Corrective Action Plans

Finding 42730 (2022-001)

Material Weakness 2022

St. Vincent Charity Medical Center and Subsidiaries

OH

Subrecipient Monitoring Material Weakness Reporting § 200.303

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Depar...

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS June 11, 2021, post-payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Planned Corrective Action: Chief Financial Officer will insure that all guidance available for PRF reporting (FAQ's etc.) is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions. Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: August 1, 2023

View Audit 46954

Finding 42727 (2022-004)

Material Weakness 2022

Greene County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and mainta...

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

View Audit 46952

Finding 42726 (2022-003)

Material Weakness 2022

Greene County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-003 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Secondary Contact: County Attorney, currently Marvin Abshire Secondary Contact Phone Number: 812-384-0081 Views of Responsible Official: We concur with the fin...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Secondary Contact: County Attorney, currently Marvin Abshire Secondary Contact Phone Number: 812-384-0081 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: Corrective action will need to be taken to review the Sam.gov verification website in the future. We will be verifying that current and future Greene County vendors are not barred or suspended on the Sam.gov verification website before using their services. As county attorney is responsible for virtually all contract drafting or approval, county attorney has added to the public works contract checklist the determination whether or not federal funds are used in fulfillment of the contract and if so, that the contract will contain a suspension and debarment paragraph applicable to contractor and subcontractors. Further, should the county submit a request for qualifications for a design-build public works project, attorney will endeavor to assure that the request for qualifications requires information concerning debarment, disqualification, or removal of the design-builder or a team member from a federal, state, or local government public works project. Attorney will perform the sam.gov verification for qualifying contracts or matters implicating suspension and debarment; will date and initial or sign the verification; and will ask his assistant to review the verification and initial or sign and date same. Either a paper copy or a PDF of the confirmed verification will be maintained in the contract file. Heather N. Perry Greene County Auditor Anticipated Completion Date: 09/01/2023

View Audit 46952

Finding 42704 (2022-001)

Material Weakness 2022

Mason County, Illinois

IL

Internal Control / Segregation of Duties Subrecipient Monitoring

Corrective Action Plan To the extent possible, monitoring of monthly financial results and compliance information will continue in the County Courthouse offices and the County Health Department. Anticipated Completion Date The County is not in a financial position to hire additional employees. The...

Corrective Action Plan To the extent possible, monitoring of monthly financial results and compliance information will continue in the County Courthouse offices and the County Health Department. Anticipated Completion Date The County is not in a financial position to hire additional employees. The increased monitoring has already begun. Responsible Parties Kenneth Walker, Mason County Board Chairman 125 North Plum Havana, Illinois 62644 (309)543-3359 Cari Meeker, County Treasurer 125 North Plum Havana, Illinois 62644 (309)543-3359 Curt Jibben, County Health Department Administrator 1002 East Laurel Ave. Havana, Illinois 62644 (309)210-0110

View Audit 43953

Finding 42679 (2022-007)

Material Weakness 2022

Reorganized School District R-II of Cape Girardeau County

MO

School Nutrition Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Name of Contact Person: Matt Lacy, Chief Financial Officer Recommendation: We recommend the District verify a vendor?s status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Corrective Action:...

Name of Contact Person: Matt Lacy, Chief Financial Officer Recommendation: We recommend the District verify a vendor?s status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Corrective Action: We will verify all vendors? status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Proposed Completion Date: Immediately

View Audit 54519

Finding 42676 (2022-002)

Material Weakness 2022

Wabash County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Wabash County Auditor, Marcie Shepherd Contact Phone Number: 260-563-0661 We concur with the finding. Description of Corrective Action Plan: We were unaware that once you elected to receive the funding as the standard revenue loss al...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Wabash County Auditor, Marcie Shepherd Contact Phone Number: 260-563-0661 We concur with the finding. Description of Corrective Action Plan: We were unaware that once you elected to receive the funding as the standard revenue loss allowance that you would still need to verify for the suspension and debarment compliance requirement. Moving forward when a request for funding is being presented to the County Commissioners/Council, Commissioners/Council will require the office that is requesting funding to provide the Auditor?s office with a Suspension and Debarment form which is signed and dated from SAM.gov. The form will be kept in the ARPA binder. Anticipated Completion Date: August 8, 2023

View Audit 54060

Finding 42673 (2022-001)

Material Weakness 2022

Marshall County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Angela C. Birchmeier, County Auditor Contact Phone Number: (574) 935-8555 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County and Auditor?s ...

