Corrective Action Plans

Finding 375459 (2023-003)

Significant Deficiency 2023

Reading Muhlenberg Career & Technology Center

PA

Questioned Costs 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

Finding 374544 (2023-001)

Material Weakness 2023

South Florida Regional Transportation Authority

FL

Reporting Subrecipient Monitoring § 200.502 § 200.508 § 200.510 § 200.71

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective action has been implemented to revise internal procedures to prepare the SEFA on a cash basis fo...

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective action has been implemented to revise internal procedures to prepare the SEFA on a cash basis for future fiscal years. This includes the creation of a reconciliation schedule to the financial statements which are prepared on an accrual basis. Contact person responsible for corrective action: Jeremy Baker, Director of Finance Anticipated Completion Date: 1/15/2024

View Audit 294245

Finding 374517 (2023-001)

None 2023

Saddleback Valley Unified School District

CA

Equipment & Real Property Management Questioned Costs Procurement, Suspension & Debarment § 200.311 § 200.313 § 200.439

The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. ...

The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. While the components of the SVI project are under the $5,000 threshold for prior approval collectively they are over this threshold. The components being under the $5,000 threshold resulted in an oversight of the needed preapproval for these purchases. Fiscal Services is developing a checklist of required steps in the procurement process when federal funds are being considered to ensure prior approval, if needed, is sought prior to purchase. The checklist will include an area where each component is listed to include delivery cost and installation and will include acknowledgement of whether these components collectively create one asset. This will allow other staff reviewing the checklist to determine if preapproval based on cost may be needed. The checklist will require approval of the department head of the requesting department acknowledging understanding of the federal purchasing requirements for capital expenditure as well as, approval of the Director, Fiscal Services and the District's Assistant Superintendent of Business Services.

View Audit 294238 Questioned Costs: $1

Finding 374501 (2023-001)

Significant Deficiency 2023

National Endowment for Democracy

DC

Questioned Costs Subrecipient Monitoring Reporting

NED management has been aware of the FFATA reporting requirements and takes a serious approach to FFATA regulations. NED's concerns regarding FFATA compliance are rooted in concern for personal and physical safety of our grantees working in the sphere of human rights and democracy, particularly thos...

NED management has been aware of the FFATA reporting requirements and takes a serious approach to FFATA regulations. NED's concerns regarding FFATA compliance are rooted in concern for personal and physical safety of our grantees working in the sphere of human rights and democracy, particularly those NED partners working in the world's most hostile authoritarian countries. As stated in our response to the FY2022 Audit, NED staff analysis of the potential reporting requirements recognized two significant risks to NED's partners and the success of its programs: 1) reporting all first-tier sub awardees would mean posting the identity of recipients and details of sensitive awards on a publicly accessible website, and 2) reporting NED partners as first-tier sub awardees of the Department of State (DOS) on a public website of federal funding accountability undermines the Congress' intentional decision to protect the independence of NED's programmatic decision-making when it crafted the NED Act. With the intention of balancing the legitimate concerns for our NED grantees with our desire to comply with the spirit of transparency and accountability rooted in FFATA, NED renewed discussions with Department of State officials to find a resolution to this issue. The leadership at NED and at State’s Bureau of Democracy, Human Rights, and Labor jointly assessed the issue to determine a long-term solution. Following the development of a Duty of Care policy outlining NED’s institutional obligations to “do no harm” with respect to the safety and security of our stakeholders, including NED grantees, NED management has since reached an agreement with our DOS Grants Officer to designate NED’s annual appropriation award as “sensitive” and therefore not subject to the annual FFATA reporting requirements. We have since received NED’s annual award for2024 with language matching several of our special funds DOS awards: “This award has been deemed sensitive and is not subject to the Federal Funding Accountability and Transparency Act (FFATA).” We expect the same terms to apply to our awards going forward which, ensuring a permanent resolution to this issue. Name of Responsible Official: Nancy Herzog, Title: VP, Grant Operations & Evaluation Date correction action executed: 11/29/2023.

View Audit 294218

Finding 374493 (2023-003)

Significant Deficiency 2023

Lighthouse Community Public Schools

CA

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.320

Views of responsible officials and Corrective Action Plan: Management of the School has noted the 2 CFR Section 200.320 to ensure that the procurement requirements are met.

View Audit 294202

Finding 374483 (2023-003)

Significant Deficiency 2023

Millersburg Area School District

PA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.320

Corrective Action Planned: When the District decides to utilize cooperative purchasing programs on noncompetitive purchasing arrangements when spending federal funds, it will ensure that it complies with its procurement policy. The District will document its process and how it complies with the pr...

Corrective Action Planned: When the District decides to utilize cooperative purchasing programs on noncompetitive purchasing arrangements when spending federal funds, it will ensure that it complies with its procurement policy. The District will document its process and how it complies with the procurement standards and keep such documentation with federal award budget/procurement documents. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding for the year ending June 30, 2024. Contact Person Responsible: Eric S. Petery, Business Manager

View Audit 294158

Finding 374480 (2023-002)

Significant Deficiency 2023

Millersburg Area School District

PA

Questioned Costs Subrecipient Monitoring Cash Management

Corrective Action Planned: The District will review and establish procedures that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods. A new federal programs coordinator has been hired and the District has consulted with an expe...

