Corrective Action Plans

Finding 385817 (2023-004)

Significant Deficiency 2023

ID

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

2023-004: Suspension Debarment Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Rec...

2023-004: Suspension Debarment Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to insure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 sanction and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be imitated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented in April 2024.

View Audit 298414

Finding 385659 (2023-002)

Significant Deficiency 2023

Idaho State University

ID

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

2023-002: Cash Management-Subrecipient Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matt...

2023-002: Cash Management-Subrecipient Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented in FY24

View Audit 298414

Finding 385653 (2023-002)

Significant Deficiency 2023

Kalamazoo Valley Community College

MI

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding Number: 2023-002 Condition: The College provided funds to two individuals for transportation in advance of being approved for participation in the program. Planned Corrective Action: The College has returned the questioned costs by transferring the expenditures out of the grant funds and red...

Finding Number: 2023-002 Condition: The College provided funds to two individuals for transportation in advance of being approved for participation in the program. Planned Corrective Action: The College has returned the questioned costs by transferring the expenditures out of the grant funds and reducing the next drawdown for the grant. The College will immediately suspend the practice of providing grant funds to individuals prior to their approval for participation in program. Moving forward, the College will require the Program Director to approve all applicants for eligibility prior to any training or support activities beginning. This will include a review of the application materials, eligibility documents, and any other required materials. Participants who do not meet the eligibility requirements will receive written notice of the reason for denial and will not be admitted to any programming or receive any supportive services. The College will also look to have staff members involved in grant administration receive targeted training and education on the revised grant disbursement procedures as well as general grant administration training. Contact person responsible for corrective action: Vice President for Finance & Business Anticipated Completion Date: 06/30/2024

View Audit 298412 Questioned Costs: $1

Finding 385652 (2023-001)

Significant Deficiency 2023

Kalamazoo Valley Community College

MI

Subrecipient Monitoring § 200.332

Finding Number: 2023-001 Condition: The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Planned Corrective Action: The College will work to develop a subrecipient monitoring policy and subrecipient...

Finding Number: 2023-001 Condition: The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Planned Corrective Action: The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management. Contact person responsible for corrective action: Vice President for Finance & Business Anticipated Completion Date: 06/30/2024

View Audit 298412

Finding 385649 (2023-004)

Significant Deficiency 2023

Cedar Valley Services, Inc.

MN

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Questioned Costs

U.S. Department of Transportation 2023-004 Formula Grants for Rural Areas – Assistance Listing No. 20.509 Recommendation: We recommend the Organization properly document Sam.gov searches. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action take...

U.S. Department of Transportation 2023-004 Formula Grants for Rural Areas – Assistance Listing No. 20.509 Recommendation: We recommend the Organization properly document Sam.gov searches. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will take the steps necessary to properly document that they have searched Sam.gov. Names of the contact persons responsible for corrective action: Rich Pavek, Executive Director, and Kris Burkey, Finance Manager Planned completion date for corrective action plan: December 31, 2024

View Audit 298394

Finding 385621 (2023-002)

Material Weakness 2023

South Spencer County School Corporation

IN

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

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: For three vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justi...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: For three vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Contact Person Responsible for Corrective Action: Food Service Director, Maggie Caudill Contact Phone Number and Email Address: (812) 649-2591 / maggie.caudill@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Small Purchase Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385615 (2023-001)

Material Weakness 2023

South Spencer County School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent...

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385519 (2023-010)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventin...

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

View Audit 298302

Finding 385517 (2023-009)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.208 § 200.302 § 200.303 § 200.305 § 200.328

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in prev...

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385513 (2023-008)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation...

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Allowable Activities and Allowable Costs/Cost Principles compliance requirements. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee to ensure all costs are correct and allowable before giving their approval. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the Schools Corporation’s fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will be checking for Allowable Activities and Allowable Costs/Cost Principles and verifying that they meet compliance. During the reimbursement process the grants person will also make sure all sections of the grant have been properly expended. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385507 (2023-005)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation is no longer part of the Special Education Cooperative. The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. The Special education director will code initial expenditures to grant appropriation lines and submit to accounts payable specialist. Accounts payable specialist then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385505 (2023-004)

Material Weakness 2023

Silver Creek School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Findings: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The Cooperative did no...

