Corrective Action Plans

Finding 547291 (2024-004)

Material Weakness 2024

Rising Sun - Ohio County Community School Corporation

IN

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

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the findi...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We had never been instructed to do price quotes for items purchased from the HPS Purchasing Co-Op before. In the future, we will obtain price quotes when purchasing from HPS when purchases are above the micro-purchasing threshold. Or we will find a different purchasing avenue and will not use HPS. The cafeteria director is currently discussing this with each of the cafeteria supervisors to decide which avenue they will use to avoid the finding in the future. Going forward, for any vendor expected to equal or exceed $25,000 that is paid from school lunch funds (or any federal funds for that matter), someone at the school corporation will verify those vendors aren’t suspended or debarred. Anticipated Completion Date: 08/01/2025: The next school year.

View Audit 351598

Finding 547285 (2024-007)

Significant Deficiency 2024

State of South Dakota

SD

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits The following are the actions that have been taken to come into compliance with monitoring subrecipient audits: • Office of Emergency Management’s, Recovery Branch Chief has reviewed the outstanding audit fin...

Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits The following are the actions that have been taken to come into compliance with monitoring subrecipient audits: • Office of Emergency Management’s, Recovery Branch Chief has reviewed the outstanding audit finding and issued the management letter resolving the issue on March 12, 2025. • The Assistant Finance Officer reviewed FAC.gov for outstanding subrecipient audits in February of 2025. At this time, we discovered the two audits in question were not received through the Department of Legislative Audit (DLA). We have updated our process to review the subrecipient audit report tracking spreadsheet at least semi-annually, which will also include a review of FAC.gov to locate audit reports not submitted to DLA so that we can manage the timeliness of our review process and issue management letters, if required, within the 180-day period. • The Director of Administrative Services approved the updated process on March 14, 2025. Contact Person: Angie Lemieux, Director of Administrative Services Anticipated Completion Date: Issued management letter resolving the issue on March 12, 2025

View Audit 351592

Finding 547277 (2024-012)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transit...

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transition of key program personnel. Information that appears to be inaccurate serves as a combination of the inability to make revisions for previously reported students and human error. The CMC principal investigator for CMC was a first-time awardee, who was not fully acclimated to the grant reporting process prior to submitting the report. The Student Support Services program is committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The program will review the existing program operating procedures and processes to align with requirements. Program personnel will engage in professional development opportunities and training to improve grant management. Currently, financial reporting is reviewed by individuals in both the Business Office and GSPAR. GSPAR will enhance its internal controls, policies, and procedures to ensure that all reporting is submitted with accurate information. GSPAR intends to create a centralized location to track and store all supporting documentation for easy access and review. GSPAR also intends to require that all financial information required by government agencies be reviewed by officials in both the Business and GSPAR Offices. In addition, GSPAR will implement a process for continuous monitoring of program records to ensure compliance with federal, Institutional and program requirements. The program staff will also engage in professional development opportunities to improve grant management and regulatory compliance. Anticipated Completion Date: December 31, 2025

View Audit 351580

Finding 547270 (2024-009)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. Du...

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification. Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response. During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained. Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement. With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals. Anticipated Completion Date: June 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547254 (2024-004)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for...

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for the timely and accurate notification of loan disbursements. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition to Ellucian Colleague for financial aid management. University officials are committed to rectifying this deficiency through significant enhancements to our notification processes and technological infrastructure. The systematic integration of notification with the actual disbursement function via Ellucian Colleague represents a robust solution to ensure compliance. By handling this process internally, we ensure greater control, reliability, and compliance with federal regulations. Regular audits of the disbursement and notification process will be implemented to guarantee that our procedures remain in alignment with federal requirements and best practices. This proactive approach ensures that all loan disbursements are properly managed and communicated, safeguarding both our students' financial interests and the university's compliance status. The university has already begun to amend procedures to ensure that all loan disbursements are accompanied by timely and accurate notifications. The Office of Financial Aid will maintain detailed records showing compliance with these notifications. The integration of Ellucian Colleague will automate the notification process. This system ensures that notifications are sent immediately upon disbursement processing, using various modalities such as email, text messages, or direct updates to the student portal. We will enhance our enhance record-keeping through the utilization of Ellucian Colleague by logging all communications sent, ensuring that there is traceable evidence of compliance. This system integration addresses previous dependencies on third-party technologies and brings control of this crucial compliance aspect in-house. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547245 (2024-001)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions rel...

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria. Anticipated Completion Date: September 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547231 (2024-002)

None 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

Equipment & Real Property Management Subrecipient Monitoring Cash Management § 200.465

Finding No. 2024-002 – Rental Costs of Real Property and Equipment Condition Found When renewing the rental contract for the administration of the Revolving Fund, the DOH, as the Revolving Fund administrator, complied with statutory laws and procedures governing contract renewal. However, under the ...

