Corrective Action Plans

Finding 39681 (2022-001)

Significant Deficiency 2022

IL

Subrecipient Monitoring Procurement, Suspension & Debarment HUD Housing Programs

Findings 2022 - 001 Community Development Block Grant (CDBG)/Entitlement Grants Federal Assistance Listing Number 14.218 Corrective Action Plans: The Department of Planning and Dev...

Findings 2022 - 001 Community Development Block Grant (CDBG)/Entitlement Grants Federal Assistance Listing Number 14.218 Corrective Action Plans: The Department of Planning and Development (DPD) will update the current Policies and Procedures established for complying with Federal Funding Accountability and Transparency Act Subaward Reporting System and update the Sub-Recipients Required Information Form to inform staff of the threshold criteria which requires reporting of each subrecipient receiving $30,000.00 or more of CDBG funding. The updated form will include 1) HUD links identified below that will provide clarification, from archived trainings and 2) the latest regulations to ensure collection of pertinent and full award information. FSRS - Federal Funding Accountability and Transparency Act Subaward Reporting System https://www.hud.gov/program_offices/comm_planning/FSRS https://www.hudexchange.info/trainings/courses/fsrs-reporting-at-hud-cpd-learning-session/ https://files.hudexchange.info/resources/documents/ffata-subaward-reporting-system-webinar-slides.pdf DPD will incorporate a review of these processes during the department?s evaluation of Grant Agreement Execution procedures. Responsible Staff Person ? Deputy Director of Community Development DPD Schedule for Completion ? October 30, 2023 Anticipated Timeline for full Implementation of Corrective Action ? December 30, 2023

View Audit 37825

Finding 39668 (2022-001)

Significant Deficiency 2022

World Vision International and World Vision Inc.

WA

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment

Finding 2022-001 ? Reporting - Late filing of FFATA required reports World Vision implemented an improved control process for collecting required information and trained relevant staff on the strengthened review procedures and the importance of submitting FFATA reports prior to the due date. Contact...

Finding 2022-001 ? Reporting - Late filing of FFATA required reports World Vision implemented an improved control process for collecting required information and trained relevant staff on the strengthened review procedures and the importance of submitting FFATA reports prior to the due date. Contact Person Responsible for Correct Action: Kenneth E. Botka Completion Date: March 11, 2022

View Audit 37786

Finding 39649 (2022-001)

Material Weakness 2022

Little Rock School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. ...

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. Condition: In our test of equipment purchases from the COVID-19 Education Stabilization Fund, we identified the purchase of 447 pieces of equipment with the unit costs greater than the $5,000 threshold for which the District did not obtain prior written approval from the Arkansas Division of Elementary and Secondary Education (DESE). Retroactive approval was subsequently obtained from DESE during the audit fieldwork. LRSD Response: The District will continue to monitor internal controls in regards to use of ESSER funds and ensure all prior approvals are granted by DESE before purchasing of capital assets with a unit value equal to or greater than $5,000. Responsible LRSD Staff: Kelsey Bailey, CDFO, will be responsible for ensuring compliance. Completion Date: Kelsey Bailey has made contact with Jayne Greene at DESE for guidance and retroactive approval was granted from DESE on March 9, 2023. Please let me know if additional information is needed. Respectfully, Kelsey Bailey Chief Deputy Finance & Operations Officer

View Audit 37215 Questioned Costs: $1

Finding 39622 (2022-003)

None 2022

Central Dewitt Community School District

IA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management § 200.313

The District will review current processes for purchasing equipment within Iowa Department of Education approval amounts or seek amendments when approval cost limits cannot be met. June 30, 2023 Cyndie Johnson

View Audit 46139 Questioned Costs: $1

Finding 39609 (2022-001)