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Findings: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The Cooperative did not have internal controls in place over payroll transactions to ensure expenditures were allowable and in conformance with the cost principles. The Treasurer reviewed a report which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee being paid from the grant fund. For vendor disbursements, although the Deputy Treasurer matched the invoice to the purchase order and provided it to the Corporation Treasurer for review and signature of the accounts payable voucher prior to payment, the control was not effective and did not detect or allow correction of errors. In the initial sample of 6 vendor disbursements, one claim was unable to be provided. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education, Tamara Swarens, Director of Elementary Curriculum and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school tswarens@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The AP Specialist makes sure that there is an appropriate claim for each payment we make, there are two signatures on each claim and the claims are approved by the Treasurer. Check processing is completed by the Deputy Treasurer as the third check. The AP Specialist now scans each invoice to the FMS accounting system to ensure that we have all back up for the claims. With the new Directors of Curriculum and Special Education, we only reimburse for positions that are charged to the federal grant that have gone through a multi-step process to ensure that they get coded to the right place. The process is also reviewed at the time a request for reimbursement is made. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385432 (2023-003)

Material Weakness 2023

Metropolitan School District of Southwest Allen County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

􀀃 Finding􀀃2023􀍲003􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃–􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃–􀀃 Participation􀀃of􀀃Private􀀃School􀀃Children􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective.􀀃􀀃As􀀃a􀀃result,􀀃the􀀃school􀀃 corporation􀀃did􀀃not􀀃consult􀀃with􀀃the􀀃non􀍲public􀀃schools􀀃withi...

􀀃 Finding􀀃2023􀍲003􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃–􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃–􀀃 Participation􀀃of􀀃Private􀀃School􀀃Children􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective.􀀃􀀃As􀀃a􀀃result,􀀃the􀀃school􀀃 corporation􀀃did􀀃not􀀃consult􀀃with􀀃the􀀃non􀍲public􀀃schools􀀃within􀀃its􀀃boundaries.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 If􀀃we􀀃enter􀀃into􀀃a􀀃grant􀀃where􀀃another􀀃district􀀃serves􀀃as􀀃the􀀃LEA,􀀃we􀀃will􀀃ensure􀀃all􀀃non􀍲 public􀀃schools􀀃within􀀃our􀀃district􀀃boundaries􀀃are􀀃notified􀀃and􀀃given􀀃the􀀃opportunity􀀃for􀀃 participation.􀀃􀀃The􀀃Director􀀃of􀀃Business􀀃will􀀃document􀀃that􀀃the􀀃public􀀃schools􀀃were􀀃 contacted􀀃and􀀃document􀀃the􀀃meeting/conversation.􀀃􀀃The􀀃Deputy􀀃Treasurer􀀃or􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃will􀀃review􀀃the􀀃documented􀀃meeting􀀃and􀀃sign􀀃stating􀀃it􀀃occurred.􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

View Audit 298274

Finding 385430 (2023-002)

Material Weakness 2023

Metropolitan School District of Southwest Allen County

IN

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

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director...

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Once􀀃the􀀃Deputy􀀃Treasurer􀀃completes􀀃the􀀃report,􀀃they􀀃will􀀃give􀀃the􀀃report􀀃and􀀃all􀀃 supporting􀀃documentation􀀃to􀀃the􀀃Asst.􀀃Director􀀃of􀀃Business􀀃for􀀃review.􀀃􀀃After􀀃thorough􀀃 review,􀀃the􀀃report􀀃and􀀃supporting􀀃documentation􀀃will􀀃be􀀃signed􀀃by􀀃both􀀃the􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃and􀀃the􀀃Deputy􀀃Treasurer.􀀃􀀃Once􀀃reviewed,􀀃the􀀃report􀀃and􀀃supporting􀀃 documentation􀀃will􀀃be􀀃given􀀃to􀀃the􀀃Director􀀃of􀀃Business􀀃for􀀃final􀀃approval􀀃and􀀃signature.􀀃􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

View Audit 298274

Finding 385424 (2023-001)

Significant Deficiency 2023

Muskingum University

OH

Subrecipient Monitoring

The University is employing internal and external resources to finalize and implement a security program that includes development of formal policies and procedures and consideration of regular tests or assessments of the policies and associated safeguards. The policies will be developed and implem...