Finding No. 2024-002 – Rental Costs of Real Property and Equipment Condition Found When renewing the rental contract for the administration of the Revolving Fund, the DOH, as the Revolving Fund administrator, complied with statutory laws and procedures governing contract renewal. However, under the applicable regulations, if a contract renewal does not include a fee increase, there is no statutory requirement to evaluate comparable rental properties or conduct a periodic market study to assess potential changes in market conditions. As a result, the Revolving Fund lacks, within its existing processes and documentation, established policies and procedures for performing and documenting such assessments and did not conduct the evaluation required under 2 CFR § 200.465 in a timely manner. However, during discussions with the auditors, the required evaluation was performed, demonstrating that the rental costs remain reasonable in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan Having addressed and resolved the matter in reference, we also concur what was discussed with the auditors, that the required information was provided demonstrating that the costs for rent are reasonable and are in accordance with the provisions of the federal regulations, proceeded as follows: • In parallel to the current process of renewal of the lease contract, the Program performed the reasonableness study for rent cost, regardless of the non-requirement within the current procedure. The study confirmed that the rent costs are reasonable and cost effective. • For the purpose and as part of the corrective action plan, the Program incorporated as part of its processes a procedure to achieve the implementation of periodic evaluation of rental costs. This procedure incudes among others, the frequency in which such evaluations will be carried out. • The Program, as Administrator, will recommend the Department of Health’s management the need to incorporate the periodic requirement in compliance with the 2 CRF § 200.465 federal section. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547230 (2024-001)

Significant Deficiency 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

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

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2...

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2, 2022. Therefore, repayment of principal and payment of interest should have begun on their respective dates, as set forth in the loan agreement and notes payable executed thereto. Views of Responsible Officials and Corrective Action Plan Once the final inspection of a construction project is performed, DOH will submit notifications to PRASA requesting the Notice of Substantial Completion letter from PRASA concurring that the project is acceptable of the operation. Such letter will be an attachment to the formal notification that DOH will send to PRASA and PRIFA. DOH’s letter will specify the starting operating date and the useful life of the project. Therefore, PRIFA will be in position to collect principal and interest for the project according to federal regulations and as established in the loan agreement. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547227 (2024-002)

Significant Deficiency 2024

Roswell Independent School District No.4

NM

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Auditor’s Recommendation - The auditor recommends the District select a methodology and implement, or update the current methodology to what is being done on the Documentation of Compliance and to ensure finance and title I program manager/personnel are in communication with each other. Views of Res...

Auditor’s Recommendation - The auditor recommends the District select a methodology and implement, or update the current methodology to what is being done on the Documentation of Compliance and to ensure finance and title I program manager/personnel are in communication with each other. Views of Responsible Officials of Auditee: The District acknowledges that the methodology used was not properly described in the signed compliance document; however, the District affirms that Title I allocations were compliant with Title I guidelines. Moving forward, the District will ensure that the wording in documentation accurately reflects the procedures used at the school level. Responsible Party: Glenda Leonard, Educator Sustainability and School Support, Jennifer Cole, Assistant Superintendent of Curriculum and Instruction, Micheal Sexton, Assistant Superintendent for Finance & Operations, and Brian Luck, Superintendent Anticipated Completion Date: June 30, 2025

View Audit 351551

Finding 547223 (2024-014)

Material Weakness 2024

Huntington County Community School Corporation

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2024-014 Finding Subject: COVID 19-Education Stabilization Fund-Special Tests and Provisions-Wage Rate Requirements Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12...

FINDING 2024-014 Finding Subject: COVID 19-Education Stabilization Fund-Special Tests and Provisions-Wage Rate Requirements Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions and construction wage rate requirements. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. The Grant Specialist will ensure future projects with construction contracts will have a prevailing wage clause while also monitoring payroll to verify compliance. To ensure that the construction wage rate is complied with, the contractor will submit the certified payrolls to the Grant Specialist who will then provide to the Corporation Treasurer for review, initial and file with the construction pay application. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547217 (2024-013)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We ...

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547210 (2024-012)

Material Weakness 2024

Huntington County Community School Corporation

IN

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

FINDING 2024-012 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Ed...

FINDING 2024-012 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-027-PN01, 22611-027-ARP, 22619-027- ARP, 23611-027-PN01, 23619-027-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies: Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Anticipated Completion Date: All expenditures initiated after March 26, 2025

View Audit 351544

Finding 547197 (2024-009)

Material Weakness 2024

Huntington County Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Num...

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Monthly meetings will be held between the Title 1 Director, administrative assistant, and member of the business office to ensure all non-public schools receive and expend monies and documentation will be signed off on by two people and kept with reimbursement forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547195 (2024-008)

Material Weakness 2024

Huntington County Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years...

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Assessment System Security Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Each building will create a list of staff that are required to complete the testing security training for Assessments. Staff will sign off on completion of training. The Director of Curriculum and/or the Director of Title 1 will review and sign off after ensuring that all required staff have completed the training. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547193 (2024-007)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (o...

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Supplement Not Supplant Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Monthly meetings will be held between Title 1 Director, administrative assistant, and member of the business office to ensure all Title 1 schools receive and expend monies and documentation will be signed off on by two people and kept with reimbursement forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547191 (2024-006)

Material Weakness 2024

Huntington County Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.303 § 200.334

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Othe...

