Corrective Action Plans

Finding 544730 (2024-005)

Material Weakness 2024

Liberty-Perry Community School Corporation

IN

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

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct th...

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct the Allowable Activities and Costs procedures for Federal Grants. Anticipated Completion Date: March 2025

View Audit 351229

Finding 544715 (2024-004)

Significant Deficiency 2024

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding Reference 2024-04 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all related federal requirements for the reporting process of these funds. Additionally, an adequate training will be provided to the personnel in...

Finding Reference 2024-04 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all related federal requirements for the reporting process of these funds. Additionally, an adequate training will be provided to the personnel involved in the administration of this program. Responsible: Mr. Ramon L. Rivera Rivera, Analyst Mr. Enrique J. Rosa Torres, Budget Office Auxiliary Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2025.

View Audit 351216

Finding 544713 (2024-003)

Significant Deficiency 2024

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.326

Finding Reference 2024-03 Corrective Action Plan: All personnel involved in the administration of programs that expend federal funds, including contractors and subcontractors, will receive adequate training on Davis-Bacon Act requirements and payroll certification processes. Responsible: Eng. Maria ...

Finding Reference 2024-03 Corrective Action Plan: All personnel involved in the administration of programs that expend federal funds, including contractors and subcontractors, will receive adequate training on Davis-Bacon Act requirements and payroll certification processes. Responsible: Eng. Maria Ayala Rivera, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2025.

View Audit 351216

Finding 544690 (2024-004)

Significant Deficiency 2024

Tusculum University

TN

Subrecipient Monitoring Student Financial Aid Significant Deficiency

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in cha...

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the designated employees in charge of overseeing the GLBA Policy Corrective Action Planned During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. A new policy was put into place during June 2024. During the 2023-24 academic year, the policy was being updated to be compliant. Due to this finding in 2022-23, the FSA Cyber Compliance Team reached out to Tusculum and Tusculum provided the Corrective Action Plan and new policy. On August 1st, 2024, Tusculum received word that the CAP acceptably addressed the GLBA finding. Anticipated Completion Date 08/1/2024

View Audit 351195

Finding 544682 (2024-003)

Material Weakness 2024

Whitley County Consolidated Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodt...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: The School Corporation concurs with the finding Description of Corrective Action Plan: To ensure compliance with federal procurement regulations, prior to entering into a purchase agreement using federal funds exceeding $25,000, the Food Service Director or Assistant Food Service Director will take one of the following actions: 1. Verify Vendor Status: Check the System for Award Management (SAM) Exclusions List to confirm the vendor is not suspended or debarred. 2. Obtain Certification: Collect a written certification from the vendor affirming their eligibility to receive federal funds. 3. Include Contractual Safeguard: If applicable, incorporate a clause or condition in the purchase agreement requiring compliance with federal suspension and debarment regulations. These steps will be documented and retained for audit purposes to ensure full compliance with federal procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 22 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com Anticipated Completion Date: 07/01/2025

View Audit 351189

Finding 544680 (2024-002)

Material Weakness 2024

Whitley County Consolidated Schools

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.303

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

View Audit 351189

Finding 544671 (2024-002)

Material Weakness 2024

Washington County Board of Education

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Assistance Listing: 21.027 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 211851 (3/3/2021 -12/31/2024) Compliance...

Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Assistance Listing: 21.027 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 211851 (3/3/2021 -12/31/2024) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Recommendation We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. However, WCPS did adjust our practices during fiscal year 2024 based on guidance from our previous audit firm to add the suspension and debarment affidavit to all new vendor registrations and service contracts. Action taken in response to finding: Effective immediately, the Purchasing Department will review all requisitions that are going against Fund 02 (Restricted Fund) and ensure that the vendor has been checked for suspension/debarment. New vendors are required to sign an affidavit that they have not been suspended or debarred. This check will ensure that old vendors that were in place prior to the FY 2023 finding have been validated against SAM.GOV or have a signed affidavit to ensure they have not been suspended or debarred. We will also be sending emails to our current vendors to ensure that we have a signed affidavit on file. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Scott Bachtell, Supervisor of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 351175

Finding 544665 (2024-004)

Significant Deficiency 2024

Washington County Board of Education

MD

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Education Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 211935 (3/24/2021 - 9/30/2023) Compliance Requirement: ...

Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Education Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 211935 (3/24/2021 - 9/30/2023) Compliance Requirement: Davis-Bacon Act Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we will start recording on a spreadsheet the Contract number and weeks covered for certified payrolls we receive that falls under the Davis-Bacon Act. This spreadsheet will have an approval column and date column to document our monitoring procedures for tracking and audit purposes. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Rob Rollins, Director of Facilities Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 351175

Finding 544634 (2024-003)

Material Weakness 2024

Washington County Board of Education

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Prior Year Finding: Yes Federal Agency: US Department of Education Federal Program: Special Education Grants to States Assistance Listing: 84.027 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 231072 (10/1/2022 - 9/30/2024) Compliance Require...

Prior Year Finding: Yes Federal Agency: US Department of Education Federal Program: Special Education Grants to States Assistance Listing: 84.027 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 231072 (10/1/2022 - 9/30/2024) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Recommendation We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. However, WCPS did adjust our practices during fiscal year 2024 based on guidance from our previous audit firm to add the suspension and debarment affidavit to all new vendor registrations and service contracts. Action taken in response to finding: Effective immediately, the Purchasing Department will review all requisitions that are going against Fund 02 (Restricted Fund) and ensure that the vendor has been checked for suspension/debarment. New vendors are required to sign an affidavit that they have not been suspended or debarred. This check will ensure that old vendors that were in place prior to the FY 2023 finding have been validated against SAM.GOV or have a signed affidavit to ensure they have not been suspended or debarred. We will also be sending emails to our current vendors to ensure that we have a signed affidavit on file. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Scott Bachtell, Supervisor of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 351175

Finding 544467 (2024-005)

Significant Deficiency 2024

Housing Authority of the City of Greensboro

NC

HUD Housing Programs Subrecipient Monitoring Internal Control / Segregation of Duties

2024-005 ALN 14.850 – Public Housing Operating Fund – Special Test - Waiting List The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Execu...

2024-005 ALN 14.850 – Public Housing Operating Fund – Special Test - Waiting List The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2025

View Audit 351142

Finding 544464 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Greensboro

NC

HUD Housing Programs Subrecipient Monitoring Eligibility

2024-001 ALN 14.850 – Public Housing Operating Fund - Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Pr...

2024-001 ALN 14.850 – Public Housing Operating Fund - Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2025

View Audit 351142

Finding 544459 (2024-002)

Significant Deficiency 2024

Community Clinic of Maui, Inc.

HI

Special Tests & Provisions Subrecipient Monitoring Eligibility

Federal Award Findings and Questioned Costs: Finding 2024.002 - Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken Mana...

Federal Award Findings and Questioned Costs: Finding 2024.002 - Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken Management recently migrated their electronic health records from AthenaPractice and Dentrix to EPIC. EPIC is programmed to calculate the sliding fee discount based upon the Family Size and Income that is entered into the system, unlike Dentrix which did not have this capability. In addition, monthly audits are conducted by the Billing Department to ensure that the supporting documentation matches the information entered into EPIC. If there are any question regarding this plan, please e-mail Monique van der Aa at monique@ccmaui.org. Sincerely, Monique van der Aa Chief Financial Officer

View Audit 351137

Finding 544452 (2024-003)

Material Weakness 2024

Ivy Tech Community College of Indiana

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.329

FINDING 2024-003 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ext. 084987 and nstitt@ivytech.edu Views of Responsible Officials: We co...

FINDING 2024-003 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ext. 084987 and nstitt@ivytech.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The college will develop an internal control system to ensure compliance with the requirement related to the TRIO reporting compliance requirement. Anticipated Completion Date: The projected date of completion for the CAP mentioned above is June 30, 2025. The Student Support Services APR process was corrected in April 2024, a query interfacing with Banner to identify errors in the APRs submitted by each campus, was created.