Material Weakness 2022

Crescent School District No. 313

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Ashley Petersen, Business Manager PO Box 20 Joyce, WA 98343 (360) 928-3311 ext 1005 Corre...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Ashley Petersen, Business Manager PO Box 20 Joyce, WA 98343 (360) 928-3311 ext 1005 Corrective action the auditee plans to take in response to the finding: The following corrective action has been applied to the finding below: Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clauses in the contracts with two contractors o The Crescent School District contract used for all public works will be updated with the appropriate language. The school is utilizing information from SAO, OSPI, WASBO, and Business Manager peers to compile a contract that complies with state and federal requirements. ? Collect weekly certified payroll reports from the contractors to confirm they paid laborers proper prevailing wages o Crescent School District will use the LNI Contractor Awards Portal for tracking all public works projects. The portal will help track all necessary documents for the project. A checklist provided by OSPI will be referenced for each project and calendar reminders will be set to follow up on weekly prevailing wage for projects as needed. In addition, more training for public works will be strongly encouraged for the Business Office. Anticipated date to complete the corrective action: ASAP

View Audit 44823

Finding 39608 (2022-003)

Material Weakness 2022

Friendly House, Inc.

AZ

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

2022-003 Cash Management Material Noncompliance Cash Management Material Weakness in Internal Control over Compliance U.S. Department of Health and Human Services Passed-through the Arizona Department of Economic Security Refugee and Entrant Assistance State Administered Federal Financial Assistance...

2022-003 Cash Management Material Noncompliance Cash Management Material Weakness in Internal Control over Compliance U.S. Department of Health and Human Services Passed-through the Arizona Department of Economic Security Refugee and Entrant Assistance State Administered Federal Financial Assistance Listing/CFDA #93.566; ADES18-191650; October 1, 2020 to September 30, 2021 and October 1, 2021 to September 30, 2022 Condition: Eide Bailly LLP (EB) noted that four out of four draw requests did not have adequate support for the class hours included. Management?s Response and Corrective Action Plan: ? Monthly Attendance Report are completed by data specialist using individual teachers? daily rosters. ? The Monthly Attendance Reports are verified by the program manager and corrected if any mistakes are identified. ? Monthly invoices are reviewed, prior to submission, with the Department Manager for additional verification and approval. ? After the student attendance has been reviewed by Program Manager and verified by the Department Manager, a review log is signed off by both the Program Manager and the Department Manager. ? Any changes to either the attendance logs or monthly student attendance will only be made with the authorization of the department manager after data has been verified, with an explanation of why that was needed. ? After the appropriate verifications have taken place, the Program Manager creates the monthly invoice, they will maintain and verify documentation for the student attendance hours reflected on the invoice. ? Management will continue to discuss and explore ways to strengthen our current internal controls, including, purchasing tracking software and/or the creation of a google form/document. ? Management will routinely review and consider any needed modifications to or implementation of new policies and procedures that would strengthen internal controls surrounding the invoicing process, record-keeping, and the management thereof. Contact Person: Jose J. Vaquera, VP of Client Services Anticipated Completion Date: May 15, 2023

View Audit 37105

Finding 39508 (2022-001)

Significant Deficiency 2022

Sanford

SD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213 § 200.303

Finding 2022-001 ? Suspension and Debarment Information on the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Planned corrective actions: As it relates to the reliance on the third-party vendor that conducts suspension and deb...

Finding 2022-001 ? Suspension and Debarment Information on the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Planned corrective actions: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventative and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to the vendors that are suspended or debarred. Sanford believes the risk of any material disbursement to suspended and debarred vendor is effectively mitigated through existing preventative and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process. Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Executive Director of Supply Chain Anticipated completion date: August 31, 2023

View Audit 34025

Finding 39507 (2022-004)

Significant Deficiency 2022

South Lane School District No 45j3

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure ...

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure that all items recorded have required approval.

View Audit 34125

Finding 39497 (2022-001)

Significant Deficiency 2022

Population Services International

DC

Subrecipient Monitoring § 200.303 § 200.328

2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Marcie Cook, Susan Mukasa Title: Vice Presidents, Global Operations Phone Number: 202 753 7532 / 202 734 7784 Estimated Completion Date ? ongoing ...

