Corrective Action Plans

Finding 31091 (2022-008)

Material Weakness 2022

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that th...

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that the documentation required to support a student?s socioeconomic status is reviewed and retained for Eligibility compliance. This information will be reviewed and entered by the Testing department with a final review by the Federal Programs Administrator. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

View Audit 33474

Finding 31089 (2022-006)

Material Weakness 2022

Gary Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2022-006 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure compliance with require...

FINDING 2022-006 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure compliance with requirements related to the Special Tests and Provisions- High school graduation rate. Specifically, it will include internal controls for removing students from graduation cohort programs with proper documentation and review. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

View Audit 33474

Finding 31072 (2022-003)

Material Weakness 2022

Gary Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring Cash Management § 200.302 § 200.303 § 200.327 § 200.328 § 200.329

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will b...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

View Audit 33474

Finding 31061 (2022-004)

None 2022

University of Rio Grande

OH

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding Number: 2022-004 Condition: The University disbursed Direct Plus Loans in excess cost of attendance minus other estimated financial assistance for a student. Planned Corrective Action: The University is working closely with the U.S. Department of Education?s Office of Inspector General on th...

Finding Number: 2022-004 Condition: The University disbursed Direct Plus Loans in excess cost of attendance minus other estimated financial assistance for a student. Planned Corrective Action: The University is working closely with the U.S. Department of Education?s Office of Inspector General on this fraudulent activity. The University will continue to monitor student financial aid accounts using the current internal controls which led to the fraud discovery. Contact person responsible for corrective action: Meghann Fraley, CFO Anticipated Completion Date: 12/31/2023

View Audit 31905 Questioned Costs: $1

Finding 31060 (2022-001)

Significant Deficiency 2022

Premier Health Partners

OH

Allowable Costs / Cost Principles Eligibility Subrecipient Monitoring

Corrective Action Plan Federal Award Findings and Questioned Costs For the Year Ended December 31, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Federal program information: Federal Program: HRSA COVID-19 Claims Reimbursement for...

Corrective Action Plan Federal Award Findings and Questioned Costs For the Year Ended December 31, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Federal program information: Federal Program: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (93.461) Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: January 1, 2022, through December 31, 2022 Summary of finding: Premier Health Partners and Subsidiaries (the Company) did not appropriately design and execute internal control procedures to review for retroactive insurance that subsequently became effective for the date(s) of service on patient accounts previously billed to and reimbursed by the COVID-19 Uninsured Program. Corrective Action Plan: Premier Health will submit all claims paid by the HRSA COVID-19 Uninsured Program to a third-party vendor to perform a search for any retroactive insurance coverage for these patients for the service dates submitted and paid by this program. Any accounts found to have retroactive insurance coverage for dates submitted will be paid back to the HRSA Uninsured Program by December 31, 2023. Expected Completion Date: December 31, 2023 Responsible Contact Persons: Amanda Ricci-Adkins ? System VP Revenue Cycle, Mike Sims ? System VP & Corporate Controller

View Audit 30529

Finding 31053 (2022-004)

Material Weakness 2022

Independent School District No.786

MN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness

Finding 2022-004 Special Tests ? Wage Rate Requirement Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not ensure proper i...

Finding 2022-004 Special Tests ? Wage Rate Requirement Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not ensure proper inclusion of prevailing wage rate clauses in two construction contracts and also did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Eric Koep, Superintendent Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2023

View Audit 34792

Finding 31041 (2022-001)

Material Weakness 2022

United Way of Monterey County

CA

Subrecipient Monitoring Cash Management Eligibility

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In March 2021, UWMC began this eme...

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In March 2021, UWMC began this emergency program with an existing system, the Smart Referral Network (SRN) software, which was adapted in order to quickly launch the program. In March of 2022, the SRN tool was replaced with a software system (Neighborly) more specifically designed to administer and report on ERAP. The new data system facilitates reconciliation to the detailed payment data. Management agrees that the expenditures for the reporting period were overstated and accepts the recommendation along with implementing the following corrective action. UWMC conducted a comprehensive reconciliation of program data to financial expenditure records of its partnering agencies through June 30, 2022. In the current fiscal year, all partnering agencies are required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. This new procedure was put in place for reimbursements effective January 1, 2023 forward. For reimbursements from July 1, 2022 ? December 31, 2022, we are going to reconcile past reimbursement requests to the partner agency general ledger report retroactively. The UWMC staff member overseeing these reconciliations with support from the UWMC Finance Department is: Kelly DeWolfe, Community Impact Director, Financial Stability kelly.dewolfe@unitedwaymcca.org (831)318-1997

View Audit 33534

Finding 31035 (2022-001)

Significant Deficiency 2022

University of Health Sciences and Pharmacy in St Louis

MO

Student Financial Aid Subrecipient Monitoring Reporting

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across ...

