Corrective Action Plans

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2025-004: Equipment Management U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-E...
2025-004: Equipment Management U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award years 2023-2025 Criteria: The Uniform Guidance (2CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number of other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: During the fiscal year 2024 audit, it was previously reported that the District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, nor had it performed the required physical inventory of equipment within the two previous years. During fiscal year 2025, the District incorporated processes and controls over equipment management that met the property record requirements. The District also performed a physical inventory during fiscal year 2025 that included counting and reconciling approximately half of the District’s equipment and property within this grant program. Therefore, the District had not yet met the requirements of performing a physical inventory of all equipment and property within the previous two years. Cause: Given the timing of when the District incorporated its processes and controls, insufficient time remained to perform a physical inventory of all the District’s equipment and property within this grant program, and only approximately half of the items were subject to the physical inventory. Effect or potential effect: The District is not in compliance with federal grant requirements over the physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: As noted above, the District updated its property records for all its property and equipment, and then approximately half of the District’s property and equipment was subject to a physical inventory. Identification as a repeat finding, if applicable: 2024-004 and 2024-006. Recommendation: We recommend the District continue to perform the processes and controls it added during fiscal year 2025, and complete the inventory count for the remaining items, to be compliance with the federal grant 2 year cycle. View of responsible officials: Management agrees with this finding. Corrective Action: Management plans to continue to keep detailed records and perform physical inventories in accordance with 2 CFR section 200.313(d)(2). Anticipated Completion Date: June 30, 2026 Contact Person: Dominic Accurso, Controller 816-321-5000 Dominic.accurso@nkcschools.org
Special Programs for the Aging-Title III, Part C-Nutrition Services – Assistance Listing No. 93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There ...
Special Programs for the Aging-Title III, Part C-Nutrition Services – Assistance Listing No. 93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program leadership will review and retrain staff of the volunteer hour log requirements, including signatures, matching of hours to digital logs, properly documentation of updates made, and retention of documentation. Program leadership will conduct reviews of documentation for all their locations on a frequent basis to address any deficiencies and address as needed. Finally, administrative staff will conduct rotating reviews of site documentation as a secondary verification. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson Planned completion date for corrective action plan: 02/28/2026
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: T...
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the spring of 2025, Clarkson College made the decision to outsource majority of financial aid functions to the Higher Education Assistance Group (HEAG) due to a lack of internal controls. Since hiring HEAG in Spring 2025 to oversee our financial aid functions, Clarkson College has seen many improvements in our internal controls. Reconciliation of Direct Loans and Federal Pell Grant funds is conducted monthly by a designated Financial Aid staff member. Following completion, the reconciliation documentation is forwarded to the College Controller for independent review. Final approval is provided by the Vice President of Enrollment and Advising. A standing monthly meeting is also held between the Financial Aid and Finance teams to review reconciliation activity, address variances, and resolve any items requiring clarification. The Federal Work-Study (FWS) program is monitored and reviewed each pay period to ensure expenditures remain within authorized limits and align with student eligibility. Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS) funds are reviewed and reconciled periodically throughout each semester by a Financial Aid staff member. Upon completion of these reconciliations, supporting documentation is submitted to the College Controller for review and verification of accuracy. These procedures ensure compliance with federal regulations, promote internal control integrity, and provide appropriate oversight of all Title IV funding streams. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented Spring semester of FY 2025.
Context and Cause – During the year ended June 30, 2025, OMEP entered into four first-tier subawards greater than $30,000 under AL number 11.611. The auditor tested one of these subawards, noting that the award was not yet reported under the Federal Funding Accountability and Transparency Act to the...