2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Marcie Cook, Susan Mukasa Title: Vice Presidents, Global Operations Phone Number: 202 753 7532 / 202 734 7784 Estimated Completion Date ? ongoing Corrective Action PSI will focus on continuous improvements to the reporting tracking system (D-Tracker) that ensures each contract has a clear program and financial reporting deadlines. The Program Management Team will keep working with Project Directors to confirm accuracy of the report deadlines in D-Tracker. Quarterly reports will be run to confirm upcoming reports due in the quarter and be shared with appropriate staff to ensure that deadlines are met or approvals to extend due dates are appropriately documented. Training will be provided throughout the year so that monitoring is part of the standard procedure.

View Audit 46560

Finding 39441 (2022-001)

Significant Deficiency 2022

County of Kent, Michigan

MI

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

2022-001 ? Housing Quality Standards (HQS) Inspections Auditor Description of Condition and Effect: In the prior year single audit, 1 out of 40 tenants selected for testing did not receive an HQS inspection within the two year window as of December 31, 2021. This tenant did not appear on the appro...

2022-001 ? Housing Quality Standards (HQS) Inspections Auditor Description of Condition and Effect: In the prior year single audit, 1 out of 40 tenants selected for testing did not receive an HQS inspection within the two year window as of December 31, 2021. This tenant did not appear on the appropriate reports that would have generated inspection letters to be sent, and so was overlooked in the process. Per management inquiry, as part of current year testing, the County still has a small list of tenants for this program that have not had an HQS inspection during the two year window as of December 31, 2022. Because of this condition there was an increased risk that required inspections would not be completed timely. Auditor Recommendation: The County should update its tracking process for determining which units are due for HQS inspection, so that all units that have not been inspected within the two year window will be considered. Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. Management has reviewed its existing procedures and has already made revisions, as appropriate, to ensure that all applicable requirements are considered in the monitoring process. Responsible Party. Community Action Department staff Date of Planned Corrective Action. September 2023

View Audit 43998

Finding 39439 (2022-002)

None 2022

County of Kent, Michigan

MI

Subrecipient Monitoring Reporting

2022-002 ? Special Reporting for Federal Funding Accountability and Transparency Act Auditor Description of Condition and Effect: Per inquiry of County management, they were not aware of the subaward submission requirements and no one from an outside agency has contacted them to alert them to this ...

2022-002 ? Special Reporting for Federal Funding Accountability and Transparency Act Auditor Description of Condition and Effect: Per inquiry of County management, they were not aware of the subaward submission requirements and no one from an outside agency has contacted them to alert them to this delinquent reporting. Because of this condition the County did not fully comply with all aspects of the above mentioned programs. Auditor Recommendation: The County should update its policies and procedures to assure that all changes in federal award compliance over reporting are captured and applied. Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. Management has reviewed its existing procedures and has already made revisions, as appropriate, to ensure complicate with Federal Funding Accountability and Transparency Act reporting requirements. Responsible Party. Community Action Department staff Date of Planned Corrective Action. September 2023

View Audit 43998

Finding 39428 (2022-001)

Material Weakness 2022

Council of Community Services

WY

Internal Control / Segregation of Duties Subrecipient Monitoring

2022? 001 - Segregation of Duties Condition/Context: Council staff have limited segregation of duties for all transactions of the entity. The Council?s staff is not large enough to permit adequate segregation of duties. This lack of segregation of duties does not allow management to detect and corr...

2022? 001 - Segregation of Duties Condition/Context: Council staff have limited segregation of duties for all transactions of the entity. The Council?s staff is not large enough to permit adequate segregation of duties. This lack of segregation of duties does not allow management to detect and correct a material misstatement if present. Due to the size of the Council?s staff it is anticipated that this will be an ongoing finding. Compensating controls are in place; however, this continues to be an ongoing finding. Recommendation: In our judgment, management and those charged with governance need to understand the importance of this communication. However, due to the lack of resources available to management to correct this weakness, we recommend that management mitigate this weakness with possible compensating controls such as close supervision and monitoring by management and by the Board of Directors. Corrective Action Planned: The Council of Community Services has a full-time bookkeeper with adequate experience, continues to have Board involvement, and actively seeks new Board members with financial experience. We also added a Board member who is a Certified Public Accountant that also sits on the Finance Committee of the Board. This additional oversight adds layers of supervision and monitoring which should allow any intentional fraud or unintentional errors to be prevented or detected and corrected in a timely manner. Compensating controls are in place; however, this continues to be an ongoing finding. Contact Mikel Scott ? Executive Director Anticipated Completion Date Due to the size of the staff, this is expected to be an ongoing finding, all compensating controls have been in place since 2015.