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Angela C. Birchmeier, County Auditor Contact Phone Number: (574) 935-8555 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County and Auditor?s office were unaware of the requirement that a contract over $25,000 needed verification that the contractor had not been suspended or disbarred. Now that we are aware, each contract will be verified by either checking the EPLS (Excluded Parties List System) or that the clause for disbarment or suspension is included in the contract. The Department requesting the contract will verify if the clause is in the contract. The Claims Deputy will also verify during the claims process for payment and the 1st Deputy will also verify. Anticipated Completion Date: We have already implemented this procedure effective April 2023.

View Audit 54392

Finding 42664 (2022-001)

Significant Deficiency 2022

Dighton-Rehoboth Regional School District

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

June 12, 2023 CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The Dighton-Rehoboth Regional School District respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public ...

June 12, 2023 CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The Dighton-Rehoboth Regional School District respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The following findings from the June 30, 2022, schedule of findings and question costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2022-001: Document Policies and Procedures Over Federal Awards (Significant Deficiency) Criteria or Specific Requirement - OMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards established significant new requirements related to Federal awards. The new requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: Cash management Determination of allowable costs Employee travel Procurement Subrecipient monitoring and management Condition and Context ? The District has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Effect - The District is not in compliance with grant requirements. Cause - Weaknesses in the formal documentation of internal controls. Questioned Costs - N/A Recommendation - We recommend the District ensure that written policies and procedures are compiled and adopted. Views of Responsible Official and Planned Corrective Action Management agrees with this finding and is actively in the process of resolving this issue. This issue will be resolved by the end of FY23. The District has been working with Clifton Larson Allen LLP to draft policies and procedures for the District. If the Oversight Agency has questions regarding this plan, please call Robert Baxter at 508-252-5000. Sincerely yours, Robert Baxter District Business Manager

View Audit 54033

Finding 42651 (2022-001)

Significant Deficiency 2022

Cabot Performing Arts Center, INC

MA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management has been making updates to its policies and procedures throughout 2022 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 51333

Finding 42642 (2022-003)

Material Weakness 2022

New Mexico Early Childhood Education and Care Department

NM

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.318

2022-003 Procurement, Suspension, and Debarment Recommendation: We recommend the program staff and ASD staff responsible for procuring contracts review federal compliance requirements to ensure appropriate language is included in all agreements. Explanation of disagreement with audit finding: The...

2022-003 Procurement, Suspension, and Debarment Recommendation: We recommend the program staff and ASD staff responsible for procuring contracts review federal compliance requirements to ensure appropriate language is included in all agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Agency?s Certified Procurement Officer (CPO) later verified that all agreements did contain the required ?Suspension and Debarment? language, it was too late to test in time to submit the audit on time. The various departments of ECECD will use this finding to ensure that designated ASD and Program staff fully understand the importance of providing complete and accurate information to the auditors. In addition, ECECD ASD will work toward improving communication regarding potential audit findings to the appropriate program staff, allowing for enough time to address the potential finding and possibly avoid a finding altogether. Name(s) of the contact person(s) responsible for corrective action: Michelle Montoya, Chief Procurement Officer; ECECD Program Managers; Ron Lucero, ASD Director; Thomas Montoya, Deputy ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer. Planned completion date for corrective action plan: June 30, 2023

View Audit 49019

Finding 42640 (2022-002)

Material Weakness 2022

New Mexico Early Childhood Education and Care Department

NM

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.331

2022-002 (Previously 2021-001) Subrecipient Monitoring U.S. Department of Health and Human Services Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.575/596 and 93.870 Recommendation: We recommend the Department implement ...

2022-002 (Previously 2021-001) Subrecipient Monitoring U.S. Department of Health and Human Services Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.575/596 and 93.870 Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure this does not occur again, the Family Support and Early Intervention Division (FSEI) Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FSEI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FSEI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. Name(s) of the contact person(s) responsible for corrective action: Mayra Gutierrez, FSEI Director; Johanna Kehoe, FSEI Deputy Director; Ron Lucero, ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer. Planned completion date for corrective action plan: June 30, 2023

View Audit 49019

Finding 42637 (2022-004)

Significant Deficiency 2022

Morrow County School District No. 1

OR

Reporting Subrecipient Monitoring Significant Deficiency

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below...

