Corrective Action Plans

Finding 1205675 (2023-005)

Material Weakness 2023

CO

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303 § 200.403

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2023 AUDITOR FINDING: 2023-005 According to 2 CFR Part 200.403 factors affecting allowability of costs - costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the perfo...

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2023 AUDITOR FINDING: 2023-005 According to 2 CFR Part 200.403 factors affecting allowability of costs - costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) be accorded consistent treatment, (e) be determined in accordance with generally accepted accounting principles, (f) to be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period and (g) be adequately documented. In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Organization did not maintain documentation to support that costs and reimbursement invoices had been approved in accordance with their internal control design. CLIENT PLANNED ACTION: To address the audit finding, we affirm that all reimbursement invoices and cost-related documentation are submitted to a Director-level staff member for review and approval prior to sending. All approved invoices and associated documentation are now stored in a centralized shared drive and onsite file cabinets accessible to relevant finance staff to ensure consistent retention and accessibility for audit and review purposes. These documents will also be accessible within the accounting information system, when organization switches to Sage, which is accessible to all parties that have approval responsibilities. CLIENT RESPONSIBLE PARTY: Cassie Kenney, Director of Accounting COMPLETION DATE: This process started as of June 30, 2024. Documents will be stored within Sage as soon as the switch to this software is effective (tentative July 1st, 2025).

View Audit 397388

Finding 1191619 (2023-006)

Material Weakness 2023

Rutgers, the State University of New Jersey

NJ

Reporting Internal Control / Segregation of Duties § 200.303 § 200.502 § 200.510

2023 006 Other – Inaccurate Reporting of the Schedule of Expenditures of Federal Awards Federal Agency: U.S. Department of Homeland Security - Pass Through – SNJ Office of Emergency Management Program Titles and ALN: Disaster Grants - Public Assistance (Presidentially Declared Disasters) (ALN 97.036...

2023 006 Other – Inaccurate Reporting of the Schedule of Expenditures of Federal Awards Federal Agency: U.S. Department of Homeland Security - Pass Through – SNJ Office of Emergency Management Program Titles and ALN: Disaster Grants - Public Assistance (Presidentially Declared Disasters) (ALN 97.036) Grant Number: Grant #4488 Proj F#2105 and Grant #4614 Proj F#690 Contact Person: Erin Cuomo, Interim Vice President IP&O Business Services; 848-932-4981 Corrective Action: The Office for Research, through its Research Administration leadership in collaboration with Institutional Planning & Operations and University Finance will develop and implement a formal Standard Operating Procedure (SOP) to establish a consistent institutional framework for the administration and oversight of federally funded capital projects, emergency recovery programs, and other non-traditional sponsored funding mechanisms. The SOP will define roles and responsibilities, establish compliance requirements, and standardize processes to ensure alignment with applicable federal regulations and institutional policies The Senior Vice President for Research, the Interim Senior Vice President & Chief Operating Officer, and the University Controller will serve as the responsible executives for oversight, approval and implementation of this SOP. Anticipated Completion Date: Completed

View Audit 395479

Finding 1179879 (2023-004)

Material Weakness 2023

North Homes, Inc.

MN

Cash Management Significant Deficiency Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: There was no evidence retained that the Organization's cash management requests were reviewed a...

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: There was no evidence retained that the Organization's cash management requests were reviewed and approved prior to submission. Corrective Action Plan: The Organization has implemented a process to ensure that formal documentation of review and approval is obtained and retained (i.e. hard copies or email). Responsible Individual: Ashli Glorvigen, CFO Anticipated Completion Date: 12/31/2026

View Audit 392245

Finding 1179788 (2023-010)

Material Weakness 2023

South Bend Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials:...