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across all team members. In addition, the Financial Aid Office has implemented new oversight, review processes and procedures across internal departments intended to enhance the timely submission of enrollment changes to the NSLDS in accordance with the requirements. These enhanced processes and procedures were implemented during the fiscal year ending June 30, 2023.

View Audit 28000

Finding 31016 (2022-001)

Material Weakness 2022

National University

CA

Reporting Special Tests & Provisions Student Financial Aid

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of t...

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause: The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Corrective action plan: NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.

View Audit 26192

Finding 31005 (2022-002)

Material Weakness 2022

Low Rent Housing Agency of Knoxville, Iowa

IA

HUD Housing Programs Subrecipient Monitoring

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insur...

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insure or collateralize our funds at 100%, we will move our funds to a bank that will insure them at 100%.

View Audit 25704

Finding 30973 (2022-001)

Significant Deficiency 2022

California Lutheran University

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigati...

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

View Audit 30198

Finding 30972 (2022-003)

Significant Deficiency 2022

Missouri Housing Development Commission

MO

Subrecipient Monitoring Reporting

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has imple...

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197

Finding 30971 (2022-002)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.400 § 200.401

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 202...

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 21.023. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021 the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity has been expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30968 (2022-001)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.400 § 200.401

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years ...

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 14.231. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, MHDC undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021, reviewed applications to identify potentially fraudulent applications during fiscal year 2022 and expects to conclude its investigation of identified cases during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30967 (2022-001)

Significant Deficiency 2022

Lake Anne Fellowship House, Section I

VA

Subrecipient Monitoring Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitvill...

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitville Pike, Lancaster, PA 17601 Audit period: Year Ending June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS None Noted FEDERAL AWARD FINDINGS Finding 2022-001 ? Required Monthly Deposits to the Reserve for Replacement Recommendation: The Corporation should have procedures in place to ensure all required monthly deposits are made. Action Taken: $782.00 shortfall of deposits was funded. Going forward, annually management will verify with ownership monthly deposit required. Anticipated Completion Date: September 22, 2022, the date the Corporation made the underfunded deposit. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Christy Zeitz, CEO at (571) 349-0055.

View Audit 36489

Finding 30939 (2022-005)

None 2022

Hazel Crest School District 152.5

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/...

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2023. Name of Contact Person: Dr. Kenneth Spells, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 27177

Finding 30876 (2022-004)

Material Weakness 2022

Okaloosa Walton Homeless Continuum of Care, Opportunity, Inc.

FL

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the...

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the relevant audited period. The former Executive Director?s employment with HHA was terminated on October 10, 2022. The former Finance Director?s employment with HHA was terminated on October 20, 2022. The third employee?s employment with HHA was terminated on October 11, 2022. Additionally, all but two of the Board of Directors who served during the period in which the irregularities occurred have been replaced. HHA appointed the current Executive Director, Crystal Harrison (?Executive Director?), on October 10, 2022, as Interim Executive Director and promoted her to the position of Executive Director on October 26, 2022. The current Executive Director has diligently searched for all documents and records for all purchases, expenses, and cash distributions at issue during the former Executive Director?s tenure as Executive Director. However, no such documents or records were located on site at HHA?s offices or on HHA?s computers or devices. In early April 2023, HHA?s attorney served the former Executive Director, former Finance Director, and former employee with a demand to produce the missing documents and records but each responded that they had no such documents or records in their possession. Unfortunately, because of the actions of the former Executive Director, Finance Director, and employee, HHA lacks sufficient operating funds to pursue a civil suit to recover the losses caused by these former employees. Further, HHA?s errors and omissions insurance policy only covers third-party claims. As such, HHA has directed its attorney to take all appropriate action to pursue criminal charges of grand theft/embezzlement and fraud against these former employees upon completion of the audit. HHA?s attorney has already reached out to law enforcement to begin this process. Once the formal criminal complaint is filed, law enforcement will be empowered to subpoena the missing documents and records (should said documents and records still exist) from the former employees, as well as their banking and financial records (including tax returns) to track the suspicious expenses and cash distributions at issue. The current Executive Director, with the full support of HHA?s Board, is committed to taking all action necessary to ensure compliance with the rules and procedures already in place regarding expenses and cash distributions, as well as to enact new enhanced procedures for periodic reviews of these procedures to timely detect deficiencies and ensure compliance going forward. In addition, the current Executive Director will implement a process to ensure that backup records are maintained electronically as well as in a paper form.

