Corrective Action Plans

Finding 32417 (2022-002)

Material Weakness 2022

Crawford County Community School Corporation

IN

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

Finding 2022-002 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: 84.425C, 84.425D, 84.425U P...

Finding 2022-002 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: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material 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 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 for a building project. The construction payments represented 45% of the Education Stabilization Fund disbursements 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 a clause for federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. In the future, when Crawford County Community School Corporation utilizes federal funding to supplement construction costs, the construction manager will ensure awarded contracts include Davis Bacon language and be assigned the task of collecting weekly pay rate data on all contractors and subcontractors. A school employee will then review. Responsible party and timeline for completion: Brandon Johnson, Superintendent, will collect weekly pay rate data from the construction manager and review.

View Audit 27913

Finding 32402 (2022-001)

Material Weakness 2022

Enumclaw School District No. 216

WA

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

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Ass...

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Assistance Listing Number(s): 84.425 Federal Program Name and Granting Agency: COVID-19 Education Stabilization Fund, U.S. Department of Education Pass-Through Agency Name: Office of Superintendent of Public Instruction Finding Caption: The District did not have adequate internal controls for ensuring compliance with Davis-Bacon Act (prevailing wage rate) requirements. Background: During the 2020-2021 school year, the District paid $658,502 from its ESSER II award to 11 contractors to repair and replace the roof at two schools, update HVAC controls in seven schools, and replace wet and rotting insulation to improve air quality and circulation to prevent the spread of COVID-19. Additionally, the District used its ESSER II award to replace faulty and broken bathroom sinks to allow for safe and consistent use of sinks for hand washing. 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 collect weekly certified payroll reports from the contractors to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit.

View Audit 27599

Finding 32390 (2022-002)

Material Weakness 2022

Christian Housing of St. Joseph, INC Chilton Place Apts.

MO

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2022 Name of Audit: Christian Housing of St. Joseph, Inc. HUD Project Number: 084-11148 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ended March 31, 2022 Corrective Action Plan Prepared by: Name: Tamara Wallace Position...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2022 Name of Audit: Christian Housing of St. Joseph, Inc. HUD Project Number: 084-11148 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ended March 31, 2022 Corrective Action Plan Prepared by: Name: Tamara Wallace Position: Executive Director ? Management Agent Telephone Number: 816-233-4250 Finding 2022-002 Comments on Findings and Each Recommendation: The Organization agrees with the auditors? finding. Action(s) Taken or Planned on the Finding: The Organization is in the process of selling its assets pending HUD approval and expects to dissolve within the next 12 months (see Note 11).

View Audit 27889

Finding 32372 (2022-001)

Material Weakness 2022

School District of Haveford Township

PA

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Management?s Response: Management will implement safeguards to ensure responsible business office employees are held accountable for following procedures to ensure timely and complete monthly and annual financial reporting.

View Audit 28232

Finding 32371 (2022-002)

Material Weakness 2022

Inova Health System

VA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Recommendation: Inova Juniper Program?s (IJP) existing policies and procedures are in line with the requirements of the pass-through agreement with the Department; however, IJP should continue to evaluate whether appropriate oversight is performed to ensure that these policies and procedures are bei...

Recommendation: Inova Juniper Program?s (IJP) existing policies and procedures are in line with the requirements of the pass-through agreement with the Department; however, IJP should continue to evaluate whether appropriate oversight is performed to ensure that these policies and procedures are being followed with regard to eligibility verification for all clients. View of Responsible Officials: Management concurs with the finding and has implemented, during 2021 and 2022, procedures to ensure the appropriate oversight is performed regarding eligibility. inova.org Inova Health Care Services Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Mara Carter, Senior Director Community Health, Inova Juniper Program, 703-321-2687 Planned Completion Date for Corrective Action Planned: Corrective action plan has been implemented.

View Audit 27876 Questioned Costs: $1

Finding 32370 (2022-003)

Significant Deficiency 2022

Inova Health System

VA

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and pr...