View Audit 351125

Finding 544448 (2024-001)

Significant Deficiency 2024

Ivy Tech Community College of Indiana

IN

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Economic Adjustment Assistance - Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ex...

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Economic Adjustment Assistance - Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ext. 084987 and nstitt@ivytech.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The college will develop an internal control that is documented for the Special Tests and Provisions - Wage Rate Requirement. Anticipated Completion Date: The projected date of completion for the CAP mentioned above is June 30, 2025.

View Audit 351125

Finding 544445 (2024-002)

Significant Deficiency 2024

Rice Lake Housing Authority

WI

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Planned: The Authority will closely monitor all deposits to make sure that the amount of funds on deposit are protected by federal deposit insurance, corporate surety bond, or collateral. Completion Date: June 30, 2025

View Audit 351122

Finding 544437 (2024-005)

Significant Deficiency 2024

City of Portsmouth

OH

Questioned Costs Period of Performance Subrecipient Monitoring § 200.303 § 200.344

Period of Performance Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: NO Action taken in response to finding: Rev...

Period of Performance Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review grant related procedures to ensure all expenditures take place during the grant period. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Crimer, Patrick Fletcher, & Kyera Pope. Planned completion date for corrective action plan: 6/30/25

View Audit 351108 Questioned Costs: $1

Finding 544433 (2024-004)

Significant Deficiency 2024

City of Portsmouth

OH

Questioned Costs Subrecipient Monitoring Significant Deficiency § 200.303

Allowable Activities – Gift Card Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to interna...

Allowable Activities – Gift Card Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to internal controls. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review and evaluate the policies for safeguarding assets and maintaining better records and reconciliation procedures. Name(s) of the contact person(s) responsible for corrective action: Temeka Mayes, Trey Burke Planned completion date for corrective action plan: 6/30/25

View Audit 351108 Questioned Costs: $1

Finding 544429 (2024-003)

Significant Deficiency 2024

City of Portsmouth

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency § 200.303

Allowable Activities – Gift Card Controls Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Explanation of disagreement with audit find...

Allowable Activities – Gift Card Controls Recommendation: We recommend that the City review and evaluate procedures to ensure that the procedures over safeguarding assets, maintenance of records, and reconciliation of activity are consistently performed. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review and evaluate the policies for safeguarding assets and maintaining better records and reconciliation procedures. Name(s) of the contact person(s) responsible for corrective action: Temeka Mayes, Trey Burke Planned completion date for corrective action plan: 6/30/25

View Audit 351108

Finding 544424 (2024-002)

Material Weakness 2024

City of Portsmouth

OH

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

FFATA Reporting Prior Year Finding: 2023-004 Recommendation: We recommend the City establish procedures and internal controls to ensure that all required sub awards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each sub award. Exp...

FFATA Reporting Prior Year Finding: 2023-004 Recommendation: We recommend the City establish procedures and internal controls to ensure that all required sub awards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each sub award. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review City’s policy, procedures, and internal controls to ensure the required sub awards and reported timely and accurately to FSRS. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Crimer, Patrick Fletcher, & Kyera Pope. Planned completion date for corrective action plan: 06/30/25

View Audit 351108

Finding 544420 (2024-002)

Significant Deficiency 2024

City of Oxnard

CA

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting

The City will improve its internal controls by implementing a new policy and procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant reporting, (2) require management and staff to meet monthly to discuss and track federal reporting requirements and r...

The City will improve its internal controls by implementing a new policy and procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant reporting, (2) require management and staff to meet monthly to discuss and track federal reporting requirements and review a listing of subaward agreements and (3) require staff to submit the Cash on Hand Report quarterly and the FFATA Report monthly.

View Audit 351106

Finding 544404 (2024-002)

Material Weakness 2024

Philadelphia Youth Basketball, Inc.

PA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213 § 200.319

Finding No. 2024-002: Procurement – Material Weakness in Internal Control Over Compliance Contact for Corrective Action: Jayson Tischler, Chief Operating Officer The Organization needed to sole source its architectural firm because it was mission-critical on a compressed timeline with the New Mar...

