Corrective Action Plans

Finding 45314 (2022-006)

Material Weakness 2022

Montgomery County

IN

Subrecipient Monitoring Period of Performance Questioned Costs § 200.1 § 200.211 § 200.303 § 200.458

FINDING 2022-006 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: ALN changed during middle of audit period. Will inquire mid-year with departments managi...

FINDING 2022-006 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: ALN changed during middle of audit period. Will inquire mid-year with departments managing grants to see if any ALN changes. If so, new grant fund will be created. Anticipated Completion Date: 08/2023

View Audit 40738 Questioned Costs: $1

Finding 45313 (2022-005)

Material Weakness 2022

Montgomery County

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2022-005 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Health Department will continue to prepare required reports with a separate individual r...

FINDING 2022-005 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Health Department will continue to prepare required reports with a separate individual reviewing prior to submission. Anticipated Completion Date:12/2023

View Audit 40738

Finding 45312 (2022-004)

Material Weakness 2022

Montgomery County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Suspension and Debarment Ordinance being presented to Board of Commissioners at 08/2023 ...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Suspension and Debarment Ordinance being presented to Board of Commissioners at 08/2023 meeting. Clause will be included in all contracts entered into by the County. Commissioners will review contracts to verify clause is included before approving contract. Anticipated Completion Date: 08/2023

View Audit 40738

Finding 45277 (2022-003)

Material Weakness 2022

Brownsburg Community School Corporation

IN

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

FINDING 2020-003 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator of Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan...

FINDING 2020-003 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator of Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Moving forward, the Nutrition Services Coordinator will ensure that a contract between the district and the vendor is in place when purchases are over $150,000 annually, per the district?s Child Nutrition Procurement Plan. Anticipated Completion Date: July 1, 2023

View Audit 50997 Questioned Costs: $1

Finding 45276 (2022-002)

Significant Deficiency 2022

Brownsburg Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.212 § 200.318

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator for Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Pla...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator for Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Moving forward, the Nutrition Services Coordinator will ensure that a certification of suspension and debarment is completed prior to approving contracts over the $150,000 threshold, per the district?s Child Nutrition Procurement Plan. Anticipated Completion Date: July 1, 2023

View Audit 50997

Finding 45240 (2022-005)

None 2022

Harvey Public School District 152

IL

Reporting Questioned Costs Subrecipient Monitoring

Condition The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for 33 reports. Plan The District will monitor these filing requirements more closely when the filing deadline approaches. Anticipated Date of Completion 6/30/23. Name of Co...

Condition The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for 33 reports. Plan The District will monitor these filing requirements more closely when the filing deadline approaches. Anticipated Date of Completion 6/30/23. Name of Contact Person Lela Bridges, Interim Superintendent. Management Response The District experienced turnover for key employees within the grant reporting process and is currently strengthening internal control procedures over grant reporting and monitoring.

View Audit 53487

Finding 45230 (2022-001)

None 2022

Susquehanna Township School District

PA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.320

Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement stan...

Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement standards. View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Federal acquisition thresholds and requirements. Effective the 22-23 fiscal year forward the District will fully deploy the referenced administrative procedures to all applicable District stakeholders and monitor all such procurements for compliance purposes.

View Audit 51859

Finding 45219 (2022-001)

Material Weakness 2022

Willoughby-Eastlake City School District

OH

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact...

Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact Person: Donna Solano, Financial Aid Coordinator

View Audit 50590

Finding 45210 (2022-009)

Material Weakness 2022

Shiloh Neighborhood Development Corporation

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

FINDING 2022-009: Prevailing Wage Rate Internal Control and Compliance Response: Going forward all construction using federal funds in excess of $2000 will have a contract stating the prevailing wage rate clause and submission of weekly certified payrolls.

View Audit 49073

Finding 45200 (2022-001)

Significant Deficiency 2022

City of Bloomington, Illinois

IL

Subrecipient Monitoring

Condition: The City did not submit the necessary FFATA reports for two of its subrecipients. Corrective Action Plan: Due to recent HUD monitoring, one subaward agreement (Bloomington Housing Authority) will begin to be awarded directly to the subrecipient in future years. The City now has a fully...