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and procedures will be created outlining processes and control activities to ensure reporting to federal awarding agencies and pass-through entities are complete and accurate. During the current fiscal year, Inova began implementing enhancements to Oracle?s Grants Accounting module. Once completed, this will assist management to automate certain processes and procedures that were not available after the initial implementation. The enhanced reporting capabilities will include automated reporting that will identify grants that expended federal awards. Grants Accounting will schedule quarterly meetings with Finance and GMO leadership present. The purpose of these meetings will be to review federal funding received that will ultimately be used in the preparation of financial reports submitted to the appropriate governing agencies. The Director of Grants Accounting will guide the meetings and obtain approvals from department leaders confirming amounts to be reported for federal grant awards. In preparation of the meetings, the Director of Grants Accounting will prepare an agenda to guide discussions of grant terms and conditions and applicable FAQs, more explicitly for awards received outside of Inova?s normal course of business (i.e., COVID-19). These meetings will also provide an opportunity for Finance, GMO, and Grants Accounting leaders to review the unique characteristics of the federal grant award programs on at least a quarterly basis. Meeting minutes will be maintained to document discussions and actions to be taken. The minutes will also serve as support for accounting memos related to special awards received that document Inova?s understanding of the award and related reporting requirements. All accounting memos will be prepared by the Director of Grants Accounting and reviewed by the Senior Director of Financial Reporting. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2023.

View Audit 27876

Finding 32338 (2022-003)

None 2022

Thurston County Chamber of Commerce

WA

Internal Control / Segregation of Duties Subrecipient Monitoring

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Resp...

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers Finding 2022-02 Debarred and Suspended Vendors Management Response: Management agrees with this recommendation and have taken steps to develop and implement proper internal controls. Person Responsible: Finance Officer and Program Managers Finding 2022-03 Monitoring Subcontractor Performance Management response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers Finding 2022-04 Written Approval of Subcontractors Management Response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers Finding 2022-005 Indirect Cost Allocation ? Questioned Costs Management Response: Management agrees with the need for additional grant training, especially as it applies to calculating and allocating indirect costs. However, we do have issues with the classification of expenses within the original contract and hope we can reconcile those prior to the finalization of the grant award. Person Responsible: President/CEO Finance Officer

View Audit 27061

Finding 32335 (2022-001)

Significant Deficiency 2022

Hopeworks of Howard County, Inc.

MD

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding: Thirteen reports within three quarters were submitted after the required deadline. We recommend reviewing the controls in place to ensure that all future reports are submitted on time and in accordance with grant requirements. If the Organization expects that there will be a delay in the su...

Finding: Thirteen reports within three quarters were submitted after the required deadline. We recommend reviewing the controls in place to ensure that all future reports are submitted on time and in accordance with grant requirements. If the Organization expects that there will be a delay in the submission of the reports, they should obtain permission to extend the submission date from the awarding agency. Statement of Concurrence or Non-Concurrence Statement of Concurrence: HopeWorks concurs with the finding and recommendation listed above. Corrective Action HopeWorks has implemented a number of streamlined processes in which to expedite the availablity of information needed to file the funder reports more timely. These processes are not limited to electronic import of payroll and benefit entries, implementation and consistent use of Bill.com for expenditures, and prioritization of recording credit card activity. Fifteen days is a strict deadline and if for some reason reporting will be late, HopeWorks will communicate to the funder and document that communication. In FY23, we are also working to streamline the technology and our internal and departmental grant reporting processes to ensure that we are being as efficient as possible with our existing resources, both technological and human.

View Audit 27429

Finding 32303 (2022-004)

Significant Deficiency 2022

City of Nashwauk

MN

Internal Control / Segregation of Duties Significant Deficiency Subrecipient Monitoring

REPRESENTATION OF CITY OF NASHWAUK CORRECTIVE ACTION PLAN Year Ended December 31, 2022 Finding Number: 2022-004 Finding Title: SEGREGATION OF DUTIES Name of Contact Person Responsible for Correcti...

REPRESENTATION OF CITY OF NASHWAUK CORRECTIVE ACTION PLAN Year Ended December 31, 2022 Finding Number: 2022-004 Finding Title: SEGREGATION OF DUTIES Name of Contact Person Responsible for Corrective Action April Kurtock, Clerk/Treasurer Corrective Action Planned The City Council will attempt to monitor transactions and structure the duties of office personnel to help ensure as much segregation of duties as possible within the City's staffing limitations and funding constraints Anticipated Completion Date Ongoing.

View Audit 31098

Finding 32302 (2022-001)

Significant Deficiency 2022

City of Chicopee, Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2022-001 Significant Deficiency in Internal Control Over Compliance ? U.S. Department of Treasury ? Coronavirus Relief Fund City Municipal Assistance ? (CFDA No. 21.019) ? Reporting (continued) Passed Through Commonwealth of Massachusetts Executive Office of Administration and Finance Nam...

