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FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Descript...
FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has joined the Clinton County Joint Services. The Director will provide the numbers for the proportionate share, and retain the documentation. The Corporation Treasurer will establish specific codes to track nonpublic proportionate share expenses, to ensure expenditures are clearly identifiable and readily reportable. Anticipated Completion Date: September 2026, we do not currently have any proportionate shares, but will with the next grant cycle.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Cor...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The FSD will enter the required information into CNPweb. Once entered, she will forward a screen shot of the information entered and the student meal count from Skyward to the Corporation Treasurer. The Treasurer will review the information and sign off through email to the FSD, who will then submit the claim to the State for reimbursement. Anticipated Completion Date: June 2026
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the ...
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of C...
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a documented secondary review, the FSD will print a before and after report from Skyward, and the direct certification download. The MS/HS ECA Treasurer will review the reports, verify Skyward, and sign off on the reports for the second check. The FSD and MS/HS ECA Treasurer will receive annual compliance training. Anticipated Completion Date: June 2026
FINDING 2025-008 Finding Subject: Special Education Cluster (IDEA) – Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 – Special Education Grants to States, Special Education Preschool Grants, COVID-19 – Speci...
FINDING 2025-008 Finding Subject: Special Education Cluster (IDEA) – Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 – Special Education Grants to States, Special Education Preschool Grants, COVID-19 – Special Education Preschool Grants CFDA Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-113-PN01, 22611-113-PN01, 23611-113-PN01, 24611-113-PN01, 86203, H027X210084, 23619-113-PN01, 24619-113-PN01, 25619-113-PN01, 22619-131-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Summary of Finding: Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semi-annually. The data reported included the School Corporation’s expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. The School Corporation did not have an oversight process in place to ensure that expenditures for vendors were posted to the correct fund, account, and object codes. During review of the expenditures, it was determined that there was not a documented second review in place for all vendor payments being made. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. 54 INDIANA STATE BOARD OF ACCOUNTS 54 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Description of Corrective Action Plan: The Treasurer will prepare the Form 9 data and review for accuracy. The Special Education Director and/or Special Education Assistant will review the data for accuracy with respect to the special education expenditures recorded during the Form 9 period to ensure that an accurate Maintenance of Effort can be calculated by DOE following Form 9 submission. The Treasurer will not submit the Form 9 until the secondary review of the data has been completed. The review of the data will be documented via the internal sign-off form created by the School Corporation. The Treasurer will continue to prepare vendor claims; however a second School Corporation employee will review the vendor claims prior to posting to ensure accuracy of the fund, account and object code used for each disbursement as well as the amount of each claim. The reviewer will indicate review has been completed by their signature/initials on the claim form. The vendor claims will not be posted until the secondary review has been completed. Anticipated Completion Date: The planned corrective action for the vendor claims will be implemented in March of 2026. The planned corrective action for the Form 9 data will be implemented in July of 2026.
FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or O...
FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Assessment System Security Audit Findings: Material Weakness, Other Matters Summary of Finding: State educational agencies (SEA), in consultation with local educational agencies (LEA), are required to establish and maintain an assessment security system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security measures and ensure that LEAs implement those policies and procedures. As such, the Indiana Department of Education created and published the Indiana Assessments Policy Manual. As a part of the assessment security, any individual who administers, handles, or has access to secure test materials at the school or school corporation shall complete assessment training and sign a testing security and integrity statement that remains on file in the appropriate building-level office each year. Each individual required to sign the testing integrity agreement shall sign the form by an established date. The School Corporation had a process to provide assessment system security training and to ensure each employee that attended training signed the agreement indicating training was received. However, there was no process in place to ensure that all school employees required to be trained were trained. Contact Person Responsible for Corrective Action: Dr. Rashella Wilfong, Assistant Superintendent / Director of Curriculum and Instruction Contact Phone Number and Email Address: 574-457-3188 x 1901, swilfong@wawasee.k12.in.us 52 INDIANA STATE BOARD OF ACCOUNTS 52 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Assistant Superintendent will continue to assign the appropriate training modules to School Corporation employees. The Assistant Superintendent will ensure that employees have completed their required training prior to the due date and will retain documentation of the completion. The Superintendent will perform a secondary review of the training log to verify that employees have completed their required training by the due date and the secondary review will be documented with the internal sign-off form created by the School Corporation. Anticipated Completion Date: The planned corrective action will be implemented in March of 2026.
FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Nu...
FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Summary of Finding: The School Corporation is required to report graduation rate data for its public high school using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. The School Corporation did not have effective internal controls to ensure required documentation to support the reason for a student’s removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. Although one person updated the reason for a student’s removal in the Student Information System, and another reviewed the documentation and approved the reason, the control was not sufficient to ensure compliance. Of the seven students tested, the School Corporation provided incorrect supporting documentation to substantiate the removal of two students from the cohort. Contact Person Responsible for Corrective Action: Karissa Stoffel, Student Information Specialist Contact Phone Number and Email Address: 574-457-3188 x 1902, kstoffel@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. 50 INDIANA STATE BOARD OF ACCOUNTS 50 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Description of Corrective Action Plan: The School Corporation has created a position for a Student Information Specialist. The Student Information Specialist will serve as the primary employee responsible for entering and maintaining student data within the student management software system. The Student Information Specialist will gather and review the documentation required for removal of a student from the cohort prior to entering that removal in the student management software. The Student Information Specialist will have the Superintendent and/or Assistant Superintendent review the documentation and software data for accuracy. The reviews will be documented with the internal sign-off form created by the School Corporation. Only after both reviews have been conducted will the Student Information Specialist remove the student from the high school graduation cohort. All documentation will be retained by the School Corporation. Anticipated Completion Date: The planned corrective action will be implemented in March of 2026.
FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, ...
FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility, Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Summary of Finding: This is a repeat finding for controls only from the immediately prior audit report. The prior audit finding numbers were 2023-007 and 2023-008. Eligibility Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education’s (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. The counts that are pre-populated should be based on the School Corporation’s records as of October of the prior fiscal year. There was no documented review by the School Corporation of the enrollment and poverty counts that were pre-populated into the School Corporation’s Title I grant application. Level of Effort – Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semi-annually. The data reported included the School Corporation’s expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. The School Corporation did not have an oversight process in place to ensure that expenditures for vendors were posted to the correct fund, account, and object codes. During review of expenditures, 48 INDIANA STATE BOARD OF ACCOUNTS 48 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation it was determined that there was not a documented second review in place for all vendor payments being made. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: Eligibility The Enrollment and Poverty numbers on the Indiana Department of Education’s (IDOE) Official Pupil Enrollment (PE) count for each school will be reviewed by the Assistant Superintendent and/or the Grant Coordinator for accuracy. Depending on who performs the initial review, either the Assistant Superintendent, Grant Coordinator and/or Treasurer will perform a secondary review of the enrollment and poverty numbers on the PE count for accuracy. The reviews will be documented using the internal sign-off form created by the School Corporation. This will ensure accuracy of the data prior to it being pre-populated into the Title I application. Level of Effort – Individual Transactions (Vendor) The Treasurer will prepare the Form 9 data and review for accuracy. The Assistant Superintendent and/or Grant Coordinator will review the data for accuracy. The Treasurer will not submit the Form 9 until the secondary review of the data has been completed. The review of the data will be documented via the internal sign-off form created by the School Corporation. The Treasurer will continue to prepare vendor claims; however a second School Corporation employee will review the vendor claims prior to posting to ensure accuracy of the fund, account and object code used for each disbursement as well as the amount of each claim. The reviewer will indicate review has been completed by their signature/initials on the claim form. The vendor claims will not be posted until the secondary review has been completed. Anticipated Completion Date: The planned corrective action for the vendor claims will be implemented in March of 2026. The planned corrective action for the Form 9 data will be implemented in July of 2026. The planned corrective action for the Pupil Enrollment Report data will be implemented in September of 2026.
FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Number...
FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension & Debarment Audit Findings: Significant Deficiency Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. The School Corporation verifies through review of the SAM exclusions each time they begin doing business with a new vendor. However, a second individual does not verify the website has been reviewed. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Treasurer will review the SAM exclusion data for each vendor before setting up the vendor information in the accounting software. The review will be indicated by printing the SAM exclusion data and attaching the printout to the vendor W-9 kept on file in the Treasurer’s office. The Treasurer will indicate their review of the exclusion data by their signature/initials on the printout and a secondary employee will review and sign/initial as well to document the second review. Additionally, at the start of each calendar year the Treasurer will review the SAM exclusion data prior to processing any vendor claim to a vendor for that calendar year. The annual exclusion review will be documented by the Treasurer re-printing the SAM exclusion data for the 46 INDIANA STATE BOARD OF ACCOUNTS 46 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation vendor and signing/initialing the printout, and second employee will verify the accuracy by their signature/initials on the printout as well. The updated printout will be attached to the vendor W-9 kept on file in the Treasurer’s office. Anticipated Completion Date: The planned corrective action will be implemented in February of 2026 with any new vendor created in the accounting software. For established vendors, the Treasurer will begin re-verifying the vendor’s exclusion data in SAM prior to processing any vendor claims and creating a spreadsheet to track the most recent SAM verification for each vendor. This corrective action will be implemented by March of 2026.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls over review of individual free and reduced status applications and information management in the Skyward Software System used to determine and maintain eligibility status. Individual Applications The school noted individual applications for both direct certification and income eligible students would be printed and reviewed after the system makes a determination of eligibility status. Out of 40 students tested, no documentation of the review was provided for 34 students. Skyward Software System The School Corporation is required to design controls ensuring computer systems used to maintain student benefit status are secured. Currently, the Skyward system allows all school lunch employees to make changes to student benefit status, and there is no indication or record within the system as to who makes these changes. Additionally, income eligibility guidelines in the system that determine whether students are eligible based on income are updated by the system automatically every year. The school is required to perform annual review to ensure these guidelines are accurate. However, no annual review is done by school corporation staff. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us 44 INDIANA STATE BOARD OF ACCOUNTS 44 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: A School Corporation employee will be designated to receive, review and process each individual application. Applications received digitally via the Skyward Software System will be printed so that a paper copy of each digital application is kept on file. The review of each application will be documented in writing on the paper copy of the application. A second School Corporation employee will perform a secondary review of every application to ensure accuracy of the eligibility determination, and the secondary review will be documented on each application. The eligibility guidelines in the Skyward Software System used to determine student eligibility will be downloaded from the School Nutrition Program’s website prior to July 1 of each year and will be uploaded into the Skyward Software System by the technology department of the School Corporation. After upload is complete, the Food Service Manager will review the data to ensure correct upload and will indicate the review on the sign-off form created by the School Corporation. The sign-off form will be retained to document the review. Anticipated Completion Date: The corrective action with regard to individual applications has already been implemented beginning with the 2025-2026 school year. For the 2025-2026 school year, the Treasurer has done the initial review of each application and the Food Service Manager has done the secondary review to ensure accuracy of each determination. Beginning in the 2026-2027 school year the process will remain the same but with the Food Service Manager performing the initial review and the Treasurer performing the secondary review. The corrective action with regard to the eligibility guidelines in Skyward will be implemented beginning with the upload of data in preparation for the 2026-2027 school year, expected to be in June of 2026.
Condition - The District, as a subrecipient of federal awards, contracted with multiple vendors, both directly and indirectly through the use of a purchasing cooperative, without verifying that the vendor was not suspended or debarred or otherwise excluded from participating in covered transactions....
Condition - The District, as a subrecipient of federal awards, contracted with multiple vendors, both directly and indirectly through the use of a purchasing cooperative, without verifying that the vendor was not suspended or debarred or otherwise excluded from participating in covered transactions. Plan - Bid specifications will include a statement that, by returning a bid, vendors are self-certifying that they are not suspended or debarred from participating in covered transactions. If a formal quote is not returned, we will use SAM.gov to ensure that vendors are not suspended or debarred. This search will be documented. We will verify that the purchasing cooperative is following the same procedures for all vendors. Anticipated Date of Completion - December 2025; Name of Contact Person - Dr. Matthew DeBaene, Superintendent; Management Response - We will ensure that all vendors utilized are not suspended or debarred, whether that be through vendor self-certification or the documented use of SAM.gov.
The District will implement internal controls over the suspension and debarment requirement and add this requirement to the procurement process at the District. In addition, we recommend that the District periodically review federal expenditure reports to identify vendors that may have been paid wit...