FINDING 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Required IDOE templates (JotForm) are completed using AS400 budget detail reports and Position Control data, with revisions submitted during the September window to correct classifications and remove ineligible set-aside amounts. Adjustments were made to align ESSER I reporting and to avoid timing discrepancies by using budget detail rather than summary reports. The completed report will be reviewed for accuracy and approved prior to submission. Beginning in fall 2023, the reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Completion Date 6/30/25

View Audit 392186

Finding 1179783 (2023-009)

Material Weakness 2023

South Bend Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403 § 200.430

FINDING 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of...

FINDING 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Payroll Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Vendor Contracts All contracts and MOUs follow a controlled approval process to ensure proper oversight and legal compliance. Once drafted, each agreement is submitted for review, and the Legal Department evaluates any document requiring an Opinion of Counsel or involving a waiver of the Corporation’s or School Board’s legal rights. Legal also maintains electronic copies of all finalized agreements. Contracts may only be approved by the Superintendent or the School Board, and MOUs must first be reviewed and approved by the Superintendent before going to the Board. After all required reviews and approvals are completed, the agreement is formally executed and electronically filed by the Legal Department. All required documentation specified in the contract will be retained, along with all related vendor invoices. Correction Date October 5, 2023 payroll and December 2024 vendor

View Audit 392186

Finding 1179778 (2023-008)

Material Weakness 2023

South Bend Community School Corporation

IN

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

FINDING 2023-008 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of ...

FINDING 2023-008 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Correction Date October 5, 2023

View Audit 392186

Finding 1179773 (2023-007)

Material Weakness 2023

South Bend Community School Corporation

IN

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

FINDING 2023-007 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: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid...

FINDING 2023-007 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: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All enrollment, withdrawal, and transfer documentation is maintained in a centralized and well-organized system. Written notifications, withdrawal/transfer forms, and communications from receiving schools are placed in the student’s file and shared with the Guidance Secretary, Student Management Office, and Data Technician. Documents are uploaded or filed promptly, and the Data Technician conducts weekly reviews to ensure accuracy, completeness, and proper coding. This process keeps records current, supports compliance, and ensures timely updates to student enrollment data, including accurate mobility reporting for state accountability and cohort tracking. Correction Dates April 1, 2026

View Audit 392186

Finding 1179772 (2023-006)

Material Weakness 2023

South Bend Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Offic...

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Beginning in fall 2023, reimbursement requests have included all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a regular basis, the Director of Federal Grants will generate the detailed expenditure report and budget summary. The detailed report will be filtered to capture only the transactions occurring since the previous reimbursement request, making it easy to identify new expenditures. These amounts will be added to the cumulative reimbursement totals. The updated total will then be compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request will be reviewed by the Chief Financial Officer and subsequently submitted to the awarding agency. Correction Date 06/30/2025

View Audit 392186

Finding 1179771 (2023-005)

Material Weakness 2023

South Bend Community School Corporation

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Offi...

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Earmarking All expenditures related to parental involvement are tracked using a designated expenditure code. The required homeless set-aside is monitored using department-level data. The same expenditure code is applied to both the mandatory parental involvement set-aside and any additional parental involvement funds. This allows the district to track the spend-down of the mandatory set-aside and determine how much must be carried over into the next grant year. Schools are expected to use the mandatory set-aside funds first, following a FIFO (first-in, first-out) approach, before accessing any parental involvement funds beyond the required amount. We are actively coordinating with the homeless liaison to ensure that fund balances remain current and transparent to all stakeholders. This collaboration supports more effective planning and helps ensure that the funds are spent down appropriately and on schedule. Correction Date 6/30/2025

View Audit 392186

Finding 1179770 (2023-004)

Material Weakness 2023

South Bend Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.334 § 200.403 § 200.430

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us View...

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. Corrected Date 06/30/2025

View Audit 392186

Finding 1179769 (2023-003)

Material Weakness 2023

South Bend Community School Corporation

IN

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

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsib...

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Activities allowed/Unallowed Title I Payroll Distribution Reports will be reviewed and approved by the Title I Director or Executive Director of Federal Grants to confirm that payroll charges were allowable under the grant. Level of Effort The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Completion Date: October 5, 2023

View Audit 392186

Finding 1179668 (2023-005)

Material Weakness 2023

Lake County

IN

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

FINDING 2023-005 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between T...