Finding 2022-001 Significant Deficiency in Internal Control Over Compliance ? U.S. Department of Treasury ? Coronavirus Relief Fund City Municipal Assistance ? (CFDA No. 21.019) ? Reporting (continued) Passed Through Commonwealth of Massachusetts Executive Office of Administration and Finance Name of Person Responsible: Marie T. Laflamme, Treasurer Sharyn Riley, Auditor John Miarecki, School Director of Budget & Finance Corrective Action Planned: The City will immediately review all expenses related to the Coronavirus Relief Funds. The City will take steps to reconcile the Coronavirus Report to our General Ledger. Anticipated Completion Date: May 30, 2023

View Audit 31097

Finding 32258 (2022-013)

Significant Deficiency 2022

State of North Dakota

ND

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the L...

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the Licensing Administrator will run a monthly report to assure unannounced visits are being completed by the Licensing Specialists. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: Completed January 2023

View Audit 36677

Finding 32257 (2022-012)

Significant Deficiency 2022

State of North Dakota

ND

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple sprea...

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple spreadsheets. The system allows each licensing specialist to see their workflow when they log into the system. It also notifies when a reinspection is needed and will escalate the notice if the reinspection is not done timely. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: The data system launched in December 2022.

View Audit 36677

Finding 32252 (2022-002)

Material Weakness 2022

Metropolitan Boston Housing Partnership, Inc.

MA

Subrecipient Monitoring Eligibility HUD Housing Programs

2022-002 Recertifications 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Com...

2022-002 Recertifications 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Compliance Plan Detail After a detailed RFP process, Metro Housing has selected an outside vendor (Nan McKay) to assist with completing a backlog of regular reexaminations amassed during calendar years 2020 and 2021. The contract was signed on September 27, 2022. By clearing up this backlog of work, Metro Housing staff working on the completion of regular re-exams for the Section 8 HCVP and MTW programs will be able to renew their focus on completing current work timely and accurately. Metro Housing is also making changes to decrease caseload sizes for Program Specialists while also streamlining workflows to better internal and external communication needed to complete our tasks. The roll-out of this new setup should be complete before the end of the current calendar year. Anticipated Completion Date June 30, 2023 ? All reexaminations will be current, and past due percentages will be lowered to acceptable levels.

View Audit 32287

Finding 32251 (2022-001)

Material Weakness 2022

Metropolitan Boston Housing Partnership, Inc.

MA

HUD Housing Programs Subrecipient Monitoring Internal Control / Segregation of Duties

2022-001 Unit Inspections 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Com...

2022-001 Unit Inspections 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Compliance Plan Detail Metro Housing is converting all eligible inspections from an annual to a biennial cycle as allowed by the program. Due to the constraints of the pandemic waivers, Metro Housing was required to perform an inspection of every unit on its portfolio over a 12-month period instead of a 24-month period, which resulted in numerous delays. This shift should allow for all our inspections to be completed timely. Metro Housing also faced problems in implementing the COVID-waiver issued by HUD to allow for self-certifications of units?namely, if the owner did not provide said waiver, our only recourse would have been to terminate the HAP Contract and force the tenant to move, which was not a course of action deemed appropriate by Metro Housing leadership given the circumstances. We do not anticipate that self-certifications will be implemented again, and so this process should not be a factor moving forward with our ability to meet program requirements. Anticipated Completion Date July 1, 2023 ? All inspections will be in compliance and on a biennial schedule.

View Audit 32287

Finding 32248 (2022-001)

None 2022

West House Corporation

RI

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

August 5, 2022 Re: West House Corporation Project No. 016-EE-010 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exist...

August 5, 2022 Re: West House Corporation Project No. 016-EE-010 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exists. Corrective Action Plan: Management has transferred the excess to another bank account. Finding 2002-002: Federal program ? PRAC: Criteria ? the HUD Occupancy handbook specifies the nature and content of tenant income re/certifications. Corrective Action Plan: Management has reviewed all files, obtained required information, and corrected calculations. Site staff will be trained in correct procedures. Please let me know if you have any questions. Sincerely, Jennifer Y. Huynh Vice President

View Audit 32171

Finding 32247 (2022-001)

None 2022

V. N. Housing Corporation

RI

HUD Housing Programs Subrecipient Monitoring

August 5, 2022 Re: V.N. Housing Corporation Project No. 016-HD-013 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exi...

August 5, 2022 Re: V.N. Housing Corporation Project No. 016-HD-013 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exists. Corrective Action Plan: Management has transferred the excess to another bank. Please let me know if you have any questions. Sincerely, Jennifer Y. Huynh Vice President

View Audit 31348

Finding 32244 (2022-001)

Material Weakness 2022

White Mountain Community Health Center

NH

Subrecipient Monitoring Special Tests & Provisions Eligibility

October 31, 2022 Corrective Action Plan Finding: 2022-001 Condition Found: The Center has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Ken ?JR" Porter Executive Director, Toni Howard Billin...