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below. US DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF)- Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Significant Deficiency #2022-004 Auditor Discussion and Recommendation: Condition and criteria: The District should have control processes in place to ensure that monitoring procedures are in place for large contracts. The District contracted work for the engineering and design of HVAC improvements. For 2 of 3 invoices, payments were made from summary invoices rather than from application and certification of payment. We also did not locate a specific contract for the project, just a proposal. When the application and certification of payments were received, there were errors and changes requiring final reconciliation and accruals. Cause: There were changes in personnel at the District during the year and the ESSER grant is fairly new to the District. In addition, the invoices from the contractor did not initially contain all of the required information. Context and effect: We reviewed 100% of the invoices for the project and $38,324 was accrued as a year end liability and additional expense when the final contractor billing was received. This affected both grant revenue and expenses and led to adjustments on the Schedule of Expenditures of Federal Awards (SEFA). Auditor?s recommendation: We recommend enhanced monitoring procedures for large contracts and that application and certification for payment be reviewed and approved by an official with knowledge of the project and status before payment is issued. We also recommend contracts containing language applicable to Federal programs be prepared for all large projects. Management?s Plan of Action: Individuals Involved: Matt Combe, Superintendent/Management Gabriel Hansen, Chief Financial Officer/Business Manager Brandi Sweeney, Maintenance Coordinator Plan: Management has assigned the Business manager review of contract request for payment prior to payment and also for the cutoff date for reporting. The Business manager will request from contractors any information needed to properly allocate payment to proper periods prior to payments being issued. Team meeting will be held to discuss the progress of projects for the district to keep all responsible properly informed. Time Frame: Re-establish payment procedures on contracts completed by January 3, 2023. Process of team meetings to discuss projects progress completed by January 3, 2023.

View Audit 49017

Finding 42636 (2022-003)

Material Weakness 2022

Morrow County School District No. 1

OR

Subrecipient Monitoring Material Weakness Equipment & Real Property Management

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below...

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below. US DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF)- Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Material Weakness #2022-003 Auditor Discussion and Recommendation: Condition and criteria: The District should have control processes in place to ensure that allowable projects subject to prevailing wage requirements are performed under those requirements. There was one project that was subject to Federal prevailing wage requirements but did not get performed or documented for those requirements. Cause: The District did not have policies and procedures set up to monitor the prevailing wage requirements. Context and effect: The District has few capital projects funded by grant dollars, but there was one project for security improvements that fell under Federal prevailing wage guidelines. The proposal from the contractor said it included prevailing wage rates, but there was not an official contract found that would detail the prevailing wage requirements and we were unable to locate copies of certified payrolls indicating the District was not monitoring this requirement. The total cost of the project was $133,878 and included costs for the equipment and installation of the security enhancements. Auditor?s recommendation: We recommend the District update their policies and procedures to identify and monitor projects with Federal prevailing wage requirements. We also recommend contracts containing language applicable to Federal programs be prepared for all large projects. Management?s Plan of Action: Individuals Involved: Matt Combe, Superintendent/Management Gabriel Hansen, Chief Financial Officer/Business Manager Brandi Sweeney, Maintenance Coordinator Plan: The district will include in contracts language requesting the proper documentation of compliance with prevailing wage on contract using Federal programs. To monitor this requirement the district will request from contractors prevailing wage certifications if they are not received timely. Time Frame: Implement in contracts language stating request for documentation of compliance with prevailing wage laws completed by January 3, 2023 Implement review of certified payroll documents and request from contractors when not received completed by January 3, 2023.

View Audit 49017

Finding 42625 (2022-006)

Significant Deficiency 2022

Municipality of Toa Alta

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-006: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUT...

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-006: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY REPORTING - SPECIAL REPORTING (L) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: The Finance Director is aware of the compliance requirement. We gave instructions to the accounting staff to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Statement of Concurrence and Responsible Persons: We concur with the auditors' finding. Kristian Rivera Santiago, Finance Director Implementation Date: April 30, 2023. See Corrective Action Plan for chart/table

View Audit 48461

Finding 42623 (2022-007)

Significant Deficiency 2022

Municipality of Toa Alta

PR

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.327

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-007: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORIT...