The District will implement internal controls over the suspension and debarment requirement and add this requirement to the procurement process at the District. In addition, we recommend that the District periodically review federal expenditure reports to identify vendors that may have been paid with federal grants in excess of the $25,000 suspension and debarment threshold to prevent potential noncompliance. All district employees who are approved to obtain bids for purchases have already been informed and trained on the expectation on obtaining proof of suspension and debarment requirements from any vendor they receive bids from or plan on making purchases from that will exceed the $25,000 threshold. Responsible Official: Mandee Campbell, Director of Business Services Anticipated Completion Date: April 1, 2026
Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nut...
Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster Non-Cash Assistance (food distribution) National School Lunch Program ALN: 10.555 Cash Assistance School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District has developed a policy entitled “Procurement: Uniform Grant Guidance for Federal Awards” that addresses the Uniform Guidance requirements related to procurement. This policy was presented to the Board of Education at the August 28, 2025 Board meeting and formally adopted by the Board of Education at the November 17, 2025 Board meeting. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: The required policy was adopted by the Board of Education at its November 17, 2025 meeting.
Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures m...
Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures meet minimum requirements before grant funds are fully expended. • Monitoring and Verification o Fiscal staff will monitor non-public expenditures throughout the grant period and verify documentation demonstrates direct benefit to eligible non-public students. • Staff Training o Staff and Cooperative personnel will receive training on non-public proportionate share requirements and allowable expenditures. • Future Compliance Measures o Strategies will be implemented to prevent shortfalls in future grant periods, including early adjustments to spending plans to ensure full compliance. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all ...
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all federal grant obligations occur within the allowable grant period and that vendor payments align with the original approved purchase orders. • Verification of Obligation Dates o Fiscal staff will verify that purchase orders, vendor invoices, and final payments reflect an obligatory date that occurs prior to the applicable grant deadline. • Staff Training o Rensselaer Central and Cooperative School Services Fiscal personnel involved in grant management will receive training on federal grant period of performance requirements and proper documentation of obligations. • Monitoring Procedures o Rensselaer Central and Cooperative School Services will conduct periodic reviews of federal grant expenditures to ensure ongoing compliance with grant timelines. • Statement of Isolated Occurrence o Rensselaer Central and Cooperative School Services reviewed the circumstances surrounding this finding and determined that the issue was isolated to fiscal year 2024. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedur...
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedures governing the administration of proportionate share funds for non-public schools to ensure compliance with federal grant requirements. (see IDEA Procurement Plan Earmarking for Non Pub CEIS Funds hyperlinked above) • Strengthening Internal Controls o Additional internal controls will be implemented requiring review and approval by the Director of Special Education, Bookkeeper, and Rensselaer Central Treasurer prior to any reimbursement related to non-public school expenditures funded through the Special Education grant. • Reimbursement Process Changes o Non-public schools will no longer receive reimbursements directly from Cooperative School Services. Cooperative School Services will receive approval and verification from the Non-Public School LEA. o All reimbursement requests must include detailed documentation demonstrating that the expenditure directly benefits eligible non-public school students receiving special education services. • Allowable Cost Verification o Rensselaer Central and Cooperative School Services will implement a verification process to ensure all expenditures comply with federal allowable cost requirements and that funds are used solely for the benefit of eligible non-public school students. • Staff Training o Rensselaer Central and Cooperative School Services personnel responsible for federal grant oversight will receive training on federal grant compliance requirements, including allowable and unallowable expenditures (e.g., gift cards and similar incentives). • Monitoring and Oversight o Rensselaer Central will conduct periodic monitoring of expenditures made on its behalf by Cooperative School Services and maintain documentation demonstrating compliance with oversight responsibilities. • Implementation Timeline o These corrective actions and revised procedures have already been implemented and will apply to all future federal Special Education grant expenditures. • Ongoing Compliance Monitoring o Rensselaer Central and Cooperative School Services will conduct annual reviews of federal grant expenditures and internal controls to ensure continued compliance with IDOE and federal grant requirements. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
February 24, 2026 Cognizant or Oversight Agency for Audit Urban Collaborative respectfully submits the following corrective action plan for the fiscal year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01748 Audit peri...