October 31, 2022 Corrective Action Plan Finding: 2022-001 Condition Found: The Center has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Ken ?JR" Porter Executive Director, Toni Howard Billing manager Planned Corrective Action: ? Update the sliding fee discount program policy to more clearly define family size and income, including examples of source documents ? Create and use a form to document the calculation of the household income entered into the EHR ? Review the complexity of the discount schedule and consider whether it would be beneficial to change the schedule from percentage discounts to flat dollar amounts for Category B, C, D and E ? Develop routine internal monitoring procedures to perform periodic testing of sliding fee discounts to help ensure the discounts are provided consistent with the Center?s sliding fee discount program Anticipated Completion Date: December 2022 Sincerely, Ken ?JR? Porter Executive Director White Mountain Community Health Center 298 White Mountain HWY, Conway, NH 03818 Phone: 603-447-8900 X321 Fax: 603-447-4846 jrporter@whitemountainhealth.org

View Audit 31346

Finding 32236 (2022-002)

Significant Deficiency 2022

Heal the Hero Foundation

AZ

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the a...

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

View Audit 34813

Finding 32195 (2022-003)

Significant Deficiency 2022

Northern Marianas College

MP

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding No. 2022 ? 001, Payroll (Renewal of Personnel Action) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the situation is unique to disputes that arise...

Finding No. 2022 ? 001, Payroll (Renewal of Personnel Action) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the situation is unique to disputes that arise between the employee and supervisor during the employee personnel action renewal process. Personnel Actions are implied as renewed per employee contract terms. In order to resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of personnel actions. Finding No. 2022 ? 002, Payroll (Contract Renewals) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts. Finding No. 2022 ? 003, Payroll Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as it is related to Finding No. 2022-002. The three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts.

View Audit 30795

Finding 32194 (2022-002)

None 2022

Universal Technology College of Puerto Rico, INC

PR

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria Accordi...

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

View Audit 30794

Finding 32193 (2022-001)

None 2022

Universal Technology College of Puerto Rico, INC

PR

Questioned Costs Student Financial Aid Subrecipient Monitoring

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate ...

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student?s parent, is eligible to receive for that payment period. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. The monthly evaluation, verification and reconciliation will include an internal audit performed by another office responsible for comparing the COD system with the student ledger to reinforce the actual disbursement control procedures ensuring that all disbursements are correctly posted and that the student?s ledger correctly shows all the activity performed on the COD system. The institution already refunded the questioned cost of $3,247.50

View Audit 30794 Questioned Costs: $1

Finding 32162 (2022-006)

Material Weakness 2022

City of Richmond

VA

Subrecipient Monitoring Material Weakness Reporting

2022-006 CDBG Entitlement Grant Cluster and COVID-19 ? Community Development Block Grant - CV ? Assistance Listing No. 14.218 Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop cont...

2022-006 CDBG Entitlement Grant Cluster and COVID-19 ? Community Development Block Grant - CV ? Assistance Listing No. 14.218 Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Housing and Community Development will work with the appropriate Federal regulatory department and review applicable guidance to determine the required reporting frequency, register with all necessary reporting systems, and receive any necessary training by June 30, 2023. Beginning July, 2023, Housing and Community Development will begin submitting the fiscal year 2024 reports while concurrently submitting any and all delinquent reports for fiscal year 2023. Name(s) of the contact person(s) responsible for corrective action: Sherrill Hampton Planned completion date for corrective action plan: October 31, 2023

View Audit 35530

Finding 32138 (2022-002)

Significant Deficiency 2022

Fall River School District

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Finding #2022-002 ? Inconsistencies Between General Ledger Project and PI-1086 Grant Claim Education Stabilization Fund- ESSER II (#84.425D) Federal Grantor - US. Department of Education Pass-through Award Number ? 2022-111736-DPIESSERFII-163 Pass-through Entity - Wisconsin Department of Public Inst...

