (2023-001)

Significant Deficiency 2023

D Street Senior Housing, Inc.

MI

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Agreed. Management made a deposit to the reserve for replacement on August 18, 2023 for $7,000.

View Audit 291250 Questioned Costs: $1

Finding 369730 (2023-007)

Significant Deficiency 2023

Springs Valley Community Schools Corporation

IN

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

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corre...

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future, the school corporation’s management will ensure a clause will be added to all contractor’s contracts stating they are following all Davis-Bacon wage laws when federal funds are being used to fund the project. Anticipated Completion Date: 02/16/2024

View Audit 291176

Finding 369720 (2023-005)

Material Weakness 2023

Springs Valley Community Schools Corporation

IN

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

Finding 2023-005 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Descript...

Finding 2023-005 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, primary and secondary review of all federal accounts payable claims. Anticipated Completion Date: 02/16/2024

View Audit 291176

Finding 369699 (2023-002)

Material Weakness 2023

School District of Jennings

MO

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

The District agrees with the finding and the recommendations of the auditors. The District has taken a number of steps to improve internal controls and will finalize a comprehensive plan for robust internal controls reinstatement by January 10, 2024. Since the arrival of new Human Resources Leadersh...

The District agrees with the finding and the recommendations of the auditors. The District has taken a number of steps to improve internal controls and will finalize a comprehensive plan for robust internal controls reinstatement by January 10, 2024. Since the arrival of new Human Resources Leadership in the fall of 2022, steps have been taken to ensure that all employee contracts are kept on file in hard copy and digital. The missing files occurred during a transition period during the hire and rehire period of spring and summer 2022, before the arrival of new leadership. At this time, the Human Resources department ensures redundancy of storage of these contracts, with both paper copies and digital copies of all signed contracts kept in secure spaces. A staff member is charged to ensure these are all filed, and the Supervisor does an internal audit to ensure safekeeping. Going forward, the Human Resources Director will conduct quarterly checks, in May, August, November, and February to ensure all files are in place.

View Audit 291162

Finding 369658 (2023-001)

Significant Deficiency 2023

Portsmouth Community Health Center, INC

VA

Procurement, Suspension & Debarment Subrecipient Monitoring

Planned Corrective Action: To correct this deficiency, the Center has put the following planned corrective action in place: Management will ensure the Center’s written procurement policies are followed for all future expenditures as required. Name of Contact Person: Michel Bile, Chief Financial Offi...

Planned Corrective Action: To correct this deficiency, the Center has put the following planned corrective action in place: Management will ensure the Center’s written procurement policies are followed for all future expenditures as required. Name of Contact Person: Michel Bile, Chief Financial Officer Anticipated Completion Date: January 2024

View Audit 291044

Finding 369627 (2023-001)

Significant Deficiency 2023

Drexel Foundation for Educational Excellence, Inc.

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Significant Deficiency § 200.334

FINDING 2023-001 – DOCUMENT RETENTION – Significant Deficiency Planned correcive action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will provide additional training to school staff that are responsible for maintaining records that i...

FINDING 2023-001 – DOCUMENT RETENTION – Significant Deficiency Planned correcive action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will provide additional training to school staff that are responsible for maintaining records that identify the poverty levels of students enrolled. Additionally, EVE shall conduct an internal audit to ensure that documents are being collected and stored appropriately. Responsible officers: Lili Cruz-Gilbes, Regional Director of Compliance and State Reporting Estimated completion date: March 15, 2024

View Audit 291003

Finding 369579 (2023-001)

Significant Deficiency 2023

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

HUD Housing Programs Subrecipient Monitoring

Statement of Condition 2023-001 (Assistance Listing 14.181): During the year ended October 31, 2023, 1 of the move-out resident files selected for testing under the Compliance supplement were missing necessary documents required by the PRAC and Hud Handbook 4350.3. Recommendation: Management shoul...