FINDING 2023-005 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop and implement a proper system of internal controls and segregation of duties. This will ensure accuracy and correctness of all quarterly P & E Reports in the future. Completion Date: June 2026

View Audit 392081

Finding 1179667 (2023-004)

Material Weakness 2023

Lake County

IN

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

FINDING 2023-004 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between T...

FINDING 2023-004 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Completion Date: June 2026

View Audit 392081

Finding 1179665 (2023-003)

Material Weakness 2023

Lake County

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303 § 200.308 § 200.403

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the f...

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding with reservations on a portion of the Finding. Description of Corrective Action Plan: \ This program is completed and the period of performance is over therefore there is not a need to formally adopt any Corrective Action Plan. The Subrecipient Contractor that administered the program has agreed that this finding was due to their internal error in submitting administration invoices too late to be properly processed and approved by the County. They will be reimbursing the ERA1 fund for the error in the amount of $154,812.56 that will be sent back to the US Treasury. Reservation: The US Treasury required the local grant recipient to prosecute ERA1 fraud activities. There were two fraud cases that were prosecuted by our local attorney. His fees were then deducted from the ERA1 fund as administration costs. The grant recipient should not be penalized for doing as directed to prosecute fraud cases without being able to pay for the services rendered. We do not control the timelines of the local courts nor the responses/actions of the defendants delaying the actions beyond the Period of Performance. Anticipated Completion Date: None, no corrective action plan is necessary.

View Audit 392081

Finding 1179664 (2023-002)

Material Weakness 2023

Lake County

IN

Cash Management Matching / Level of Effort / Earmarking HUD Housing Programs § 200.1 § 200.302 § 200.303

FINDING 2023-002 Finding Subject: CDBG - Entitlement Grants Cluster - Program Income Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding. Descriptio...

FINDING 2023-002 Finding Subject: CDBG - Entitlement Grants Cluster - Program Income Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This same finding was part of the 2022 audit in Finding 2022-003. The department was aware that this same finding would be arising in the 2023 audit again due to multiple year errors of previous staff. The corrective action plan proposed and adopted as part of the Corrective Action Plan for finding 2022-003 is still in force and is working to eliminate such findings in the future. The Lake County Redevelopment Commission adopted Resolution 001-2025 on January 16th, 2025 amending the Policy and Procedures Manual of the Department concerning Program Income (PI) internal controls for proper reporting in the IDIS system to address and correct the finding going forward. Anticipated Completion Date: Done

View Audit 392081

Finding 1179663 (2023-003)

Material Weakness 2023

Legacy Senior Services

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP Rural Distribution) Assistance Listing Number: 93.498 Finding Summary: The Organization’s special reports submitted to the Department of Health and Human Services (H...

Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP Rural Distribution) Assistance Listing Number: 93.498 Finding Summary: The Organization’s special reports submitted to the Department of Health and Human Services (HHS) for Period 5 were not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Stephanie Schmidt Corrective Action Plan: Before future reports are submitted to the federal agency, documented approval of this submission will be acquired. Anticipated Completion Date: January 2025

View Audit 392080

Finding 1179585 (2023-003)

Material Weakness 2023

Huerfano County

CO

Reporting § 200.303 § 200.502 § 200.510

Recommendation: We recommend the County implement a countywide system to allow for a more automated system of tracking federal expenditures, that may include updated processes to be developed to set up new organization codes which would require grant managers to provide the required information need...

Recommendation: We recommend the County implement a countywide system to allow for a more automated system of tracking federal expenditures, that may include updated processes to be developed to set up new organization codes which would require grant managers to provide the required information needed for accurate SEFA preparation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has implemented new process to ensure accurate preparation of their SEFA’s.

View Audit 391977

Finding 1179209 (2023-001)

Material Weakness 2023

Food Bank of Delaware, Inc.