Condition: The City did not submit the necessary FFATA reports for two of its subrecipients. Corrective Action Plan: Due to recent HUD monitoring, one subaward agreement (Bloomington Housing Authority) will begin to be awarded directly to the subrecipient in future years. The City now has a fully-staffed Community Development department with positions supporting the CDBG grant. The City has added FFATA reporting as a part of its subaward process. The City will also seek out technical assistance and training to ensure successful reporting going forward. Anticipated Date of Completion: November 2022 Contact Person: Patti-Lynn Silva, Finance Director

View Audit 41926

Finding 45178 (2022-007)

Significant Deficiency 2022

Tabor College, Inc.

KS

Questioned Costs Student Financial Aid Subrecipient Monitoring

2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the...

2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College is currently meeting with companies who provide services to assist with meeting the requirements of the Gramm-Leach-Bliley Act. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: April 2023 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.

View Audit 44253

Finding 45136 (2022-004)

Material Weakness 2022

South Dearborn Community School Corporation

IN

Special Tests & Provisions Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses ar...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses are incurred and paid by the district instead of reimbursing the private schools their expenses. This will be reviewed by the Director of Curriculum to ensure compliance. Anticipated Completion Date: March 2023

View Audit 45261

Finding 45126 (2022-001)

Material Weakness 2022

North Fork Local School District

OH

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

The District will enforce, not only that the contract includes prevailing wages are to be paid, but that certified payroll reports from contractors are provided to the District. These payroll reports will be reviewed, and retained before payment will be made to the contractor. The control and proc...

The District will enforce, not only that the contract includes prevailing wages are to be paid, but that certified payroll reports from contractors are provided to the District. These payroll reports will be reviewed, and retained before payment will be made to the contractor. The control and procedure will be implemented immediately by completing a check list. To comply with the prevailing wage law this checklist will be completed before payment is issued to the contractor.

View Audit 45258

Finding 45098 (2022-002)

Significant Deficiency 2022

North Olympic Healthcare Network

WA

Questioned Costs Subrecipient Monitoring Reporting

U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost reven...

U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost revenue amounts on any subsequent filings, if applicable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will design and implement procedures of review ensuring the appropriate option is selected for how lost revenue is reported for any future reporting periods and on any subsequent filings. Name(s) of the contact person(s) responsible for corrective action: Beau Brown, CFO Planned completion date for corrective action plan: September 30, 2023.

View Audit 40455

Finding 45027 (2022-001)

Significant Deficiency 2022

Chespenn Health Services, Inc.

PA

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Servi...

Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Services, Inc.'s Compliance Officer and Chief Operating Officer will conduct random monthly audits of sliding fee applications at all three locations. Results from the audits will be presented to the site Office Manager who will then conduct staff training sessions with the Patient Service Representatives. The audit and subsequent training will include a review of the following parameters for proper documentation and sliding fee scale determination: Identification: o State issued driver's license o State issued or state recognized identification card o School identification o Government issued passport o If married, a copy of spouse's identification as well Social Security Cards: o For the applicant o For the spouse, if married o For all dependents 18 years of age or younger o For a college student, up to 23 years of age with college documentation o If a social security card is not available for a child, a birth certificate will be accepted Paystubs: o One recent pay stub, if married a copy from spouse as well o Benefits statement from social security, if married from husband and wife o Awards letter for unemployment, if married from husband and wife o Self-employed - Last year's income tax statement o If paid in cash, a letter from the employer, on company letter head that states the hourly rate and hours worked o If the letter is handwritten, the letter must be notarized o When an individual has no source of income and has no insurance, they are required to fill out the information on the front and the back of the sliding fee scale form. Photo identification and social security cards are required Responsible Party: Susan Harris-McGovern, President/CEO Susan.harris@chespenn.org, 610-485-3800 Estimated Time of Completion: March 31, 2023

View Audit 40406

Finding 45022 (2022-001)

Significant Deficiency 2022

Early County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.403

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Federal Awarding Agency: U.S. Department of Education Pass-Thr...

