Corrective Action Plans

Finding 375938 (2023-003)

Material Weakness 2023

IA

Allowable Costs / Cost Principles Eligibility Material Weakness § 200.303

Finding 2023-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 4 TIN#237224698 Federal Financial A...

Finding 2023-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 4 TIN#237224698 Federal Financial Assistance Listing Number: 93.498 Finding Summary: Imagine the Possibilities, Inc. final eligible expenditure listing identified as eligible and claimed under the Provider Relief Fund program was not reviewed and approved by a separate individual outside of the preparer. In addition, the Organization’s special report submitted to the Department of Health and Human Services for Period 4 TIN #237224698 was not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. The Organization will review the internal controls and implement improvements related to allowability of all federal cost claimed, including those regarding the identification of duplicate items and approved costs. Anticipated Completion Date: March 31, 2024

View Audit 294998

Finding 375884 (2023-004)

Material Weakness 2023

Northwestern School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-004 Finding Subject: Education Stabilization Wage Rate Requirements Summary of Finding: The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wag...

Finding 2023-004 Finding Subject: Education Stabilization Wage Rate Requirements Summary of Finding: The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling $603,973, was paid for with COVID-19 – Education Stabilization Fund grant funds during the audit period. The contract did not include the required prevailing wage rate clause. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. The corporation acknowledges this error. Description of Corrective Action Plan: The Director of Operations and Director of Finance will work together to ensure wage rate language is in all federal contracts for future projects. Anticipated Completion Date: Immediate

View Audit 294966

Finding 375879 (2023-003)

Material Weakness 2023

Northwestern School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: Education Stabilization Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSERI II reports and two ESSER III reports for a total of six reports. The reports were prepared and submitted by the Director of...

FINDING 2023-003 Finding Subject: Education Stabilization Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSERI II reports and two ESSER III reports for a total of six reports. The reports were prepared and submitted by the Director of Finance without a documented oversight or review process. In addition, four of the six annual data reports were not supported by the School Corporation’s records. The financial information provided did not agree to the data submitted; therefore, we could not determine the accuracy of the annual data reports. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. The submissions referenced without proper documentation were submitted by the previous CFO. The current finance staff is unable to locate any supporting documentation regarding those submissions. There is a reimbursement request internal controls document that was signed by both the CFO and Superintendent, but here is no supporting documentation to accompany it. Description of Corrective Action Plan: The current Director of Finance and finance team have attached all supporting documentation from the financial software to their submissions along with an internal controls document signed by the Director of Finance and Superintendent. The corporation is actively working with the Department of Education to amend when it believes to be some errors in the prior submissions as well. Anticipated Completion Date: August 2024

View Audit 294966

Finding 375874 (2023-002)

Material Weakness 2023

Northwestern School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403 § 200.430

FINDING 2023-002 Finding Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principals Summary of Finding: A portion of the wages for the CFO/Treasurer, the Director of Operations, the Director of Finance, and two School Secretaries were paid from the School Lunch Fund. The...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principals Summary of Finding: A portion of the wages for the CFO/Treasurer, the Director of Operations, the Director of Finance, and two School Secretaries were paid from the School Lunch Fund. The wages charged to the School Lunch fund were based on fixed percentages and did not provide adequate information to determine if the percentage charged was appropriate. Total wages charged to the program for the above noted employees was $31,617. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. There was a substantial amount of turnover within the finance department. It was understood that the mentioned salaries were removed from the 0800 fund following the last audit. During review it was discovered only the Director of Operations and Assistant Treasurer salaries were removed from the child nutrition cluster. Upon discovery the Operations Assistant and Director of Finance were still having a portion of the salary paid from the 0800 fund, they were immediately removed. Description of Corrective Action Plan: The Director of Finance and the Operations Assistant’s salaries have been removed from the 0800 fund and returned to the 0300 fund. Anticipated Completion Date: Immediate and has been completed.

View Audit 294966 Questioned Costs: $1

Finding 375761 (2023-004)

Material Weakness 2023

Penn-Harris-Madison School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403

FINDING 2023-004 Finding Subject: COVID-19 - Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronav...