DE

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.510

Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. The omission resulted from incomplete grant tracking repor...

Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. The omission resulted from incomplete grant tracking reports not reconciled to the general ledger and grant agreements; absence of an independent secondary review; and procedures that did not fully capture pass-through and subrecipient activity. Objective Design and implement effective internal controls to ensure the SEFA is complete, accurate, and in compliance with 2 CFR §200.510(b) and §200.303; prevent recurrence of material omissions; and sustain readiness for Single Audit reporting. 1. Comprehensive Reconciliation Process Implement a standardized monthly and year-end reconciliation that ties federal award expenditures (including drawdowns and indirect costs) to the general ledger, award agreements/portals, and program manager reports. Create a SEFA Reconciliation Workbook with crosswalks by ALN, passthrough entity, award number, program, and period of performance. 2. Federal Awards Inventory & Certification Maintain a centralized Federal Awards Inventory listing all awards by ALN, award number, passthrough entity, and funding stream. Require annual certifications from responsible leadership team members confirming completeness and accuracy of reported expenditures and period-of-performance coverage. 3. Formal Review Workflow (Independent of Preparer) Establish a documented two-tier review: (1) VP of Finance prepares SEFA and reconciliation; (2) Leadership Team Members perform independent reviews using a SEFA Checklist covering ALNs, pass-throughs, subrecipient disclosures, notes (basis, indirect cost rate), and period-of-performance matching. Evidence the review via dated sign-offs. 4. Subrecipient & Pass-through Controls The VP of Finance create procedures to identify all pass-through and subrecipient transactions. Maintain subrecipient listings with amounts passed through and ensure required disclosures (ALN, pass-through numbers) are captured in SEFA. Reconcile subrecipient agreements and payment registers to SEFA. Leadership Team Members perform independent reviews for accuracy and completeness. 5. Close Calendar & Training Adopt an annual SEFA close calendar with milestones (pre-close, interim, final). Provide annual training for finance and program staff on Uniform Guidance reporting requirements and the SEFA Checklist; include updates to OMB Compliance Supplement as applicable. 6. Monitoring & Continuous Improvement Quarterly CAP monitoring by VP of Finance with status reports to the Finance Committee. Track metrics (e.g., % variance between GL and SEFA, number of checklist exceptions) and remediate promptly. Conduct a pre-audit SEFA "dry run" at least 60 days before year-end close. Roles & Responsibilities • VP of Finance: CAP owner; oversight, quarterly monitoring, reports to Finance Committee, designs reconciliation and review workflow; ensures adherence to checklist and certifications; prepares SEFA, reconciliation workbook, and supporting schedules. • Responsible Leadership Team Member/Program Managers: Certify award activity and completeness; provide supporting documentation. Timeline & Milestones Immediate (within 30 days): Approve CAP; establish Federal Awards Inventory template; draft SEFA Checklist; schedule training. Short term (within 60-90 days): Implement monthly reconciliation; obtain program certifications; pilot independent review on QI data. By next year-end close: Execute full close calendar; complete pre-audit SEFA dry run; document reviewer sign-offs; present monitoring results to Finance Committee. Compliance References • 2 CFR §200.510(h): SEFA preparation requirements (completeness, ALN, pass-through, etc.). • 2 CFR §200.303: Internal controls over federal awards. Management Statement (for 2 CFR §200.511(c) submission) Management agrees with the finding and has initiated the corrective actions described herein. The CAP will be monitored quarterly by the VP of Finance, with status updates provided to those charged with governance until all actions are fully implemented and operating effectively.

View Audit 391575

Finding 1175577 (2023-004)

Material Weakness 2023

Colfax County

NM

Cash Management Period of Performance Reporting § 200.302 § 200.303

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. Cou...

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. County Manager and Financial Specialist were not trained in Railroad project management. Changes in staff within the County Manager’s Office and private corporations as well as state and federal agencies resulted in change in requirements, poor communication, and delay in reporting ultimately resulting in disruption of reimbursement to the County. Colfax County worked with NM Department of Transportation and Federal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County.