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All withdrawals will have the proper documentation (transcript request or withdrawal form) attached to the student record and the form will be dated within two weeks of the student enrollment end date. The forms must be signed by the parent and the principal. Title 1 Director will review for accuracy and completion of forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547189 (2024-005)

Material Weakness 2024

Huntington County Community School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers)...

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A210014, S010A220014, S010A230015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Unused homeless reservation set aside funds will be carried over and added to the set aside amount for the new grant application. The Form 9 will be reviewed and signed off on by the Title 1 Director and a member of the business office. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547187 (2024-004)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A21...

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Title 1 Director and a member of the business office will check to ensure the enrollment counts provided in the Title 1 application are accurate and that the nonpublic school enrollment, addresses, and socioeconomic status of students are accurate before submitting the information on the Title 1 application. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547176 (2024-003)

Material Weakness 2024

Area 20/21 Workforce Development Board

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Procedures were put in place in October 2024 to monitor CCMEP spending.

View Audit 351543

Finding 547172 (2024-004)

Material Weakness 2024

Asian University for Women (auw) Support Foundation

MA

Subrecipient Monitoring § 200.332

Finding 2024-004: Identifying the Award and Applicable Requirements Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless, AUWSF ta...

Finding 2024-004: Identifying the Award and Applicable Requirements Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.

View Audit 351526

Finding 547171 (2024-003)

Material Weakness 2024

Asian University for Women (auw) Support Foundation

MA

Subrecipient Monitoring Reporting

Finding 2024-003: Subrecipient Monitoring Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless the management will implement train...

Finding 2024-003: Subrecipient Monitoring Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless the management will implement training on relevant Asian University for Women (AUW) program personnel in the area of Federal Funding Accountability and Transparency Act (FFATA). All such training of relevant personnel is planned to be completed by December 31, 2025.

View Audit 351526

Finding 547170 (2024-002)

Material Weakness 2024

Asian University for Women (auw) Support Foundation

MA

Subrecipient Monitoring § 200.332

Finding 2024-002: Subrecipient Monitoring – Risk Assessment Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management does not agree that there is a material weakness related to compliance with the grant. Manag...

Finding 2024-002: Subrecipient Monitoring – Risk Assessment Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management does not agree that there is a material weakness related to compliance with the grant. Management would like to note the following points: 1) There are two organizations, The Asian University for Woman (AUW), and the Asian University for Woman Support Foundation (AUWSF). These are separate organizations, but AUWSF exists solely to support AUW, and AUWSF is constantly monitoring AUW. 2) The US State Department has emailed that AUW is NOT a subrecipient of AUWSF. This email was forwarded to the auditors. 3) The US State Department has been substantially involved in helping AUWSF carry out this grant work, since 2022, and has not provided any feedback that the AUWSF should be carrying out additional risk assessment procedures on AUW. 4) AUWSF had a fiscal year 2023 single audit, done by the same auditors here, with substantially the same grants and there was no material weakness related to compliance noted during that audit. 5) A variety of information about the AUW and AUWSF including their clean audited financial statements, internal control policies, and other information is documented and publicly available on the AUW and AUWSF’s joint website. 6) AUWSF notes that it actively monitors and reviews the expenditures of the funds they provide to AUW. The funds are paid in installments and only upon satisfactory receipt of documentation of funds expended are subsequent installments sent. AUWSF receives monthly financial statements and bank statements from AUW to further reconfirm the AUW expenditures. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.

View Audit 351526

Finding 547168 (2024-001)

Significant Deficiency 2024

Fort Thomas Unified School District No.7

AZ

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

2024-001: PROVISIONS OF THE DAVIS-BACON ACT Program: Federal Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), Significant Deficiency in internal control Compliance Requirement: N. ...

2024-001: PROVISIONS OF THE DAVIS-BACON ACT Program: Federal Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), Significant Deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Repeat Finding: No. Condition/Context: During our testing on one of 1 contractor, we noted the District did not have adequate internal controls designed to ensure contractors were in compliance with applicable Davis-Bacon Wage Rate requirements. The District did not retain documentation supporting indication of certified payrolls being submitted in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by Impact Aid. In addition, contracts or purchase orders were not documented to support the need for compliance under Davis Bacon. Corrective Action: The District will establish internal control procedures during the purchasing process to ensure that all required vendors adhere to the provisions of the Davis Bacon Act and will obtain certified payroll reports to ensure compliance with those provisions. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Derrick Bryce, Business Manager

View Audit 351521

Finding 547145 (2024-004)

Significant Deficiency 2024

Anne Arundel County, Maryland

MD

Subrecipient Monitoring § 200.332

2024-004: 93.959 – Substance Use Prevention, Treatment, and Recovery Services  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disag...

2024-004: 93.959 – Substance Use Prevention, Treatment, and Recovery Services  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards.  Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

View Audit 351510

Finding 547144 (2024-003)

Significant Deficiency 2024

Anne Arundel County, Maryland

MD

Subrecipient Monitoring § 200.332

2024-003: 59.059 – Inclusive Ventures Programs  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees w...

2024-003: 59.059 – Inclusive Ventures Programs  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards.  Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

View Audit 351510

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