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

View Audit 39876 Questioned Costs: $1

Finding 44959 (2022-001)

Material Weakness 2022

Elma School District No. 68

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Elma School District No. 68 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federa...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Elma School District No. 68 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included 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 allowable activities and costs, procurement, and restricted purpose requirements Name, address, and telephone of District contact person: Lisa Arnold 1235 Montesano Elma Road Elma, WA, 98541 (360) 482-2822 Corrective action the auditee plans to take in response to the finding: The district concurs with the auditor. The district will ensure that processes are followed by all purchases going through the district office for approval before purchase. Purchases are now through an online system InformedK12 to help ensure procedures are followed. The district would like to note that this finding is because the district did not go out to bid for the student Chromebooks. The bid step was overlooked due to the quick turnaround to purchase devices to make sure all students had Chromebooks for the pandemic. Anticipated date to complete the corrective action: 01/2023

View Audit 46960 Questioned Costs: $1

Finding 44952 (2022-002)

Significant Deficiency 2022

Public Allies, INC

WI

Subrecipient Monitoring § 200.208 § 200.332 § 200.338 § 200.425 § 200.501

CORRECTIVE ACTION PLAN Finding 2022-002: Subrecipient Monitoring ...

CORRECTIVE ACTION PLAN Finding 2022-002: Subrecipient Monitoring Public Allies has developed a Risk Assessment tool that will be implemented with subgrantees ("local sites") for Program Year '23. The tool?s development was driven by noted best practices and guidance shared with AmeriCorps grantees and Public Allies? prior monitoring findings. The tool includes a self-assessment by local sites and the results will drive the level of monitoring and training and assistance each site receives. Public Allies will also be piloting a new Progress Report, that will provide an at-a-glance assessment of site performance based upon metrics determined in collaboration with subgrantees. The programmatic monitoring process will be led by a dedicated monitoring team that is supported by staff that provide direct programmatic training and technical assistance to sites. For fiscal monitoring, Public Allies has shifted from outsourcing all accounting and financial management to bringing all accounting in-house. As described above, this staff now includes a Finance Director, a Staff Accountant and Senior Accountant. This shift was the result of an evaluation of internal operations and financial management systems. The addition of multiple full-time accounting staff has improved our capacity to monitor and manage subgrantees, effectively track and manage process improvements, ensure fiscal-related grants compliance, and efficiently manage our federal grant funding requests and reports. A fiscal Grants Manager was hired to review subgrantee financial reporting, provide technical assistance, and implement financial monitoring of subrecipients. Finally, a desk audit will be implemented in FY23. The number of files to be reviewed for each site will be determined based upon risk factors assessed, including: AmeriCorps Monitoring Common Findings, staff retention data, prevalence of turnover in AmeriCorps members, and length of time since the site underwent an audit. Requested programmatic and fiscal documents will include: ? Ally/Member Leadership Journal Position Descriptions ? Time Logs ? Ally/Member Evaluations ? Exit Documentation ? Ally/Member Payroll Register, and ? Operating Partner Due Diligence ? Annual Financial Statement ? Separation of Duties Survey ? Internal Controls Questionnaire The Public Allies Network will be notified of the Desk-Based Audit by May 26th and the desk audit will conclude by fiscal year end. Findings of the audit, in the form of a Monitoring Report will be shared with subrecipients, including required follow-up necessary to remediate compliance findings. Results of the desk audit will be used to determine future training needs, policy recommendations, and future monitoring Person Responsible: Najah Woods, Apprenticeship Program Grants Manager Implementation Date: August 31, 2023

View Audit 44589

Finding 44948 (2022-002)

Significant Deficiency 2022

Albright College

PA

Questioned Costs Subrecipient Monitoring Reporting

Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corr...

Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corrective Action Plan The College has corrected the misstated reports. To help ensure this does not occur again, the College will appropriately assign all necessary data collection responsibilities and ensure that corresponding submission deadline are clearly communicated. The Assistant Controller will be assigned the responsibility to coordinate the collection of necessary data and the compilation of the report. The Controller will then review the draft report and make timely submission. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeffrey Strader ? Vice President, Finance and Strategic Partnerships Anticipated Completion Date: Reports have been corrected as of February 2023 and secondary review will be performed in quarters going forward. Procedures will be incorporated into the College?s work processes during Fiscal Year 2022-2023

View Audit 39624

Finding 44947 (2022-001)

None 2022

King's College

PA

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

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year -...

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.

View Audit 38808

Finding 44881 (2022-001)

Significant Deficiency 2022

Alight

MN

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken ...

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.

View Audit 44660

Finding 44824 (2022-001)

None 2022

Citizens for Better Living, Inc.

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form...

Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form to the Federal Audit Clearinghouse within the required time period. Management agrees to the finding and recommendation. Action(s) Taken or Planned on the Finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on October 11, 2022, no further action is required.