View Audit 33406 Questioned Costs: $1

Finding 30874 (2022-003)

Material Weakness 2022

Miami County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-003 Contact Person Responsible for Corrective Action: Mary Brown Contact Phone Number: 765-472-3901 Ext. 1240 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We were notified in May of 2023 at training the county needed to have a Procure...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Mary Brown Contact Phone Number: 765-472-3901 Ext. 1240 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We were notified in May of 2023 at training the county needed to have a Procurement and Suspension and Debarment policy and procedures in place. I was notified of the options through our Field Examiner and will be using SAM.gov to verify vendors meet the requirements to enter into a covered transaction. Anticipated Completion Date: January 2024

View Audit 33402

Finding 30819 (2022-003)

Material Weakness 2022

Jaeb Center for Health Research Foundation INC

FL

Subrecipient Monitoring Material Weakness § 200.303 § 200.332

2022-003 Subrecipient Monitoring The Organization has created a subrecipient monitoring schedule that follows the grant cycle of each of its federal grants and has also created a template document to collect the information required by 2 CFR Part 200, Subpart D, Section 200.332. Staff time has bee...

2022-003 Subrecipient Monitoring The Organization has created a subrecipient monitoring schedule that follows the grant cycle of each of its federal grants and has also created a template document to collect the information required by 2 CFR Part 200, Subpart D, Section 200.332. Staff time has been allocated to collecting the required information from each subrecipient during 2023, which will continue annually to complete this requirement from this point forward.

View Audit 35574

Finding 30806 (2022-001)

Material Weakness 2022

Meridian School District No. 505

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 federal wage rate requirements. Name, address, and telephone of District?s contact person: Daniel Yorton 214 W Laurel Rd Bellingham, WA 98226 360-988-3840 Corrective ac...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District?s contact person: Daniel Yorton 214 W Laurel Rd Bellingham, WA 98226 360-988-3840 Corrective action the auditee plans to take in response to the finding: The district would like to thank the auditors for their work and recommendations regarding Davis-Bacon requirements. The district has implemented internal controls to ensure that contract language meets Davis-Bacon requirements. The district has also implemented internal controls to ensure that contractors submit weekly certified payroll and Davis-Bacon requirements are met. Anticipated date to complete the corrective action: 7/31/23

View Audit 26733

Finding 30802 (2022-002)

Material Weakness 2022

Meridian School District No. 505

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District?s contact person: Daniel Yorton 214 W Laurel Rd Bellingham, WA 98226 360-988-3840 Corrective...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District?s contact person: Daniel Yorton 214 W Laurel Rd Bellingham, WA 98226 360-988-3840 Corrective action the auditee plans to take in response to the finding: The district does not agree with the finding. See detail in the finding response. Based on SAO?s stance regarding piggybacking for public works projects, the district will continue to use our process for determining piggybacking requirements while seeking support when needed. The district will default to the public bid process for the public works process. In instances where it is favorable for the district to piggyback on public works projects, we will consult our attorney for legal guidance. We will also consider submitting a help desk request for guidance from SAO when needed. Anticipated date to complete the corrective action: 7/31/23

View Audit 26733

Finding 30785 (2022-001)