February 24, 2026 Cognizant or Oversight Agency for Audit Urban Collaborative respectfully submits the following corrective action plan for the fiscal year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01748 Audit period: July 1, 2024 - June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDINGS Significant Deficiency 2025-001 Internal Control - Payroll and Cash Disbursement Recommendation: AAFCPAs recommends the Collaborative strengthen internal controls by requiring supervisory approval of all timesheets prior to payroll processing, implementing review procedures to ensure payroll amounts agree to authorized pay rates, and reconciling disbursements to invoices and monitoring outstanding reimbursement checks to ensure resolution. The Collaborative acknowledges the findings related to internal controls over payroll and cash disbursements. While the monetary values of the identified variances were minor, management recognizes the importance of maintaining rigorous oversight to ensure full compliance with federal laws and to mitigate the risk of misstatement. To address these concerns, the Collaborative is continuing to implement the following corrective actions: 1. Enhanced Payroll Approval Process: Timesheets are approved by the respective supervisor and then sent to the Executive Director for final approval prior to payroll submission. 2. Pay Rate Verification: The finance department will implement a secondary review procedure to ensure that all payroll amounts align precisely with authorized pay rates. This cross-verification will occur prior to each payroll cycle to prevent future rate variances. 3. Disbursement Reconciliation: Management is updating its cash disbursement procedures to require a formal reconciliation of every check or payment against its original invoice. This process will ensure that no payment exceeds the authorized invoiced amount. 4. Monitoring Reimbursements: The Collaborative will establish a monthly review of all outstanding reimbursement checks and related documentation to ensure timely and accurate resolution of all financial obligations. If the Department of Education has questions regarding this plan, please call Lynn Prentiss, Executive Director at 401-272-0881. Sincerely yours, Lynn Prentiss Executive Director
2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported t...
2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.
Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...
Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026
Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individ...
Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individuals: The Agency acknowledges the documentation deficiencies identified related to payroll and contract management. These issues were largely due to leadership transitions and changes in operational processes. The Agency has evaluated these gaps and is actively implementing corrective actions to strengthen internal controls and ensure compliance with Uniform Guidance requirements. Corrective Action Plan: Corrective actions currently in progress include: • Standardizing documentation requirements for all employee pay rates, including maintaining supporting documentation within personnel files • Implementing internal review procedures to ensure payroll changes align with Board-approved actions • Centralizing contract management and maintaining all executed service provider agreements in a secure, accessible location • Establishing documentation retention procedures to ensure all supporting records for federal award expenditures are complete and readily available for audit review The Agency is committed to fully resolving these issues and strengthening internal processes to ensure ongoing compliance and accountability. The Agency is implementing enhanced internal control procedures to ensure that all costs charged to federal awards are properly authorized, documented, and maintained in accordance with federal requirements. These improvements include the development of standardized processes for payroll documentation, contract management, and documentation retention. Internal review procedures are also being strengthened to ensure alignment between Board approvals and financial records. Anticipated Completion Date: June 30, 2026
FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the fi...
FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026
Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corre...
Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corrective Action: Management acknowledges the sliding fee scale discount should have been applied consistently and accurately and plan to improve the process going forward. Management corrected the patient accounts by applying the sliding fee scale discount. Contact person responsible for corrective action: Julie Fratianne, CFO Anticipated Completion Date: June 30, 2026
Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanatio...
Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is prepared to return the FY25 FWS Unspent portion of the 7% Community Service required spending (7% of Final FWS Funding of $742,211 = $51,954.77 (rounded to $51,955) [Community Service spending requirement] minus $25,061 (FWS funds spent in community service as reported on FISAP) = $26,894 (Unspent portion of 7% to be returned to ED). Since the pandemic year, ISU’s off-campus (community service) participation has been dwindling and overall FWS participation has suffered since many students and employers are opting to be involved in the University’s Career Path Internship (CPI) program over FWS. Due to the struggles in recent years to meet the 7% Community Service requirement, ISU has been applying for a waiver of the Community Service requirement but thus far our waiver requests have been denied. The Financial Aid Office is reviewing current processes related to tracking FWS Community Service spending and partnering with the Career Center to proactively identify off-campus participants and looking at ways to cooperate with the University’s CPI program participants who are FWS-eligible and who are working in Community Service activities and plan to expand on-campus FWS Community Service opportunities to meet the minimum 7% community service requirement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Katheryn Wareing, Senior Accountant for Financial Aid/FWS Administrator Planned completion date for corrective action plan: 08/24/2026
Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement wit...
Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with...
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025
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