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-007: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: We are going to prepare written policies and procedures in accordance with Uniform Guidance. Statement of Concurrence and Responsible Persons:We concur with the auditors' finding. Kristian Rivera Santiago, Finance Director Implementation Date: May 31, 2023. See Corrective Action Plan for chart/table

View Audit 48461

Finding 42620 (2022-005)

Significant Deficiency 2022

Municipality of Toa Alta

PR

Subrecipient Monitoring Reporting Significant Deficiency

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS RELIEF FUND (ALN 21.019) PASS-THROUGH P.R. DEPARTMENT OF TREASURY REPORTING - SPECIAL REPORTING...

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2022 FINDING 2022-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS RELIEF FUND (ALN 21.019) PASS-THROUGH P.R. DEPARTMENT OF TREASURY REPORTING - SPECIAL REPORTING (L) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action: The Finance Director is aware of the compliance requirement. We gave instructions to the accounting staff to maintain a dateline control sheet to ascertain that required reports for all grants were submitted within the due date. Statement of Concurrence and Responsible Persons: We concur with the auditors' finding. Kristian Rivera Santiago, Finance Director Implementation Date: April 30, 2023. See Corrective Action Plan for chart/table

View Audit 48461

Finding 42613 (2022-003)

Material Weakness 2022

National League of Cities

DC

Subrecipient Monitoring

NATIONAL LEAGUE OF CITIES CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 U.S. DEPARTMENT OF COMMERCE National League of Cities submits the following corrective action plan for the year ended September 30, 2022. Independent Public Accounting Firm: MARCUM LLP 1899 L Street NW, Suite...

NATIONAL LEAGUE OF CITIES CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 U.S. DEPARTMENT OF COMMERCE National League of Cities submits the following corrective action plan for the year ended September 30, 2022. Independent Public Accounting Firm: MARCUM LLP 1899 L Street NW, Suite 850 Washington, DC 20036 Audit Period: The findings from the September 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding No. 2022-003: Reporting ? Compliance Finding and Material Weakness in Internal Control Over Compliance ALN 11.307 ? Economic Adjustment Assistance, Grant Period: January 1, 2022 to September 30, 2022, Grant Number ED22HDQ3070070 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), prime recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime recipient is required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition and Context The League did not file a FFATA subaward report for its three subrecipients timely. All FFATA sub-award reports were filed after September 30, 2022, which was more than a month after the League awarded its subrecipients with grants more than $30,000. Recommendation It was recommended that the League implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Action Taken: NLC took the following corrective actions that addressed the noncompliance within the performance period of the subject cooperative agreement: (1) Uploaded all the required subaward data on FSRS.gov on November 13, 2022; (2) Institute a standard checklist procedure associated with issuance or modification of subaward agreements to determine possible applicability of the subaward reporting requirement. _______________ Contact Person Responsible for Corrective Action: Michael Terseck, Chief Financial Officer If the US Department of Commerce has questions regarding this plan, please call Michael Terseck, Chief Financial Officer, (202)329-6358. Sincerely, Michael Terseck Chief Financial Officer National League of Cities

View Audit 38790

Finding 42612 (2022-001)

Material Weakness 2022

Scripps Health and Affiliates

CA

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

Finding 2022-001: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and mana...

Finding 2022-001: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and manager responsibilities ? Modified failure to comply provisions ? Deployed educational programs for both management and staff ? Reviewed/improved Kronos Time and Attendance system automated notifications ? Made training resources available to management and staff via our Scripps intranet site Leadership monitors policy compliance by individual employee and manager via systemwide reporting on a biweekly basis. Contact person: Eric Cole Expected Completion Date: Completed ? September 2022

View Audit 40148

Finding 42610 (2022-001)