Finding No. 2024-002: Procurement – Material Weakness in Internal Control Over Compliance Contact for Corrective Action: Jayson Tischler, Chief Operating Officer The Organization needed to sole source its architectural firm because it was mission-critical on a compressed timeline with the New Markets Tax Credit financing process. The Organization’s construction owner’s representative firm, D3 Development, LLC, undertook a market review that confirmed fair and reasonable pricing and service for the selected architectural services. The Organization then subsequently received a federal grant after the construction project began, which allowed the Organization to reimburse for architectural expenses. The Organization was able to reimburse through budget approval from HUD for those retroactive expenses, where competitive bidding had not been a requirement for the organization for any existing federal grants or awards. To ensure future compliance with federal procurement requirements, the Organization will revise its procurement policy to require a competitive bidding process, and proper documentation and record keeping of such, for all vendors eligible for reimbursement under federal programs. Additionally, the Organization will include suspension and debarment confirmation through the System for Award Management (SAM) in its procurement policy for all contractors. The Organization believes that these steps outlined above address this corrective action. Expected Completion Date: April 2025

View Audit 351077

Finding 544363 (2024-003)

Significant Deficiency 2024

Ontrack Inc.

OR

Subrecipient Monitoring Reporting Significant Deficiency

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Establish FSRS Reporting Policy and Proced...

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Establish FSRS Reporting Policy and Procedures o The Organization will develop and implement a formal Subaward Reporting Policy to ensure that all first-tier subawards of $30,000 or more are reported in FSRS in compliance with 2 CFR Part 170. 2. Assign Responsibility and Oversight o A specific staff member within the Grants department will be designated as the FSRS Reporting Coordinator and will be responsible for verifying the completeness and accuracy of subaward reporting and for timely submission to FSRS. o A pre-submission review will be conducted by the FSRS Reporting Coordinator to verify that subawards over $30,000 are captured and reported. 3. Implement Internal Controls and Review Checkpoints o All subawards will be reviewed as part of the pre-award and post-award grant workflow to determine FSRS applicability. o A pre-submission review will be conducted by the Grants Compliance Officer to verify that subawards over $30,000 are captured and reported. 4. Monitoring and Audit Trail Documentation o FSRS submissions will be documented and retained in the grant file along with confirmation of submission and reporting screenshots. Anticipated Completion Date September 30, 2025

View Audit 351003

Finding 544359 (2024-002)

Significant Deficiency 2024

New Mexico Coalition Against Domestic Violence

NM

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

To ensure accountability and timely completion, management conducts periodic meetings to review upcoming deadlines and confirm that the departments responsible have completed and submitted the required reports. These meetings serve to reinforce compliance, address any potential delays proactively, a...

To ensure accountability and timely completion, management conducts periodic meetings to review upcoming deadlines and confirm that the departments responsible have completed and submitted the required reports. These meetings serve to reinforce compliance, address any potential delays proactively, and ensure adherence to all reporting obligations.

View Audit 350999

Finding 544350 (2024-002)

None 2024

Voorhees University

SC

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.305

We concur with the recommendation. The one (1) instance of drawdown that exceeded the three day rule for drawdowns was an oversight on the part fo the institution. In addition, we will revise the spreadsheet used to track cumulative program expenditures against drawdowns.

View Audit 350984

Finding 544348 (2024-001)

Significant Deficiency 2024

City of Bell, California

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2024-001 Procurement and Suspension and Debarment – Internal Control over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City Accounting staff (Acc...

Finding 2024-001 Procurement and Suspension and Debarment – Internal Control over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City Accounting staff (Accountant) will access SAM.Gov to check for possible party ineligibility following receipts of an offer or proposal and again, immediately before making the award and keep record of that check with the time stamped for every CIP project that is advertised for bids. In addition, staff will verify that neither the contractor nor any of its key personnel appear on the Federal or State debarment lists. All this documentation then will be compiled in the project file in both hard-copy and electronically. Responsible Person: Director of Finance Expected Implementation Date: July 1, 2025

View Audit 350982

Corrective Action Plans

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