FINDING 2023-004 Finding Subject: COVID-19 - Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronavirus pandemic, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. Per the School Corporation’s approved application, program funding was budgeted for salaries and respective benefits, counseling services, and supplies. A sample of 40 payroll claims charged to the ESSER program for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable cost principles. Of the 40 payroll claims tested, 21 payroll claims were determined to be for payroll adjustments into the ESSER II fund. For all 21 payroll adjustments, totaling $1,509,248, there was not adequate supporting documentation to determine to where the payroll was originally paid, to whom the original payment was made and at what amount the original payment was made. The total amount of the 21 payroll claims/adjustments, $1,509,248, was determined to be questioned costs. Due to the lack of documentation for the payroll adjustments into the ESSER II fund, all adjustments were reviewed. A review of the additional adjustments resulted in an additional $114,353 of payroll charges in which there was not adequate supporting documentation to determine to where the payroll was originally paid, to whom the original payment was made and at what amount the original payment was made. In addition, the School Corporation requested a total reimbursement of $3,342,940 in payroll costs from their ESSER allocation during the audit period. However, expenditures per the ledger for payroll and benefits totaled $2,995,014. As a result, the School Corporation over requested and received $347,926 for payroll expenditures that cannot be substantiated. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the payroll adjustments and additional payroll noted above. Contact Person Responsible for Corrective Action: Dr. Thomas A. Keeley, Executive Director of Business Services Contact Phone Number and Email Address: (574) 258-9591 Tkeeley@phm.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports, reimbursement requests and payroll processing. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

View Audit 294813 Questioned Costs: $1

Finding 375760 (2023-005)

Material Weakness 2023

Penn-Harris-Madison School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be e...

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were to be prepared and submitted by the School Principal and reviewed by the Executive Business Director; however, no evidence of this review or oversight process could be provided. As such the annual data reports were prepared and submitted to IDOE without an oversight or review process to prevent or detect and correct errors. In addition, five of the six reports submitted during the audit period were not supported by the School Corporation’s records. The following errors were identified:  The ESSER I, Year 2 report, which had an applicable reporting period of October 1, 2020 through June 30, 201, reported $534,761 in expenditures. However, actual expenditures for the applicable reporting period totaled $478,883.  The ESSER 1, Year 3 report which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $243,814.67.  The ESSER II, Year 1 report, which had an applicable reporting period of July 1, 2020 to June 30, 2021, reported $733 in expenditures. However, actual expenditures for the applicable reporting period totaled $322,539.  The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $276,642.  The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,315,208. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports and reimbursement requests. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

View Audit 294813

Finding 375753 (2023-003)

Material Weakness 2023

Penn-Harris-Madison School Corporation

IN

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

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Condition and Context Direct charges to a federal award are to be for allowable costs and made in conformance with the applicable cost principles. Payroll benefits were entered by the payr...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Condition and Context Direct charges to a federal award are to be for allowable costs and made in conformance with the applicable cost principles. Payroll benefits were entered by the payroll department and reviewed by the Payroll Coordinator to ensure proper payment. However, this review was not completed on a detailed level by employee to ensure the payroll withholdings, deductions, and benefits retained from employees’ wages were for allowable costs and made in conformance with applicable cost principles. The lack of internal controls was a systemic issue throughout the audit period. Contact Person Responsible for Corrective Action: Dr. Thomas A. Keeley, Executive Director of Business Services Contact Phone Number and Email Address: (574) 258-9591 Tkeeley@phm.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify tasks and responsibilities for the payroll process. The school corporation will print a detailed employee wage report for each payroll with double signatures indicating a thorough review process by the payroll coordinator and the payroll accounting specialist/Food Service Manager. Finally, the Executive Director for Business Services will complete noting a final review of corresponding benefits withholdings to the corresponding vendor payments indicating the process is complete with an official signature. Anticipated Completion Date: March 1, 2024.

View Audit 294813

Finding 375748 (2023-002)

Material Weakness 2023

Evergreen Local School District

OH

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303 § 200.514

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

View Audit 294809

Finding 375745 (2023-003)

Material Weakness 2023

Kamalani Academy

HI

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

Finding 2023 - 003 Allowable Costs - Native Hawaiian Education – Assistance Listing 84.362A KA concurs with the Recommendation. In conjunction with the search and seating of a permanent School Director (in progress), the Reconstituted Governing Board (“RGB”) as a whole, intends to prioritize the: A)...

Finding 2023 - 003 Allowable Costs - Native Hawaiian Education – Assistance Listing 84.362A KA concurs with the Recommendation. In conjunction with the search and seating of a permanent School Director (in progress), the Reconstituted Governing Board (“RGB”) as a whole, intends to prioritize the: A) Updating and/or creation of policies (that either don’t exist or aren’t documented); B) Cascading policies to related processes and procedures; and C) Training appropriate staff; and D) Monitoring the practices, to ensure the day to day practices are consistent with and aligned to the policies, processes and procedures. Policy Focus: Grant Management (e.g., accounting, reporting, budgeting, compliance, authorized procurement, inventory, federal draws, federal progress report, communication with federal program office, utilization of curriculum, supplies, equipment in compliance with the specific grant). Any questions regarding this response may be directed to Aumoana Kanakaole-Lato, Reconstituted Governing Board Chair at aumoana.kanakaole@kamalaniacademy.org.