View Audit 36832

Finding 39338 (2022-002)

Significant Deficiency 2022

University of the Sciences in Philadelphia

PA

Subrecipient Monitoring Special Tests & Provisions

As discussed in Note A to the financial statements, the University merged with and into Saint Joseph?s University on June 1, 2022.

View Audit 46684

Finding 39333 (2022-001)

Material Weakness 2022

Housing Authority of the City of Live Oak

FL

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

HOUSING AUTHORITY OF THE CITY OF LIVE OAK 406 Webb Drive N.E. Live Oak, Florida 32064 Phone (386) 362-2123 Fax (386) 364-8346 Corrective Action Plan ? March 31, 2022 Audit Findings 2022-1 Condition: Deficiencies Were Noted in Our Examination of Procurement Steps to resolve: We concur wit...

HOUSING AUTHORITY OF THE CITY OF LIVE OAK 406 Webb Drive N.E. Live Oak, Florida 32064 Phone (386) 362-2123 Fax (386) 364-8346 Corrective Action Plan ? March 31, 2022 Audit Findings 2022-1 Condition: Deficiencies Were Noted in Our Examination of Procurement Steps to resolve: We concur with the Auditor?s recommendation. We will review and update all our Procurement Policies to ensure that all contracts are in compliance with HUD regulations. Timeframe: By FYE March 31, 2023 Individual responsible for correction: Nathaniel Smith, Executive Director

View Audit 43828

Finding 39198 (2022-005)

Material Weakness 2022

Oakland County, Michigan

MI

Subrecipient Monitoring

Finding Number: 2022-005 Condition: The County did not have proper controls regarding subrecipient monitoring in place during the year under audit. Planned Corrective Action: Currently Working with Guidehouse on creating a more efficient process for subrecipient monitoring. Contact person responsibl...

Finding Number: 2022-005 Condition: The County did not have proper controls regarding subrecipient monitoring in place during the year under audit. Planned Corrective Action: Currently Working with Guidehouse on creating a more efficient process for subrecipient monitoring. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 11/30/2023

View Audit 37913

Finding 39142 (2022-007)

Material Weakness 2022

Oakland County, Michigan

MI

Subrecipient Monitoring Reporting

Finding Number: 2022-007 Condition: The County did not file the required FFATA reports for CDBG subrecipients. Planned Corrective Action: Priority is being placed on filing the FFATA reports. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 12/31/2023

View Audit 37913

Finding 39137 (2022-001)

Significant Deficiency 2022

Management Sciences for Health, Inc.

MA

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting

Finding Number: 2022-001 Late subrecipient monitoring submission Federal Program(s) HS4TB-Global (ALN 98.U10) Management Corrective Action Plan The Senior Director of Finance has taken on an active oversight role for the Contracts and Award Management team, prioritizing the review of tracking of pro...

Finding Number: 2022-001 Late subrecipient monitoring submission Federal Program(s) HS4TB-Global (ALN 98.U10) Management Corrective Action Plan The Senior Director of Finance has taken on an active oversight role for the Contracts and Award Management team, prioritizing the review of tracking of project reporting requirements. He will review the current system for tracking the FFATA report requirements by including automatic population of the system from MSH?s Contract/Subaward management system. MSH will continue to use a designated mailbox and designated contract/award specialist for primary point of responsibility of monthly FSRS reporting. In addition to the current step of having the Specialist?s supervisor review the uploading of FSRS reports, a list of all subawards issued will be circulated to all MSH contract/award officers for monthly review and sign off prior to the close of the FSRS reporting period. MSH agrees with this finding. Individuals Responsible for Corrective Action Plan Gordon Kihuguru Chief Financial Officer (703) 667-3959 Completion date: 12/31/2022

View Audit 37083

Finding 39135 (2022-003)

Significant Deficiency 2022

Connecticut Fair Housing Center, Inc.