Context and Cause – During the year ended June 30, 2025, OMEP entered into four first-tier subawards greater than $30,000 under AL number 11.611. The auditor tested one of these subawards, noting that the award was not yet reported under the Federal Funding Accountability and Transparency Act to the Federal Subaward Reporting System (FSRS). Per further inquiry, all of the first-tier subawards were yet to be reported to the FSRS. OMEP was aware of the FFATA reporting requirements, but the reporting was not made timely. Internal controls were not adequately designed, and procedures were not in place to track and report first-tier subawards within the time frame required by federal requirements. Recommendation – The Organization should establish written policies and procedures for reporting first-tier subawards. Action Taken: OMEP will add a fiscal policy, that includes a documented review of first tier subawards, to ensure they are input to the FSRS no later than the last day of month that follows the initial obligation to the sub awardee. Responsible parties: Controller. Anticipated completion date: June 30, 2026.
FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity...
FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs - Cost Principles Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs - Cost Principles compliance requirements. Context: During testing payroll disbursements charged to CNC grants, we noted: One selection in a sample of 40 for which the employee was paid above their contracted hourly rate. One selection in a sample of 40 for which the contract sheet for fiscal year 2025 did not include an accurate breakdown for cafeteria employees employed for less than one year and employees employed more than one year. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure controls surrounding salary/hour rate schedules are implemented/enhanced and that rate changes are properly reviewed when instituted. Responsible Party and Timeline for Completion: Betty Huddleston, July 1, 2026
Management agrees with the finding. The Health System has implemented the policy titled, Alameda Health System Reports Policies – SUD Program, to ensure program earmarking requirements and proper documentation is retained to evidence fulfilled requirements. Management will continue to refine interna...
Management agrees with the finding. The Health System has implemented the policy titled, Alameda Health System Reports Policies – SUD Program, to ensure program earmarking requirements and proper documentation is retained to evidence fulfilled requirements. Management will continue to refine internal data collection processes to sufficiently monitor earmarking requirements.
Management agrees with the finding. The Health System has implemented the policy and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation is maintained by the program to evidence preparation and review processes and timely filin...
Management agrees with the finding. The Health System has implemented the policy and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation is maintained by the program to evidence preparation and review processes and timely filing of the annual report. Management will continue to refine internal processes to ensure quarterly and annual reports are filed timely.
FINDING 2025-004 Finding Subject: Child Nutrition Cluster-Reporting Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street, Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Co...
FINDING 2025-004 Finding Subject: Child Nutrition Cluster-Reporting Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street, Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-004. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the monthly reimbursement claim process for the audit period. Corrective Action: Internal Controls regarding the monthly reimbursement claim process will be implemented to be completed each month. The High School Kitchen Manager, along with the Food Service Director, will review the sale reports, attendance factor, and edit checks to calculate the total claim count for each federal program. The Manager and Food Service Director will approve and sign the total meal counts to claim prior to entering data into the CNP website. Anticipated Completion Date: January 31, 2026.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster-Suspension and Debarment Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street. Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: ...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster-Suspension and Debarment Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street. Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-003. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Corrective Action: Internal Controls regarding Procurement and Suspension and Debarment will be implemented to maintain reasonable assurance of compliance with the Procurement and Suspension and Debarment by requiring the Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Form as part of the procurement process. Once returned with the RFQ/RFP (request for quote or proposal), the Food Service Director will review with the Business Manager for approval, including both signatures. Additionally, the Business Manager will look up all vendors on the pre-approved Suspension and Debarment vendor website, and those results will be shared with the Food Service Director before the procurement process. All completed forms will be filed with the Business Manager. In addition, CN Director will provide a template letter to the vendor stating that they have not been suspended or debarred from procurement with federal entities. Vendor will be asked to sign the letter and return to the Food Service Director to keep on file at Mississinewa Community Schools. Anticipated Completion Date: January 23, 2026.
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the ...