View Audit 294807

Finding 375725 (2023-001)

Material Weakness 2023

Herron High School, Inc.

IN

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2023-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2022-001) Material Weakness Recommendation: The Auditor reco...

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2023-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2022-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compliance to review federal award provisions and requirements, evaluate risks of noncompliance, and respond to such risks through internal controls. The process should include methods to identify and communicate changes to federal award requirements to all key individuals within the Organization and to verify internal controls are implemented correctly and are operating effectively. Planned Corrective Action: As the organization has grown, compliance of federal programs has become decentralized. We agree that additional resources need to be added to ensure compliance with all state and federal awards. The Organization has added additional capacity to the Business Office to assume the compliance and reporting responsibilities. Michelle Krauter, the Director of Accounting & Finance, is responsible for ensuring fiscal compliance and will coordinate program compliance activities with the Heads of School at each campus and the Directors of Academic Accountability. Through the monitoring activities conducted by the Indiana Department of Education during 2023, staff gained a better understanding the compliance requirements and are implementing processes to ensure ongoing adherence to the requirements. Evaluation of these processes will continue through 2024. 43

View Audit 294798

Finding 375666 (2023-008)

Material Weakness 2023

City of Fairfield

CA

HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking § 200.303

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Utility Allowance Schedule Type of Finding: Instance of Non‐Co...

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Utility Allowance Schedule Type of Finding: Instance of Non‐Compliance and Material Weakness in Internal Control over Compliance Views of Responsible Officials: The Housing Authority fully complied with 24CFR 982.517(C)(1) of HUD regulations that states that "A PHA must review its schedule of utility allowances each year and must revise its allowance for a utility category if there has been a change of 10 percent or more in the utility rate since the last time the utility allowance schedule was revised. The PHA must maintain information supporting its annual review of utility allowances and any revisions made in its utility allowance schedule." Each year, the Housing Authority hires a consultant to analyze the Utility allowances for the Fairfield jurisdiction. Once that assessment is completed, Housing Authority staff and Management review it. The Housing Authority staff then meets with the Consultant to discuss any irregularities found or resolve questions emanating from its review. Once staff and Management are satisfied with the information, have clear documentation explaining the Consultant's conclusions, and memorialize any categories that have changed 10% or more, Management will finalize its review of the Utility Allowance Schedule. The Housing Authority will document Management’s approval of the utility allowance adjustments, if any. Responsible Individual(s): Tanya Tran, Housing Division Manager LaTanna Jones, Deputy Executive Director Anticipated Completion Date: June 1, 2024

View Audit 294738

Finding 375664 (2023-006)

Material Weakness 2023

City of Fairfield

CA

HUD Housing Programs Internal Control / Segregation of Duties Material Weakness § 200.303

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Contr...

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials: We concur. The Housing Authority addressed this issue when the City was informed in March 2023 there was not enough documentation prior to online grant reporting for the auditors to verify grant reports were reviewed prior to submission on other grants being audited. The Housing Authority has continuously maintained a check and balance approach for preparing and reviewing VMS reports before HUD submission. All reports are prepared by the Housing Authority and finance staff, then reviewed by either the Housing Authority Manager or the Deputy Executive Director before submission to HUD. The reviewer is now documenting their review prior to submitting the VMS reports. Responsible Individual(s): Tanya Tran, Housing Division Manager Anticipated Completion Date: June 30, 2023

View Audit 294738

Finding 375660 (2023-005)

Significant Deficiency 2023

City of Fairfield

CA

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Agency: U.S. Department of Transportation Program/Cluster: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Pass‐through: California Department of Transportation Award No. and Year: STPCML‐5132 (049) – 2022 and HSIPL‐5132 (52) ‐ 2022 Compliance Requirement: Special...