Corrective Action Planned: The District will review and establish procedures that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods. A new federal programs coordinator has been hired and the District has consulted with an experienced federal programs coordinator to train that individual. Procedures are now in place to ensure that the District files all quarterly cash on hand reports within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. All existing compliance issues related to filing deadlines are being addressed and corrected. Anticipated Completion Date: Acton has already been taken by the District to resolve the underlying issue of the finding for the year ending June 30, 2024. Contact Person Responsible: Eric S. Petery, Business Manager

View Audit 294158

Finding 374479 (2023-001)

Significant Deficiency 2023

Brattleboro Development Credit Corporation

VT

Reporting Subrecipient Monitoring Significant Deficiency

Audit Finding Reference: 2023-001 Improve Controls and Timing of Reporting Planned Corrective Action: The Organization currently has written Grant Management Policies, and Management agrees with this finding, that these policies do not adequately address the Federal Funding Accountability and Tran...

Audit Finding Reference: 2023-001 Improve Controls and Timing of Reporting Planned Corrective Action: The Organization currently has written Grant Management Policies, and Management agrees with this finding, that these policies do not adequately address the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 which requires recipients (i.e., direct recipients) of grants or cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The Organization will update its Grant Management Policies to address the requirements of the Federal Funding Accountability and Transparency Act, and once formally adopted, the Organization will distribute the new policies and procedures to necessary staff, as well as advise and train its staff on following such policies and procedures. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: Director of Finance & Grant Management

View Audit 294142

Finding 374472 (2023-002)

Significant Deficiency 2023

Bay De Noc Community College

MI

Subrecipient Monitoring Questioned Costs Special Tests & Provisions

Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the eva...

Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. As a result of this condition, the College is not meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. Corrective Action. Currently, the College is reviewing the compliance requirements for the Gramm Leach Bliley Act and will amend the current policy to ensure that each safeguard is being addressed within the policy. Responsible Person. Jonathan Lane, Director of IT. Anticipated Completion Date. June 30, 2024

View Audit 294140

Finding 374462 (2023-002)

Significant Deficiency 2023

Latino Network

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring

2023-002 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Allowable Costs Context: Expenditures should be charged to the proper programs and allocated in accordance with the cost allocation plan and documentation of approval of any subsequent change to the alloc...

2023-002 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Allowable Costs Context: Expenditures should be charged to the proper programs and allocated in accordance with the cost allocation plan and documentation of approval of any subsequent change to the allocation plan should be maintained. Recommendation: We recommend management implement procedures to ensure that costs charged to the grant follow the approved cost allocation and documentation of approved changes to allocations be maintained. Action Taken: Management concurs with the auditor’s finding and will enhance documentation protocols, standardize the approval process, and have regular reviewing and monitoring.

View Audit 294126

Finding 374435 (2023-005)

Material Weakness 2023

Lawrenceburg Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

View Audit 294097

Finding 374431 (2023-003)

Material Weakness 2023

Lawrenceburg Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-003 Finding Subject: COVID-19 Emergency Connectivity Fund Program - Suspension and Debarment Summary of Findings: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and...

FINDING 2023-003 Finding Subject: COVID-19 Emergency Connectivity Fund Program - Suspension and Debarment Summary of Findings: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have adequate procedures in place to ensure that vendors were not suspended or debarred before entering into a covered transaction. Suspension and Debarment Before entering into subawards and covered transactions with program funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Two covered transactions were identified that equaled or exceeded $25,000. Both transactions, totaling $837,454 were selected for testing. For the noted transactions, the School Corporation did not verify the vendor’s suspension and debarment status before the payment due to the School Corporation not having any policies or procedures in place to verify that contractors were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When purchasing goods or services using Federal dollars a search will be conducted to verify that the vendor is not suspended or disbarred from receiving federal funds. If the vendor is not located in the Sam.gov database; we will reach out to the vendor and request a statement verifying this. If a contract is signed between LCSC and the vendor; we will request that suspension and disbarment language be included in the contract. Anticipated Completion Date: February 2024

View Audit 294097

Finding 374411 (2023-001)

Significant Deficiency 2023

York College of Pennsylvania

PA

Student Financial Aid Reporting Subrecipient Monitoring

Corrective Action Planned: The College has noted the issue and it has since been rectified and has re-ran the process to provide the proper effective dates for withdrawn students to the National Student Clearinghouse. The College does report to the National Student Clearinghouse every 30 days. The C...

Corrective Action Planned: The College has noted the issue and it has since been rectified and has re-ran the process to provide the proper effective dates for withdrawn students to the National Student Clearinghouse. The College does report to the National Student Clearinghouse every 30 days. The College has reviewed their policies and procedures to ensure proper reporting requirement procedures to NSC and NSLDS. Training has been provided to those responsible for manual adjustments to records having extenuating circumstances. Name(s) of Contact Person(s) Responsible for Corrective Action: Eric Dinsmore, Senior Director of Financial Aid Anticipated Completion Date: As of January 2024, withdrawal student status change effective dates have been corrected. The College has reviewed reporting policies and procedures and has provided training to responsible parties for manual reporting whenever extenuating circumstances occur. The College will implement any additional necessary changes in 2024 fiscal year.

View Audit 294058

Finding 374389 (2023-005)

Significant Deficiency 2023

Bethany College

KS

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency

Corrective Action Plan 2023-005: The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2024 Contact Person: Joshua Bieber, Director of Information Technology

View Audit 293985

Finding 374382 (2023-003)

Significant Deficiency 2023

Bethany College

KS

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

Corrective Action Plan 2023-003: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and e...

Corrective Action Plan 2023-003: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2024 Contact Person: Steven W. Eckman, President

View Audit 293985

Corrective Action Plans

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