Material Weakness 2022

North Mason School District No. 403

WA

Questioned Costs Procurement, Suspension & Debarment 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, equipment, procurement and restricted purpose requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus ...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement and restricted purpose requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The following corrective actions are being implemented in response to the finding: 1. Implement a Resource Manager The District has purchased an asset management software to use as a tool to ensure compliance regarding tracking district assets, including laptop computers and other technology devices purchased using ECF funds. The software will provide the District with a centralized tracking system for our technology inventory. When laptops are distributed to school buildings for distribution, the software will be used when checking them out to students and staff using a unique asset tag number. With this software, the district will be able to match laptops and devices to individual students and the historical checkout, maintenance, and assigned location data will be available on all devices in our system and can be available at any time. A student will be issued only one device at a time. 2. Improve Use of Asset Tags The District already places asset tags on high value assets such as equipment and technology devices. Improvements being made include using a unique tag color of asset tag, and using ?ECF? as the first three digits in the asset tag number for technology devices purchased using ECF funds. 3. Procurement and Piggybacking The District is putting the following action steps in place to ensure compliance when entering an interlocal agreement and piggybacking: a. Review of all related board policies and procedures and follow them when procuring goods and services. b. Evaluate all procurement options to determine of piggybacking is the best option, c. Follow the SAO Guide: Piggybacking Under Washington State Law and follow all state law when procuring goods and services. d. Use the piggybacking checklist found in the SAO Guide. e. Pay particular attention to special guidelines and compliance rules for piggybacking when using federal funds. f. Consult with our legal representatives for additional guidance when needed g. Maintain all documentation supporting method of procurement of goods and services. Anticipated date to complete the corrective action: 1. An asset management software has already been purchased and will be implemented with all new technology assets starting with technology devices being distributed to schools this summer. School Library Technicians will be provided training at the start of the new school year in September 2023. 2. An order has already been placed for a new set of asset tags with the series of tag numbers beginning with ?ECF.? 3. The Assistant Superintendent of Finance and Operations, the IT Director, and Maintenance Director, will meet together in July 2023 to review district?s procurement policies and procedures, review the SAO?s Piggybacking Guide and checklist, and review the other procurement guides and resources found in the Resource Library on the SAO website.

View Audit 39523 Questioned Costs: $1

Finding 42569 (2022-001)

None 2022

City of Watsonville

CA

Subrecipient Monitoring Reporting

FEDERAL AWARD FINDINGS - CURRENT YEAR ?Finding reference number: 2022-001?Assistance Listing Number: 14.218?Assistance Listing Title: Community Block Development Grant Coronavirus (COVID19)?Name of Federal Agency: Department of Housing and Urban Development.?Fiscal Year of Initial Finding: 2022?Name...

FEDERAL AWARD FINDINGS - CURRENT YEAR ?Finding reference number: 2022-001?Assistance Listing Number: 14.218?Assistance Listing Title: Community Block Development Grant Coronavirus (COVID19)?Name of Federal Agency: Department of Housing and Urban Development.?Fiscal Year of Initial Finding: 2022?Name(s) of the contact person: Marissa Duran?Corrective Action Plan: The City is going to send the monitoring letter to the subrecipient as soon as possible. Also going forward, we have notified the program manager and her supervisor of this requirement for both continuous and one-time subrecipients. ?Anticipated Completion Date: June 30, 2023

View Audit 39729

Finding 42516 (2022-001)

Material Weakness 2022

Clarkston School District No. J250-185

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Clarkston School District No. J250-185 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Fede...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Clarkston School District No. J250-185 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). 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: Randy Lybyer, Director of Financial Services 1294 Chestnut Street Clarkston, WA 99403-0070 (509) 769-5538 Corrective action the auditee plans to take in response to the finding: The Clarkston School District welcomes the State Auditor?s Office review of federal wage rate requirements in our use of federal funds for the Grantham Elementary HVAC construction project. We agree with the auditor?s findings that our internal control structure was inadequate to ensure compliance with wage rate requirements. The following internal control processes have been implemented effective immediately. 1. Identify public works projects and other contracts that require compliance with federal wage rate requirements through regular communication with District administrators and maintenance/operations management staff. 2. Complete and enhance the Districts contracts checklists for agreements entered into with contractors, agencies or purchasing cooperatives for the contraction of public works projects. 3. Consult with ESD, OSPI, and SAO to assure proper and complete terms are included in agreement documentation. 4. Collect and review weekly Certified Payroll Reports from contractors and subcontractors upon commencement of applicable projects until completion. 5. Confirmation of receipt and review of Certified Payroll Reports shall be verified prior to vendor payments. A contributing factor to this internal control weakness was turnover in key compliance positions during the time the contracts were being processed and construction was commencing. Anticipated date to complete the corrective action: Immediately

View Audit 38833

Finding 42514 (2022-002)

None 2022

Mutual Hsg Assoc of So Central Ct Dba Neighborworks New Horizons

CT

Subrecipient Monitoring Eligibility Reporting

CORRECTIVE ACTION PLAN Audit Finding Reference: 2022-001 Planned Corrective Action: The Finance Department will work with a consultant to update the Policies and Procedures manual to be in line with best practices. We have implemented additional software modules to improve accuracy and efficiency ...