Federal Agency: U.S. Department of Transportation Program/Cluster: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Pass‐through: California Department of Transportation Award No. and Year: STPCML‐5132 (049) – 2022 and HSIPL‐5132 (52) ‐ 2022 Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control over Compliance Views of Responsible Officials and Corrective Action Plan: The Public Works Department does review the certified payroll by management and files it within the project folder yet there was no documented sign off to verify when this review was completed. The City will add an additional step to document the verification of the review by management for future projects. Responsible Individual(s): Roger Dunham, Administration Division Manager Anticipated Completion Date: March 1, 2024

View Audit 294738

Finding 375659 (2023-004)

Material Weakness 2023

City of Fairfield

CA

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

Federal Agency: U.S. Department of Homeland Security Program/Cluster: Staffing for Adequate Fire & Emergency Response Federal Assistance Listing Number: 97.083 Pass‐through: N/A Award No. and Year: EMW‐2020‐FF‐00816, 2020 Compliance Requirement: Reporting Type of Finding: Material Weakness in Intern...

Federal Agency: U.S. Department of Homeland Security Program/Cluster: Staffing for Adequate Fire & Emergency Response Federal Assistance Listing Number: 97.083 Pass‐through: N/A Award No. and Year: EMW‐2020‐FF‐00816, 2020 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials and Corrective Action Plan: The Fire Department has addressed this issue when the City was informed in March 2023 there was not enough documentation prior to online grant reporting for the auditors to verify grant reports were reviewed prior to submission on other grants being audited. The two (2) submissions in question were reviewed and verified by management but were not documented for the auditors to verify when the review was completed, prior to the City being notified in March 2023 to further document the review process. The City has implemented this recommendation. Responsible Individual(s): Taylor Armour, Administration Division Manager Anticipated Completion Date: June 30, 2023

View Audit 294738

Finding 375646 (2023-002)

None 2023

Sessions Village 202 171-Ee015

WA

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Reporting § 200.302 § 200.303

Finding 2023-002: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Sessions Village 202 review their internal controls over the cash...

Finding 2023-002: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Sessions Village 202 review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. Action Taken: The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Sessions Village 202’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward.

View Audit 294725

Finding 375643 (2023-002)

None 2023

Cheney Care Community

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.302 § 200.303

Finding 2023-002: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review...

Finding 2023-002: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. Action Taken: The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Cheney Care Community’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Cheney Care Community will consistently perform the general ledger account coding internal control procedures on invoices going forward.

View Audit 294723

Finding 375629 (2023-001)

Significant Deficiency 2023

Metropolitan Washington Council of Governments, Inc.

DC

Procurement, Suspension & Debarment § 200.214 § 200.303

Views of responsible officials: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract wit...

Views of responsible officials: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors. Name(s) of the contact person(s) responsible for corrective action: Rick Konrad, Facilities and Purchasing Manager Planned completion date for corrective action plan: December 1, 2023

View Audit 294695

Finding 375603 (2023-005)

Material Weakness 2023

Randolph Central School Corporation

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporatio...

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent and reviewed by the Treasurer prior to submission. However, this review process was not effective and did not detect and allow correction of errors prior to submission. All six of the submitted reports were selected for testing. Four of the reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy of the reports. The lack of controls was systematic throughout the audit period. The noncompliance was isolated to the four reports identified above. The auditors recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are supported by the ledgers or reports used to complete the report Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation is required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted includes, but is not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The annual data reports will be complied/prepared by the Treasurer and the Assistant Superintendent to ensure the reports are supported by the corporation’s financial data. The JotForm will be reviewed by the Superintendent prior to submission. Anticipated Completion Date: 2/21/2024

View Audit 294679

Finding 375599 (2023-004)

Material Weakness 2023

Randolph Central School Corporation

IN

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

FINDING 2023-004 Finding Subject: Education Stabilization Fund - COVID-19 - Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to help safely reopen and s...

FINDING 2023-004 Finding Subject: Education Stabilization Fund - COVID-19 - Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to help safely reopen and sustain the safe operation of schools and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ARP ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. To receive reimbursement for ESSER expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Assistant Superintendent reviewed it. The documentation attached to the reimbursement request; however, did not have adequate detail to determine the payroll paid was in conformance with the applicable cost principles. Furthermore, payroll disbursements were posted by the Treasurer without a review to ensure the payee, amount, fund, and disbursement classification was accurate prior to disbursement. The lack of controls was a systemic issue throughout the audit period. The auditors recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Treasurer will prepare a detailed payroll appropriation report each payroll. The Assistant Superintendent will review it to ensure the payee, amount, fund, and disbursement classification are accurate prior to disbursement. After approval, at the end of the month, the Treasurer will complete a reimbursement request and the Assistant Superintendent will review it for accuracy prior to submission. Anticipated Completion Date: 2/21/2024

View Audit 294679

Finding 375592 (2023-003)

Material Weakness 2023

Randolph Central School Corporation

IN

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

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educational Agencies (i.e. the School...