View Audit 389365

Finding 1175576 (2023-003)

Material Weakness 2023

Colfax County

NM

Cash Management § 200.303

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. Cou...

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. County Manager and Financial Specialist were not trained in Railroad project management. Changes in staff within the County Manager’s Office and private corporations as well as state and federal agencies resulted in change in requirements, poor communication, and delay in reporting ultimately resulting in disruption of reimbursement to the County. Colfax County worked with NM Department of Transportation and Federal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County.

View Audit 389365

Finding 1175228 (2023-006)

Material Weakness 2023

Oregon Coast Community Action

AL

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.404 § 200.405 § 200.430

Item 2023-006 Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services (Repeat 2022- 008) Federal Grant/Contract Number: 10CH011215-03-03; 10CH011215-03 C3; 10CH011215-04; 10HE000901-01-C6 Grant period – 2022 & 2023 The HS progra...

Item 2023-006 Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services (Repeat 2022- 008) Federal Grant/Contract Number: 10CH011215-03-03; 10CH011215-03 C3; 10CH011215-04; 10HE000901-01-C6 Grant period – 2022 & 2023 The HS program has established an internal process of requester/approver in place to review transaction requested. Documents then get reviewed again by HR or Finance staff based on the transaction type before getting processed.

View Audit 388923

Finding 1174692 (2023-006)

Material Weakness 2023

City of Woonsocket

RI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303

Reference Number: 2023-006 Finding: Improve Segregation of Duties over Expenditure Approvals Name of Contact Person: Christine Chamberland Corrective Active Plan: The City will establish formal procedures to ensure that the responsibilities for approving purchase orders and invoices are assigned to ...

Reference Number: 2023-006 Finding: Improve Segregation of Duties over Expenditure Approvals Name of Contact Person: Christine Chamberland Corrective Active Plan: The City will establish formal procedures to ensure that the responsibilities for approving purchase orders and invoices are assigned to different individuals, thereby maintaining effective segregation of duties. In instances where staffing limitations make segregation impractical, management will implement compensating controls, including independent review and approval of these transactions. Documentation of all reviews and approvals will be maintained for audit purposes. Training will be provided to relevant staff to ensure understanding and compliance with these procedures. Proposed Completion Date: 6/30/26

View Audit 388245

Finding 1174132 (2023-003)

Material Weakness 2023

Norman County

MN

Cash Management Reporting Significant Deficiency § 200.303

Finding Number: 2023-003 Finding Title: Reporting Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Taylor Spilde Corrective Action Planned: Taylor has been receiving supporting documents and reports since 1/1/2024. Taylor received notification sinc...

Finding Number: 2023-003 Finding Title: Reporting Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Taylor Spilde Corrective Action Planned: Taylor has been receiving supporting documents and reports since 1/1/2024. Taylor received notification since 2024 and has been reporting since receiving notification. Anticipated Completion Date: 1/1/2024

View Audit 387778

Finding 1174131 (2023-002)

Material Weakness 2023

Norman County

MN

Eligibility Significant Deficiency Internal Control / Segregation of Duties § 200.303

Finding Number: 2023-002 Finding Title: Eligibility - MAXIS Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Teri Taylor Corrective Action Planned: Implementation of quarterly internal auditing of cases Annual Public Assistance Program review/train...

Finding Number: 2023-002 Finding Title: Eligibility - MAXIS Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Teri Taylor Corrective Action Planned: Implementation of quarterly internal auditing of cases Annual Public Assistance Program review/trainings for staff Anticipated Completion Date: Quarterly internal audits anticipated start date: April 2026 Anticipated completion date of ongoing program training: July 2026

View Audit 387778

Finding 1173373 (2023-006)

Material Weakness 2023

Jackson County

OH

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The new VIP processing system and accompanying spreadsheet is now used to complete a more thorough list for the Board for approval.

View Audit 387032

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