Statement of Condition 2023-001 (Assistance Listing 14.181): During the year ended October 31, 2023, 1 of the move-out resident files selected for testing under the Compliance supplement were missing necessary documents required by the PRAC and Hud Handbook 4350.3. Recommendation: Management should ensure that all resident files are maintained at the site for each resident of the Property in accordance with the HUD Handbook 4350.3. Management Response: Management agrees with the recommendation and will ensure that resident files are retained in accordance with the terms of the PRAC and HUD Handbook 4350.3.

View Audit 290960

Finding 369551 (2023-001)

None 2023

Shawmet Homes, Inc.

MO

Subrecipient Monitoring

Condition: Federal Award Programs Audits - The Organization was notified it did not pass its physical REAC inspection. Recommendation: The Organization should adopt a policy which requires periodic (more than annual) review of its operating and maintenance policies and procedures, as well as review ...

Condition: Federal Award Programs Audits - The Organization was notified it did not pass its physical REAC inspection. Recommendation: The Organization should adopt a policy which requires periodic (more than annual) review of its operating and maintenance policies and procedures, as well as review by the individuals monitoring the operating and maintenance of the property, to ensure that physical maintenance of the property is within good standing. View of Responsible Officials and Corrective Actions: Financial Reporting - Shawmet Homes, Inc. will take the corrective action to meet all of the requirements as indicated and agreed to by HUD. Anticipated Completion Date: Completion date to reflect full compliance in reporting will be resolved within the HUD requirements.

View Audit 290839

Finding 369541 (2023-002)

Significant Deficiency 2023

Child and Family Agency of Southeastern Connecticut, Inc.

CT

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

Audit Finding Reference: 2023-002 Recommendation: The Agency should establish a system of controls to ensure that expenditures of the grant are allowable under the grant conditions.Plan of Action:  CFA agrees with the auditors finding. Management will develop a written procedure to ensure that p...

Audit Finding Reference: 2023-002 Recommendation: The Agency should establish a system of controls to ensure that expenditures of the grant are allowable under the grant conditions.Plan of Action:  CFA agrees with the auditors finding. Management will develop a written procedure to ensure that proper action is taken at the time the invoice is submitted for approval. This will include reviewing the cost principles in Subpart E of the Uniform Guidance with the appropriate staff to ensure they are charging allowable costs to the grant. A system of internal controls will be developed and reviewed to ensure that all grant expenditures are allowable under the regulations of the grant. We anticipate having this written procedure ready by February 29, 2024. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please contact Lisa Baxter. BaxterL@ChildandFamilyAgency.org Sincerely yours, Lisa Baxter Chief Financial and Administrative Officer

View Audit 290825

Finding 369535 (2023-001)

Significant Deficiency 2023

Child and Family Agency of Southeastern Connecticut, Inc.

CT

Procurement, Suspension & Debarment Subrecipient Monitoring

Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Name of Contact Person: Lisa Baxter, Chief Financial and Administrative Officer Audit Fi...

Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Name of Contact Person: Lisa Baxter, Chief Financial and Administrative Officer Audit Finding Reference: 2023-001 Recommendation: We recommend the system of controls for procurement, suspension and debarment are updated to properly address the necessary requirements. Plan of Action: CFA agrees with the auditors finding. Management will develop a written procedure to ensure that proper action is taken at the time the invoice is submitted for approval. We anticipate having this written procedure ready by February 29, 2024. As of today the vetting process is being applied by our HR staff with current subcontractors and staff working in the federally funded programs.

View Audit 290825

Finding 369513 (2023-003)

Material Weakness 2023

Rapid City Club for Boys, Inc.

SD

Internal Control / Segregation of Duties Subrecipient Monitoring

Finding No 2023-003: Heartland Heights Apartments Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has met with Lloyd Property Management and has been receiving regular financial statements. The Organization will implement a plan to evaluate internal cont...

Finding No 2023-003: Heartland Heights Apartments Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has met with Lloyd Property Management and has been receiving regular financial statements. The Organization will implement a plan to evaluate internal controls to ensure adequacy and effectiveness. Anticipated Completion Date: Ongoing

View Audit 290783

Finding 369499 (2023-001)

Significant Deficiency 2023

Wells College

NY

Student Financial Aid Subrecipient Monitoring

Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The fin...