CT

Subrecipient Monitoring HUD Housing Programs Reporting

FINDING 2022-003 Condition: The Organization did not report sub-awards on the Federal Sub-award Reporting System (FSRS)Website www.FSRS.gov. The reporting was not done for any of the four sub-awards associated with the major program tested. Amounts passed through to these subrecipients include $42...

FINDING 2022-003 Condition: The Organization did not report sub-awards on the Federal Sub-award Reporting System (FSRS)Website www.FSRS.gov. The reporting was not done for any of the four sub-awards associated with the major program tested. Amounts passed through to these subrecipients include $428,651 of subrecipient expenditures during 2022. Total new sub-awards made during 2022 were $1,749,827 and total cash paid to sub-award recipients was $43,496 during 2022. Recommendation: The Organization should reevaluate its procedures and controls regarding federal subaward reporting to ensure proper compliance and should also complete the necessary reporting. Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the recommendation noted above by October 31, 2023.

View Audit 37910

Finding 39076 (2022-004)

Significant Deficiency 2022

North Newton School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

FINDING 2022-004 Contact Person Responsible for Corrective Action: Karen Zackfia, Director of Business and Finance Contact Phone Number: Karen Zackfia, 219-285-2228 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement and Suspension and Deba...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Karen Zackfia, Director of Business and Finance Contact Phone Number: Karen Zackfia, 219-285-2228 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement and Suspension and Debarment compliance requirements were not met because a system of internal controls had not been established by Cooperative School Services. The North Newton School Corporation is a participating member school corporation of Cooperative School Services, a special education cooperative. Cooperative School Services has developed internal controls to ensure the Procurement and Suspension and Debarment compliance requirements are met. North Newton School Corporation will implement internal controls to ensure that Cooperative School Services is complying with Procurement and Suspension and Debarment compliance requirements. Anticipated Completion Date: The corrective action plan will be implemented on March 16, 2023.

View Audit 46473

Finding 39067 (2022-001)

Significant Deficiency 2022

Indiana Humanities Council, Inc.

IN

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action Plan February 13, 2023 National Endowment for the Humanities Indiana Humanities Council respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent public accounting firm: Blue & Co. 12800 N Meridian St, Ste 400 Ca...

Corrective Action Plan February 13, 2023 National Endowment for the Humanities Indiana Humanities Council respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent public accounting firm: Blue & Co. 12800 N Meridian St, Ste 400 Carmel IN 46032 Audit period: 11/1/2021-10/31/2022 FEDERAL AWARD FINDINDS AND QUESTIONED COSTS 2022-001 ? Matching Requirements Condition: IH grant management system contained errors that led to the misaccumulation of matching dollars reported to the NEH. Recommendation: We recommend that controls surrounding the accumulation of grant information within the grant management system be established to provide accurate accumulation of matching dollars including monitoring of this information and follow up with grantees as necessary. Action Taken: We concur with the audit finding. Since this finding was first discussed in December 2022, we have taken the steps to resubmit the SF-425 for the impacted grant utilizing information from the properly reported and closed subawards. Subawards that have not yet provided a close-out report were excluded from this revised SF-425. Interim SF-425 reporting for January 31, 2023 included the match only from subawards that had been closed during the grant period - open awards were excluded. We are in the process of implementing a new grant database, which includes automated communication tools with grant recipients. One of the challenges that the grants management team has is consistently and timely communicating deadlines and expectations. By sending automated reminders ? triggered by specific events such as the end of a grant year, planned completion date of the project, etc., we can hopefully obtain more timely information from grant recipients. As well, the system will be able to trigger reports to staff of grantees who are delinquent in their reporting such that follow up can occur. If the National Endowment for the Humanities has questions regarding this plan, please call Keira Amstutz, IH President and CEO at 317-616-9379. Sincerely, Keira Amstutz President and CEO kamstutz@indianahumanities.org 317-616-9379

View Audit 46472

Finding 39057 (2022-001)

Significant Deficiency 2022

Knox Community School Corporation

IN

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2022-001 CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 Dr. Darrel L. Bobe Superintendent Terri L. Roesler Treasurer Debbie Utt Payroll/Personnel Ethan Singleton Technology Coordinator Kevin Curtis Director of Buildings & Grounds Information on the federal program: S...