CORRECTIVE ACTION PLAN Audit Finding Reference: 2022-001 Planned Corrective Action: The Finance Department will work with a consultant to update the Policies and Procedures manual to be in line with best practices. We have implemented additional software modules to improve accuracy and efficiency in financial reporting. Finance added new hires towards the latter part of 2022 and management will provide training and professional development for the team. We are planning on completing a hard close for the period ending June 2023 and will consult with Cohn Reznick upon completion in Fall 2023. Our long-term goals are to conduct monthly and quarterly closes on all properties going forward. Name of Contact Person: Arlene Lawrence, CFO, arlene@nwnh.net, 203-562-4514 Anticipated completion date: November 2023 Audit Finding Reference: 2022-002 Planned Corrective Action: Our Property Management team worked with the tenant to bring the recertifications up to date. The recertification is now in compliance with the HOME Investment Partnerships Program. Name of Contact Person: Tom Cruess, President/CEO, tom@nwnh.net, 203-562-4514 Anticipated completion date: July 12, 2023

View Audit 38691

Finding 42510 (2022-004)

Material Weakness 2022

Oklahoma Association of Community Action Agencies, Inc.

OK

Subrecipient Monitoring

Corrective Action Plan Prepared by: Amanda Ewing, Executive Director Corrective Action Plan for this finding will be overseen by Executive Director and Office and Programs Manager and is already complete. A plan for compliance with this requirement was adopted by the Association on 10/1/2022. S...

Corrective Action Plan Prepared by: Amanda Ewing, Executive Director Corrective Action Plan for this finding will be overseen by Executive Director and Office and Programs Manager and is already complete. A plan for compliance with this requirement was adopted by the Association on 10/1/2022. Subrecipients of all current (FY23) grants are being monitored as required.

View Audit 38274

Finding 42496 (2022-001)

Significant Deficiency 2022

Unity House of Troy, INC

NY

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

To: Heather R. Lewis, Partner, MMB+CO From: Stacey Faulisi, CFO Re: Corrective Action Plan (CAP) Date: 7/24/23 Heather, Unity House is in agreement with the finding noted above. Given the finding on our single audit, we have developed the following, comprehensive CAP to decrease the likelihood of...

To: Heather R. Lewis, Partner, MMB+CO From: Stacey Faulisi, CFO Re: Corrective Action Plan (CAP) Date: 7/24/23 Heather, Unity House is in agreement with the finding noted above. Given the finding on our single audit, we have developed the following, comprehensive CAP to decrease the likelihood of any future findings, similar to those found by your audit. Finding 2022-001, Payments to Subrecipients (24 CFR section 576.203) Status: Corrective Action in Progress Planned Action: Prior to the findings noted in this audit, Unity House procured a comprehensive grants management software package. One of the intents of this software is to streamline the processes related to payments associated with every grant Unity House holds. In July 2023, procedures for tracking and processing subrecipient payments were updated. Dates related to internal approvals, receipt of final invoices, and payments issued to subrecipients will be tracked in our grants management system (anticipated to go live in August 2023). Quarterly reports will be generated in the system to monitor compliance. Additionally, a Subrecipient Check Request Form, which prompts a check to be cut by Unity House within two business days, has been created and will be submitted by the Unity House Subaward Manager upon receipt of final invoices. Responsible Party: Stacey Faulisi, CFO Completion Date: October 1, 2023 (full implementation), November 1, 2023 (complete first quarterly fidelity review)

View Audit 39157

Finding 42475 (2022-004)

None 2022

Gloucester City School District

NJ

Subrecipient Monitoring

Recommendation Number - 2022-004; Corrective Action Required by the Board - Grant amounts recorded in the school district's budget report must be in agreement with the State of New Jersey Department of Education EWEG System; Method of Implementation - District financial reports will be updated when ...

Recommendation Number - 2022-004; Corrective Action Required by the Board - Grant amounts recorded in the school district's budget report must be in agreement with the State of New Jersey Department of Education EWEG System; Method of Implementation - District financial reports will be updated when Federal Grant budget amendments are made, ensuring all records are in agreement; Person Responsible for Implementation - School Business Administrator; Planned Completion Date of Implementation - 06/30/2023.

View Audit 38674

Corrective Action Plans

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