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educational Agencies (i.e. the School Corporation), to assist them in providing special education and related services to eligible children with disabilities ages 3-21. IDEA’s Special Education – Preschool Grants program provides grants to states, and through them to LEAs to assist them in providing special education and related services to children with disabilities ages three to five and, at the state’s discretion, to two-year-old children with disabilities who will turn three during the school year. To receive reimbursement for special education expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Assistant Superintendent reviewed it. The documentation attached to the reimbursement request; however, did not have adequate detail to determine the payroll paid was in conformance with the applicable cost principles. Furthermore, payroll disbursements were posted by the Treasurer without a review to ensure the payee, amount, fund, and disbursement classification was accurate prior to disbursement. The auditors recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Treasurer will prepare a detailed payroll appropriation report each payroll. The Assistant Superintendent will review it to ensure the payee, amount, fund, and disbursement classification are accurate prior to disbursement. After approval, at the end of the month, the Treasurer will complete a reimbursement request and the Assistant Superintendent will review it for accuracy prior to submission. Anticipated Completion Date: 2/21/2024

View Audit 294679

Finding 375587 (2023-002)

Significant Deficiency 2023

Louisiana Delta Service Corps

LA

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.404

Management Response: Management will include others on correspondence regarding approval of payroll, which will help detect when an approval of payroll is not made timely. If payroll is not approved before paid, then Management will perform a documented review to ensure payroll payments are proper. ...

Management Response: Management will include others on correspondence regarding approval of payroll, which will help detect when an approval of payroll is not made timely. If payroll is not approved before paid, then Management will perform a documented review to ensure payroll payments are proper. Management will also develop a policy to stop living allowance payments timely when a member will not meet their service hour obligation. Responsible Person: Lisa Moore, Executive Director Anticipated Remediation Date: Fiscal year ended August 31, 2024

View Audit 294676

Finding 375586 (2023-001)

Material Weakness 2023

Louisiana Delta Service Corps

LA

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Management Response: Due to the size of LDSC’s administrative staff, complete segregation of duties is not economically feasible. However, during the 2023 fiscal year, LDSC created a financial policies handbook that outlines controls and responsibilities in the financial reporting cycle. We will ens...

Management Response: Due to the size of LDSC’s administrative staff, complete segregation of duties is not economically feasible. However, during the 2023 fiscal year, LDSC created a financial policies handbook that outlines controls and responsibilities in the financial reporting cycle. We will ensure the areas recommended above are added to our current policy to the extent it is economically feasible. Responsible Person: Lisa Moore, Executive Director Anticipated Remediation Date: Fiscal year ended August 31, 2024

View Audit 294676

Finding 375558 (2023-007)

Significant Deficiency 2023

Richmond County

NC

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

Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact per...

Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-007 Inadequate Request for Information Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Questioned Costs Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. December 12, 2023 and ongoing. Linda Taylor, DSS Manager December 12, 2023 and ongoing. Electronic verifications discussed with all Medicaid Staff. Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. Linda Taylor, DSS Manager Section III - Federal Award Findings and Questioned Costs (continued) Linda Taylor, DSS Manager A training will be conducted at the end of the Continuous Coverage Unwinding per DHB-Admin. Letter 13-23. This policy is not required to be enforced at this time. We would like to reserve the rights to conduct this training at the is time to prevent confusing employees. Proposed training date to be held at the end of the Continous Coverage Undwinding period. Linda Taylor, DSS Manager Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training date December 12, 2023. December 12, 2023 and on going.

View Audit 294603

Finding 375416 (2023-001)

Significant Deficiency 2023

Community Chest, Inc.

NV

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

Finding Summary: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that p...

Finding Summary: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Quarterly progress reports did not have evidence of review and approval by an individual independent of the preparation process. Responsible Individuals: Erik Schoen, CEO Corrective Action Plan: Management agrees with this finding. We will review our internal data collection process to ensure/reflect that necessary oversight of programmatic reports has occurred. Anticipated Completion Date: June 30, 2024

View Audit 294476

Finding 375402 (2023-003)

Significant Deficiency 2023

Western Wayne School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding 2023-003 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Peggy Huesman Contact Phone Number: 765-478-5375 Views of Responsible Official: We concur with the finding. Description of Corrective Action...

Finding 2023-003 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Peggy Huesman Contact Phone Number: 765-478-5375 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will work with the Maintenance Department to make sure that any contractor paid with Federal Funds has a “Davis Bacon Clause” in their contract. Anticipated Completion Date: April 1, 2024

View Audit 294472

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