View Audit 46027

Finding 44823 (2022-001)

Significant Deficiency 2022

Cit of Richmond

CA

Cash Management Subrecipient Monitoring Reporting

Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: F...

Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: FEMA-4308-DR-CA Name of pass-through Entity: California Office of Emergency Services Name(s) of the contact person: Nickie Mastay, Daniel Chavarria Corrective Action Plan: Since noting the deficiencies, the Public Works Department has successfully hired a new Public Works Director, a new Deputy Public Works Director, project managers, and support staff to improve and adhere to necessary grant reporting and reimbursement with proper supporting documentation. Management has assigned a team to review and track all grants monthly, including the Via Verdi project. All team members will be trained on grant reporting and drawdown, and reminders set in their calendars to ensure these tasks are completed in a timely manner. Anticipated Completion Date: Fiscal Year 23-24

View Audit 45353

Finding 44789 (2022-066)

Significant Deficiency 2022

State of Oregon

OR

Subrecipient Monitoring § 200.332

2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 20...

2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary. MANAGEMENT RESPONSE: We agree with this recommendation. ODE acknowledges that it did not implement pandemic funding related desk audit and site monitoring procedures in FY 21. FY 21 saw the COVID-19 Delta and Omicron variants continue to infect school staff and students so on-site visits were not feasible. The pandemic also forced districts to dedicate administrator time and attention to student health and safety and adjusting to the ever-changing health environment, guidance and requirements. In anticipation of such challenges during the pandemic, ODE set up the ESSER reimbursements to districts allows for much more detailed reporting when requesting reimbursement to allow ODE to track how districts were spending their funds. While not traditional monitoring, it was an effective, efficient, and creative way to ensure ODE spending oversight in unprecedented times. As discussed with Secretary of State auditors, ODE finalized and implemented a risk assessment tool in the spring of 2023 and has completed an initial set of ten monitoring desk reviews with districts. Anticipated Completion Date: June 30, 2024 Contact: Cynthia Stinson, Senior Manager of Federal Investments & Pandemic, Renewal Effort, OTLA

View Audit 45093

Finding 44787 (2022-031)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring

2022-031 Oregon Housing and Community Services Comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.027 Coronavirus State and Local Fiscal Recovery Fund (COVID-19) Federal Award Numbers and Years: OMB Appro...

2022-031 Oregon Housing and Community Services Comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.027 Coronavirus State and Local Fiscal Recovery Fund (COVID-19) Federal Award Numbers and Years: OMB Approved No. 1505-0271, 2022 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness, Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 45 CFR 75.351; 45 CFR 75.352(b); 45 CFR 75.352(d) When recipients of Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) provide award funds to an entity to carry out objectives of program on behalf of the CSLFRF recipient, the entities receiving such funding are subrecipients. The recipient has the responsibility to monitor expenditures and activities subrecipients. Nearly all the department?s CSLFRF expenditures are comprised of payments to a private organization. Per the contract, the organization was hired to conduct eligibility assessments for the Emergency Rental Assistance program and be responsible to ensure only eligible applicants receive rental and utility assistance payments. CLSFRF funds were used for emergency rental assistance; therefore, the organization is carrying out a program on behalf of the department. The department then has the responsibility to monitor the expenditures and activities of the organization. The department incorrectly identified the organization as a vendor rather than a subrecipient during the contracting process. Per the guidance above, this was not an appropriate determination because the organization carries out eligibility determinations of the program. Management acknowledged no monitoring of the organization was performed during the audit period; therefore, there are no related key controls for the fiscal year ended June 30, 2022. Although program staff maintain a close working relationship with the organization, these interactions are not formalized and documented for the purpose of subrecipient monitoring. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management reassess the department?s contracting process to appropriately identify whether an organization is a vendor or a subrecipient. If a subrecipient, we recommend the department comply with subrecipient monitoring requirements, including developing related internal controls and processes to monitor the expenditures and activities of the organization. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS performed appropriate due diligence in determining whether organization was a subrecipient or vendor. Internally OHCS identified the issue of how to classify the organization and used all resources available to make the determination. The result of the due diligence and discussion was that OHCS determined the organization should be classified as a vendor, not a subrecipient. OHCS will review and strengthen the current process for determination. Anticipated Completion Date: December 31, 2023 Contact: Sandra Flickinger, Procurement Manager

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