The University is employing internal and external resources to finalize and implement a security program that includes development of formal policies and procedures and consideration of regular tests or assessments of the policies and associated safeguards. The policies will be developed and implemented beginning in fiscal year 2024 and will be finalized prior to the completion of next year's audit period.

View Audit 298271

Finding 385418 (2023-002)

Material Weakness 2023

University of Puerto Rico

PR

Questioned Costs Subrecipient Monitoring Reporting

Finding Number 2023-002 – Various ALN – Reporting Management’s Response The UPR concurs with this finding. The UPR Finance Office at Central Administration will send reminders to the employees in charge of preparing or sending the reports to the corresponding federal agencies or pass through entit...

Finding Number 2023-002 – Various ALN – Reporting Management’s Response The UPR concurs with this finding. The UPR Finance Office at Central Administration will send reminders to the employees in charge of preparing or sending the reports to the corresponding federal agencies or pass through entities. • For CSLFRF program reports, the Finance Office at Central Administration will send a biweekly reminder to the employee in charge of submitting the reports. • HEERF program reports are sent by the responsible person at each one of the eleven (11) campuses. For these reports, the Finance Office will send an e-mail to the employees responsible for submitting quarterly reports and annual reports, reminding them of their due dates. For the quarterly reports, this e-mail will be sent in the first week of the months of April, July, and October 2024. Additionally, for the 2024 annual report, a reminder will be sent on the first week of March 2025. • For Family Planning program reports, the Finance Office will issue a reminder for quarterly reports in the first week of the months of April, July, October, and January. For the progress reports, a reminder will be sent in the first week of February and for the annual report, a reminder will be sent in the month of April. • The Central Finance Office will issue a circular letter to the finance directors of the 11 units requesting them to instruct all their staff responsible for issuing federal program reports to schedule a reminder in their Outlook calendar 10 days before the issuance of each report. Responsible Person or Office: Finance Office at Central Administration / Finance Office at the eleven campuses Timeline: 2024-2025

View Audit 298262

Finding 385401 (2023-022)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Allowable Costs / Cost Principles Period of Performance Reporting § 200.303 § 200.403 § 200.77

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budg...

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

View Audit 298253 Questioned Costs: $1

Finding 385399 (2023-023)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.303

The Department will continue refining the capabilities of the Contract Tracking System (CTS) Database, utilized for regulatory reporting, to contain all of the necessary reporting data elements required for timely and accurate FFATA reporting. This includes configuring the database to allow for fund...

The Department will continue refining the capabilities of the Contract Tracking System (CTS) Database, utilized for regulatory reporting, to contain all of the necessary reporting data elements required for timely and accurate FFATA reporting. This includes configuring the database to allow for fund source splits to ensure contract awards are not duplicated and capturing the FSRS reporting date. Additional internal controls will be implemented, including a reconciliation of the CTS Database every quarter by the Grants Manager. The long-term goal is to migrate this legacy system to a new platform that incorporates validation to eliminate or reduce errors. DBHDD will update the internal controls related to Transparency Act Reporting and SF-425 Federal Financial Reports (FFR) for Mental Health Services Block Grant (MHBG) and Substance Abuse Prevention and Treatment Block Grant (SABG) no later than March 31, 2024. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than April 30, 2024.

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Finding 385398 (2023-021)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Allowable Costs / Cost Principles Period of Performance Reporting § 200.303 § 200.403 § 200.77

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budg...

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

View Audit 298253 Questioned Costs: $1

Finding 385395 (2023-019)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Special Tests & Provisions Questioned Costs Subrecipient Monitoring § 200.303

In February 2024, DCH and a third party executed a contract amendment which incorporates the required provisions per section 7.1.3 of the NCCI Technical Guidance Manual.

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Finding 385392 (2023-018)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

DCH completed most of the action items in the Corrective Action Plan (CAP) during fiscal year 2023 and has continued towards completion during fiscal year 2024. All identified security vulnerabilities have been addressed, which have significantly enhanced DCH’s overall cybersecurity posture. Key ac...