Finding #2022-002 ? Inconsistencies Between General Ledger Project and PI-1086 Grant Claim Education Stabilization Fund- ESSER II (#84.425D) Federal Grantor - US. Department of Education Pass-through Award Number ? 2022-111736-DPIESSERFII-163 Pass-through Entity - Wisconsin Department of Public Instruction Condition: ESSER II grant reimbursement claims are submitted to the Wisconsin Department of Public Instruction using a PI-1086 report. A PI-1086 reimbursement claim includes the approved budget and the actual allowable program expenditures incurred to date. A PI-1086 claim is a summary report and the detail to support the claim must be maintained by the District. ESSER funding was audited as a major federal program for the year ended June 30, 2022. During the audit, we noted that general ledger costs in Project 163 (ESSER II project) were not consistent with the approved budget amounts or actual disbursement amounts in the PI-1086. Payroll costs included in the approved budget were not recorded to Project 163, and construction costs not included in the approved budget, were recorded to Project 163. After bringing to the District?s attention, late journal entries were made to reallocate the approved budgeted payroll cost to Project 163. Construction costs not included in the ESSER II budget were moved out of Project 163. Criteria: The District is required to track costs claimed on PI-1086 in detail by each grant?s specific project code. Project code numbers are provided by DPI to aid in tracking allowable reimbursable costs claimed to a grant. Reimbursement claims submitted to DPI should agree to the actual costs reported in the general ledger for that grant?s project code. Cause: The District?s approved ESSER II budget was $234,748. An ESSER II grant claim submitted reflected actual disbursements to date of $234,748. The PI-1086 reflected that actual costs incurred were the same as the approved budget. The unaudited general ledger Project 163 expenditures totaled $234,748, however, the breakdown of costs by Account Code object and function was not consistent with the approved budget. This caused confusion about what costs were being claimed. Effect: Costs claimed for reimbursement need to be consistent with the Wisconsin Department of Instruction approved budget. A reimbursement request could be made and paid by DPI for expenditures that did not comply with the approved budget or grant requirements. Context: Education Stabilization Fund (ESSER) was new grant funding in response to the rising costs associated with COVID-19 coronavirus. The federal government provided ESSER grants to aid schools in operating safely. Recommendation: Establish controls to ensure PI-1086 claims are made with information consistent with the District?s general ledger. Reclassify costs as needed with a journal entry to move costs in or out of a grant project based on costs claimed under the grant. If needed, request that the Wisconsin Department of Public Instruction amend an approved budget to be consistent with actual allowable costs incurred by District. Response: The District will evaluate its controls to ensure grant project codes are being properly utilized and costs claimed under the grant are appropriately coded. Prior to filing PI-1086 grant claims, we will ensure costs submitted are consistent with our general ledger and the approved budget. Contact Person: Dennis Birr Anticipated Completion: June 30, 2023

View Audit 28280

Finding 32078 (2022-001)

Material Weakness 2022

Hood Canal School District No. 404

WA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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: Jeanie Beebe, Director of Finance and Operations 111 N State Rt 106 Shelton, WA 98584 (36...

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: Jeanie Beebe, Director of Finance and Operations 111 N State Rt 106 Shelton, WA 98584 (360) 877-5463 Corrective action the auditee plans to take in response to the finding: The District concurs with the finding. Corrective action will include inserting a prevailing wage rate clause into all federally funded contracts, as well as collecting and reviewing all weekly certified payroll reports in a timely manner from all contractors and subcontractors to verify that prevailing wage was paid. Anticipated date to complete the corrective action: May 17, 2023

View Audit 27938

Finding 32074 (2022-005)

Material Weakness 2022

Wasco County School District No 29

OR

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment

Finding: 2022-05 CFDA Number: 84.425 Award Name and years: Education Stabilization Fund (ESF), 2022 Federal Agency: Department of Education ? Oregon Department of Education Category of Finding: Equipment/Real Property Management Questioned Cost: $28,007 Criteria: According to the 2022 Uniform ...

Finding: 2022-05 CFDA Number: 84.425 Award Name and years: Education Stabilization Fund (ESF), 2022 Federal Agency: Department of Education ? Oregon Department of Education Category of Finding: Equipment/Real Property Management Questioned Cost: $28,007 Criteria: According to the 2022 Uniform Guidance Compliance Supplement, subrecipients may use ESF funds to purchase equipment only if the obtain prior approval by the pass-through entity. Condition: Two equipment purchase were made without prior approval from Oregon Department of Education out of a total population of 11 invoices. We tested all 11 invoices ? no sample was created. Cause and Effect: The lack of adequate controls contributed to material noncompliance with Equipment/Real Property Management compliance requirements for the Education Stabilization Fund grant, which was a major program during the fiscal year. Recommendation: We recommend procedures be strengthened to ensure grant adherence. Agency Response: We accept this finding and acknowledge we missed getting prior approval. Internal control steps have been taken, with the adding of additional fiscal staff. Greater care will be taken with future grants.

View Audit 28062 Questioned Costs: $1

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