Wells College (the College) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2022 - June 30, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT Finding 2023-001 - Student Financial Assistance Cluster Compliance Requirement N. Gramm-Leach-Bliley Act-Student Information Security Recommendation: Our auditors recommend that we conduct a formal risk assessment and update our written information security program (WISP) to ensure the seven required elements are addressed. As part of this process, Information Technology (IT) policies should be updated to align with our current IT environment and be formally approved and implemented throughout the College. Action Taken: Wells College is partnering with Grey Castle Security to do a Risk Assessment and Penetration test. This will be completed in February. Additionally, Grey Castle has helped to redraft our Incident Response Plan. This has been completed, and training on this plan is scheduled for later in January, with Tabletop simulations occurring with the Wells College Emergency Planning Team and IT in February. Over the next couple of months, IT will be refreshing its policies in collaboration with the Wells College Technology Advisory Group (TAG), a committee representing all areas of the college. Once TAG has approved policies, they will go to the Cabinet for approval. Multiple policies will be merged to create the WISP as a self-contained document, rather than the multiple policies in place. The Chief Financial Officer, Robert Cree, is responsible for implementing this plan by June 30, 2024, and can be reached at (315) 364-3408 or rcree@wells.edu .

View Audit 290774

Finding 369473 (2023-003)

Significant Deficiency 2023

Western Seminary

OR

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhan...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhancing the documentation and reporting of our internal security audits. Person Responsible for Corrective Action Plan: Sean Gordon, Director of Information Technology Operations and Software Development Anticipated Date of Completion: June 30, 2024

View Audit 290692

Finding 369423 (2023-003)

Material Weakness 2023

Newberry College

SC

Student Financial Aid Subrecipient Monitoring Material Weakness

Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion...

Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024

View Audit 290607

Finding 369355 (2023-001)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the Col...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024

View Audit 290586

Finding 369351 (2023-001)

Significant Deficiency 2023

New Mexico Aging and Long-Term Services Department

NM

Cash Management Subrecipient Monitoring Significant Deficiency

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division...

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division (ASD) has processed the OPR for return of the $10,958 to the Department of Health. ALTSD will implement training for agency directors and other leaders who oversee and implement grant projects. This training will include the process for development of the initial budget allocations to appropriate categories grant procedures for requesting changes to the budget categories from the funder. The training will also include a process for streamlined communication between the director or manager and the ASD grant staff responsible for the financial controls. Timeline of Corrective Actions: Perform first training to any programmatic grant manager or involved staff by January 1, 2024. This will be ongoing any time a new grant award is received by the agency. Responsible Party(ies): Chief Financial Officer

View Audit 290577

Finding 369348 (2023-002)

Material Weakness 2023

Valparaiso Community Schools

IN

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

Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon...

Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon wage rate requirement language has been added to all bid packets and quote solicitations. The Educational Support Coordinator and Deputy Treasurer will work with VCS Department Directors to monitor all federally-funded construction projects for compliance with said language. Anticipated Completion Date: February 1, 2024

View Audit 290574

Finding 369341 (2023-001)

Material Weakness 2023

Columbia Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness

Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in ag...

Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the agreement with West Roofing to install and renovate the HVAC system at Columbia High School, which was January 7, 2021, ESSER funds were not awarded to the District. The District planned on using its Permanent Improvement funds (a non -federal program sourced fund) to pay West Roofing. The District initially paid West Roofing from the Permanent Improvement fund for the installation/renovation of the HYAC at Columbia High School as per the initial contract. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through ESSER funds. The prevailing wage was not met under the existing contract. The District has implemented the following Action Plan for Correction: 1. The Treasurer will ensure that all agreements intended to be sourced through Federal Funds will contain prevailing wage rate provisions prior to signing such agreements. 2. The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Funds, 3. The Treasurer will educate all responsible parties in the District regarding prevailing wage documentation to ensure appropriate documentation is obtained prior to payment to the contractors and prior to requesting Federal Funds.

View Audit 290568

Finding 369320 (2023-005)

Significant Deficiency 2023

Great Plains Food Bank

ND

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individu...

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate

View Audit 290553 Questioned Costs: $1

Corrective Action Plans

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