DCH completed most of the action items in the Corrective Action Plan (CAP) during fiscal year 2023 and has continued towards completion during fiscal year 2024. All identified security vulnerabilities have been addressed, which have significantly enhanced DCH’s overall cybersecurity posture. Key achievements include enhanced staffing (CISO, Cybersecurity Engineer, Senior Cybersecurity Analyst, and ten cybersecurity interns), and the introduction of 20 organization-wide security policies aligned with National Institute of Standards and Technology (NIST) Federal Computer Security Standards. The closeout of the remaining CAP remediation tasks is set to be completed by the end of February 2024.

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Finding 385382 (2023-015)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Special Tests & Provisions Questioned Costs Subrecipient Monitoring § 200.303

DCH revised it contracts with its CMOs to include the following language: 8.6.2 The Contractor shall submit to DCH audited financial reports specific to this Contract on an annual basis. The audit must be conducted in accordance with generally accepted accounting principles and generally accepted a...

DCH revised it contracts with its CMOs to include the following language: 8.6.2 The Contractor shall submit to DCH audited financial reports specific to this Contract on an annual basis. The audit must be conducted in accordance with generally accepted accounting principles and generally accepted auditing standards. The above language was added to the DCH contract in June 2022.

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Finding 385373 (2023-020)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Corrective Action Plan is as follows. The Georgia Department of Human Services (DHS) is redesigning its Contract Development and Procurement processes. With the new design, the accountability for Federal Funding Accountability and Transparency Act (FFATA) reporting will be with a new Office of...

The Corrective Action Plan is as follows. The Georgia Department of Human Services (DHS) is redesigning its Contract Development and Procurement processes. With the new design, the accountability for Federal Funding Accountability and Transparency Act (FFATA) reporting will be with a new Office of Procurement Services (OPS). The OPS resources dedicated to FFATA will be trained on all reporting requirements by DHS. The expected implementation of the new processes by December 2024.

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Finding 385367 (2023-031)

Significant Deficiency 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs § 200.303

Verbal direction was given initially in a meeting with the Contract Liaisons (construction auditors) and to the District Construction Managers to remind them that the Certified Payroll Review Form must be used. This will also be discussed at the District Construction Managers meeting in April and a ...

Verbal direction was given initially in a meeting with the Contract Liaisons (construction auditors) and to the District Construction Managers to remind them that the Certified Payroll Review Form must be used. This will also be discussed at the District Construction Managers meeting in April and a memo is being distributed to the District Construction Managers and Contract Liaisons reminding everyone of the process. Contract Liaisons who audit the projects for contract compliance have been informed to make sure the Certified Payroll Review Form is being used. The use of the form and proper procedure for checking payrolls will be verified each time the project is audited. The Contract Liaisons have also been informed to let each of the construction managers know to use the form. Payroll review will also be incorporated into the Contract Liaison’s annual training so that the construction staff will be reminded of the process and to also inform and educate new employees of the process. The procedures to be followed are outlined in the Construction Manual. (excerpt below) The Construction Manager shall complete the Certified Payroll Review Form for ALL payrolls reviewed. The Form shall be complete with any observed issues documented in as much detail as possible and shall be signed and dated by the Construction Manager. The Construction Manager should compare the wage rates listed on the payrolls to the applicable wage rates listed in the Contract based on the job title of the Contractors/Subcontractors employee. The Construction Manager should place comments or check marks by each employee on the Contractor’s/Subcontractor’s payrolls as they are reviewed, and wages compared. Once a set of payrolls has been reviewed, the Construction Manager will print their name and current date in the top right-hand corner of the payroll and initial.

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Finding 385364 (2023-030)

Material Weakness 2023

State of Georgia/state Accounting Office-Ein Noted

GA

Reporting Special Tests & Provisions Subrecipient Monitoring § 200.303

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification...

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. The crossmatch process is conducted using software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. GDOL developed an aggressive plan to complete all crossmatches. We are running cross matches on all the state and federal programs. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing non-overpayment staff to assist with overpayment investigations. Additionally, we are utilizing temporary agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. We are slated to run our last accelerated crossmatch in March 2024 and will resume our regular crossmatch schedule in June 2024. Additionally, GDOL has procured a vendor to build and implement a modernized unemployment insurance (UI) system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Summary: The current unemployment system is obsolete and cannot be remediated at this time Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

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Corrective Action Plans

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