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our procurement for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to use our procurement process following our school board policies. NISEC has reported that for the 2023-2024 school year the corrective action plan was initiated by the below process. As a member of the Northwest Indiana Special Education Cooperative (NISEC), the School Corporation usually expends contracted services out of our general education fund. For the fiscal year of 2023-2024 we included our contracted speech services into our federal grant funds. During the audit the School Corporation was notified that we didn’t following the procurement procedures when expending out of the federal grant. This finding was due to the School Corporation not going out and receiving multiple bids for contracted companies that provide services to our students. The School Corporation uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding and discussing with the auditor we created a memo that we took to our board. In the memo we explain why we use the three contracted vendors instead of going out for bids. Finding Speech pathologist and Assistant are very difficult in the school setting and we have created great working relationships with these three contracted companies. Within the memo we list all of the contracted vendors we use and why we work directly with them instead of going out for bids. At the beginning of each school year we will take a new memo with any contracted companies that we will be using during the school year. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 31 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us Anticipated Completion Date: The Northwest Indiana Special Education Cooperative created the memo as soon as we received the finding and took the memo to the board. We have procedures in place now that any vendor that will exceed the simplified acquisition threshold, we will obtain bids or create a memo if bids are not an option. We took the memo to our October 9,2024 board. This was completed fully as of July 1, 2024. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate"
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the a...
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our earmarking for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to track time and effort logs for individuals servicing our non-public students with disabilities. These are housed in the special education office located at Pierce Middle School. Since staff are performing special education duties only, reports are logged semiannually. NISEC has reported that for the 2023-2024 school year the corrective action plan was implemented fully. Anticipated Completion Date: This was completed fully as of July 1, 2024.
FINDING 2025-001 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card/High School Graduation Rate Contact Person Responsible for Corrective Action: Mike Krutz Contact Phone Number and Email Address: 219-650-5300 x5370, mkrutz@mvsc.k12.in.u...
FINDING 2025-001 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card/High School Graduation Rate Contact Person Responsible for Corrective Action: Mike Krutz Contact Phone Number and Email Address: 219-650-5300 x5370, mkrutz@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our processes for the future. Description of Corrective Action Plan: The High School Staff implemented procedures to ensure adequate documentation is received to support a student’s removal/withdrawal from a cohort. The Student Withdrawal Report Form has been updated to include the most current State Withdrawal Codes as well as a high school administrator’s signature for approval. The procedures for removal/withdrawal from a cohort are as follows: 1. The student and/or parent complete the Withdrawal Report Form with the assistance of the attendance secretary. The Withdrawal Checklist Form is started and initialed by the attendance secretary. 2. The student and/or parent meet with an administrator or designee to review the Withdrawal Report Form and complete the Exit Interview Form. The Checklist Form is initialed by administrator or designee signifying completion of this step. 3. The attendance secretary scans the forms into the current student management system. The Checklist Form is initialed by the attendance secretary signifying completion of this step. 4. The original forms are hand delivered to the Registrar who then completes transfer requests and verifications to receiving schools. The Checklist Form is initialed by the Registrar signifying completion of this step. 5. The Registrar upon receiving the original documents hand delivers the Checklist Form to an administrator who reviews and signs the form approving the withdrawal. 6. The original documents are filed in the student’s permanent record folder. 7. Cohorts are reviewed after each trimester by grade level administration and cross referenced with the student management system to check for anomalies. Grade level administration will report their findings to the head principal or designee. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 28 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us If a student stops attending school and the student/parent does not come in to complete the process, the following procedures are followed: 1. The guidance office secretary attempts (and documents attempts) to contact the parent via phone calls, emails (with read receipt), and certified letters. All paperwork is printed and put in the student file. 2. The guidance office secretary searches the Education ID Portal site to determine if the student is attending another high school. 3. Continual effort is made to contact the parents by the guidance secretary or grade level dean. 4. Once the parent is reached, the above procedures are followed (see step1-7 above). 5. After 3 methods of contact are made (call, email, certified letter), the Student Withdrawal Report is completed and signed by an administrator and withdrawal codes 14 (Unknown/No Show 18+) or 15 (Truancy-Underage No Show) are used. 6. When the school is unable to get in contact with the parent, reports are made to DCS, Merrillville Truancy Court, and the updated procedures for Missing Students/Unknown Location are to be initiated immediately. Additional Step to Corrective Action Plan: We are establishing an annual internal audit, to be completed by central office staff, to ensure that all procedures related to the removal or withdrawal of individuals from a cohort are consistently and properly followed. The internal audit will consist of 10-15 randomly selected withdrawn student’s records. This audit will review documentation, decision-making processes, and compliance with established guidelines to confirm alignment with policy and regulatory requirements. The goal is to promote accountability, maintain program integrity, and identify any areas for improvement or need for additional training. Anticipated Completion Date: June 15, 2026
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and...