Material Weakness 2022

Sedro-Woolley School District No. 101

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Brett Greenwood 801 Trail Road Sedro-Woolley, W...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Brett Greenwood 801 Trail Road Sedro-Woolley, WA. 98284 360-855-3500 Corrective action the auditee plans to take in response to the finding: The District used the Emergency Connectivity Funds (ECF) to provide a laptop to every student when we were forced to close due to covid-19. This felt like an emergency situation to us and we were focused on finding ways to deliver curriculum while students were at home. We were not aware of the unmet need requirement for this funding, so we accept the finding. Corrective Action: if we are awarded Emergency Connectivity Funds in the future, we will address the unmet needs criteria to ensure these funds are spent per the grant requirements. Anticipated date to complete the corrective action: Immediately

View Audit 26730 Questioned Costs: $1

Finding 30784 (2022-001)

Material Weakness 2022

Anacortes School District No. 103

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The Anacortes School District feels this audit finding is specific to the Emergency Connectivity Fund and has decided not to claim any funds in a recently awarded allocation. Additionally, the District will not apply for any Emergency Connectivity Fund grants in the future.

View Audit 26729 Questioned Costs: $1

Finding 30780 (2022-004)

Significant Deficiency 2022

Los Angeles Community College District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

The Accounting Office will require all program personnel to complete a checklist of all expenditures incurred close to the end of the fiscal year in order to identify any expenditures that need to be accrued. Personnel responsible for implementation: Nyame-Tease Prempeh Position of responsible pers...

The Accounting Office will require all program personnel to complete a checklist of all expenditures incurred close to the end of the fiscal year in order to identify any expenditures that need to be accrued. Personnel responsible for implementation: Nyame-Tease Prempeh Position of responsible personnel: Assistant Director of Accounting Date of Implementation: July 1, 2023

View Audit 27427

Finding 30773 (2022-003)

Significant Deficiency 2022

Los Angeles Community College District

CA

Subrecipient Monitoring Special Tests & Provisions

A. Perform regular backup restoration tests i. The District is planning to complete a backup restoration by the end of Q1 2023. B. Improve server and network security i. The District has completed reviewing the changes needed to address the identified critical vulnerabilities. The vulnerabili...

A. Perform regular backup restoration tests i. The District is planning to complete a backup restoration by the end of Q1 2023. B. Improve server and network security i. The District has completed reviewing the changes needed to address the identified critical vulnerabilities. The vulnerability patch will be applied by the end of the 2022 calendar year. ii. The District completed the high vulnerability patch on November 10, 2022. iii. The District completed the critical patch updates outside of the identified 30 calendar day window due to minimizing substantial business impact. The patching periods fell under the critical business time period. Verbal approval was provided but the District will strictly follow procedure to obtain written authorization from the VC/CIO for delaying the patching. C. Perform timely access revocation and system access review i. The District has undergone a comprehensive discovery of our current environments and scoped out opportunities to optimize the deprovisioning synchronization. This scope has been incorporated into a public solicitation which completed early Fall 2022. Currently, the District awaits board authorization on issuing a professional services contract to begin the effort. The target is to initialize a project in January to automate deprovisioning synchronization of employees across the multiple EPR systems. Meanwhile, regular access reviews of SAP and SIS will be a separate process that will be regularly conducted. The target completion is early Q2 2023. D. Strengthen password controls ? optimize account lockout configuration in SAP Database i. The SAP Database accounts identified are system accounts that are not used for any type of interactive login. The password policy has been applied to interactive login accounts only thus these accounts were not included. The District is currently exploring the feasibility of applying these policies to the system accounts without impact to downstream automated processes. E. Establish and document approval of IT policies and procedures i. The LACCD Office of Information Technology Information Security Team has completed the initial draft of the Operational Protocol for Portable Media, which is currently under review. The OIT anticipates implementation will be completed by March 31, 2023. ii. An Operational Protocol for Risk Acceptance of SIS Permissions requires finalizing a formal Role-Based Access Control (RBAC) model for SIS. This process was delayed due to leadership changes in the Office of Educational Programs and Institutional Effectiveness (EPIE), the main process stakeholder, that occurred during the audit year. The OIT anticipates that the RBAC will be finalized and a Risk Acceptance Process for SIS permissions will be finalized and implemented by June 30, 2023. Personnel responsible for implementation: Carmen V. Lidz Position of responsible personnel: Vice Chancellor & Chief Information Officer

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