Finding 2022-001 CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 Dr. Darrel L. Bobe Superintendent Terri L. Roesler Treasurer Debbie Utt Payroll/Personnel Ethan Singleton Technology Coordinator Kevin Curtis Director of Buildings & Grounds Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards and the GEER grant award. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following correction action: The treasurer will ensure that a second individual reviews and signs all future data reports prior to their submission. Responsible party and timeline for completion: Terri Roesler, Treasurer, will oversee the correction action plan. Correction action started immediately after it was brought to our attention during the audit process.

View Audit 44938

Finding 39054 (2022-006)

Significant Deficiency 2022

Converge, Inc.

MS

Subrecipient Monitoring Reporting

Management agrees with the finding. The Organization has registered in the FSRS system and will begin meeting this reporting requirement immediately.

View Audit 36881

Finding 39051 (2022-003)

Significant Deficiency 2022

Converge, Inc.

MS

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Management agrees with the finding. The Organization has hired knowledgeable staff and has implemented a process to record a receivable in the corresponding period of expenditures submitted to the federal PMS portal.

View Audit 36881

Finding 39049 (2022-001)

Material Weakness 2022

Converge, Inc.

MS

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Management agrees with the finding. The Organization is in the process of implementing a new compliance monitoring process: ? Subrecipients will receive their awards on a cost reimbursement basis. ? Subrecipient payments will be disbursed quarterly. ? Subrecipient payments will only be issued after...

Management agrees with the finding. The Organization is in the process of implementing a new compliance monitoring process: ? Subrecipients will receive their awards on a cost reimbursement basis. ? Subrecipient payments will be disbursed quarterly. ? Subrecipient payments will only be issued after submission, review, and approval of required financial and performance reports. Moving to a cost reimbursement model will reduce the risk of overstating the Organization?s revenue and expenditures and motivate subrecipients to record and submit detailed data on a quarterly basis. This new model will be effective for the grant year beginning April 1, 2023 and a memo of change is being distributed to subrecipients under contract. The Organization will work with the granting agency to determine whether the Organization will pay back the funds or will be allowed to carry them forward to the next period.

View Audit 36881 Questioned Costs: $1

Finding 38921 (2022-009)

Material Weakness 2022

Antelope Union High School District No. 50

AZ

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Condition/Context: The District spent $12,772 of federal funding on video conferencing, COVID-19 testing, charging stations, fire and alarm testing, palm tree trimming, ADEQ monitoring, and a printer. These expenditures were not explicitly authorized within the budget approved by the passthrough age...

Condition/Context: The District spent $12,772 of federal funding on video conferencing, COVID-19 testing, charging stations, fire and alarm testing, palm tree trimming, ADEQ monitoring, and a printer. These expenditures were not explicitly authorized within the budget approved by the passthrough agency for the related grant. In addition, the District expended $31,500 in payroll for retention stipends that were not explicitly written into the budget approved by the passthrough agency. Lastly, for eleven of 25 general disbursements tested, an approved purchase order or requisition was not maintained to support the authorization of the purchase. Among those eleven purchases, five did not have invoices approved for payment. Action planned in response to finding: The District will establish proper internal controls over processing expenditures to ensure that only those expenditures that are allowed and approved within the budget be spent out of grant funds. Those expenditures should be approved within a purchase order and requisition and the related invoices should be approved for payment. Planned completion date for corrective action plan: For the period ending June 30, 2023.

View Audit 44342 Questioned Costs: $1

Corrective Action Plans

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