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as ...
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-...
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-023- PN01 , 25611-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Suspension and Debarment Audit Findings: Significant Deficiency Condition: An effective system of internal controls was not in place at the School Corporation to ensure the HamiltonBoone- Madison Special Education Cooperative's compliance with applicable requirements related to the Special Education Cluster (IDEA), specifically with respect to Suspension and Debarment requirements. No instances of noncompliance (entering a contract with a vendor that was suspended or debarred) were identified in the transactions selected for testing. The matter represents a deficiency in internal controls over the Suspension and Debarment process, rather than identified noncompliance with program requirements. Context: Suspension and Debarment As part of its internal control procedures, the Cooperative utilizes the System for Award Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. This verification process is designed to ensure that vendors are not suspended, debarred, or otherwise excluded from participation in federal programs, in accordance with applicable procurement regulations. Three covered transactions that equaled or exceeded $25,000 were identified. Of the three transactions, all were selected for testing, totaling $141,578. The Cooperative did not verify the vendors' suspension and debarment status prior to payment for two of the three covered transactions. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will enhance oversight of the Hamilton-Boone-Madison Special Education Cooperative's procurement process to ensure all applicable procurement steps, including suspension and debarment checks, are completed and follow federal regulations for the program, prior to entering into a contract with the respective vendor. Responsible Party and Timeline for Completion: David Hortemiller, CFO and Susan Wilson, Director of Finance met with Steven Wornhoff, Director of HBM Cooperative and Kim Kuersteiner, HBM Technology Manager to establish a process to review all vendors for suspension and debarment. Training was provided in regard to the Sam.gov website. Since August 2024, the Hamilton-Boone-Madison Special Services Cooperative (the Cooperative) has used the System for Awards Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. The Cooperative will continue to use this process for any transaction equaling or exceeding $25,000. Documentation of the verification process will be retained by the Cooperative.
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding an...
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action. (b) Action taken - The Authority will strengthen internal controls and training of staff to ensure compliance deadlines are met and immediately obtain the missing leases. (c) Planned implementation date - The Authority expects to complete the corrective actions by June 30, 2026.
FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Ide...
FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: During the testing of claim reimbursements, we noted that monthly reimbursements are prepared and reconciled by Food Service Director. The reimbursements are reviewed informally by the Treasurer but this review is not formally documented and therefore, auditable evidence of the review was not available. The lack of formal, documented review existed throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Management will implement a formal, documented review of the monthly reimbursement claims submitted by the Food Service Director prior to submission to the State. Responsible Party and Timeline for Completion: The Food Service Director will prepare and reconcile monthly claims. The FSD will forward to the cafeteria supervisor for review. Both the FSD and cafeteria supervisor will sign off before being submitted to the state for reimbursement. This measure has already been implemented beginning with the November 2025 claim submitted in January 2026.
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment ...
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment with existing practices. The finalized policies will be presented for Board approval and implemented by March 18, 2026, and responsibility for ongoing monitoring and periodic review has been assigned to the Chief Financial Officer and Director of Administration to ensure continued compliance. Training will be provided to applicable staff, and compliance with the updated policies will be incorporated into management’s periodic internal reviews.
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are los...
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediatel...
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Desc...
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Although the Education Stabilization Fund projects have been completed, the School Corporation will implement procedures to ensure compliance with Davis Bacon and wage rate requirements for all future federally funded grants that have this stipulation. Anticipated Completion Date: Immediately (February 1, 2026)
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