Corrective Action Plans

Finding 384438 (2023-004)

Material Weakness 2023

IN

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

FINDING 2023-004 Finding Subject: COVID 19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation failed, due to the lack of internal controls, to ensure that the ESSER annual data reports were complete and accurate prior to submission and that the reports had sufficie...

FINDING 2023-004 Finding Subject: COVID 19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation failed, due to the lack of internal controls, to ensure that the ESSER annual data reports were complete and accurate prior to submission and that the reports had sufficient oversight to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Director of School Finance will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Superintendent, or his or her designee, will review the records and annual data report. The Director of School Finance and the Superintendent, or his or her designee, will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: This Corrective Action Plan will be put in effect April 2024 or when the next annual data reports are prepared.

View Audit 297573

Finding 384436 (2023-003)

Material Weakness 2023

Linton-Stockton School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ens...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ensure that the parameters that were entered into the student information software system were accurate. The School Corporation failed to maintain adequate documentation of the on-line and paper applications that were reviewed so that documentation was available for audit. The School Corporation failed, due to the lack of internal controls, to provide adequate oversight of the direct certification process to ensure that the Direct Certification Reports were generated and input accurately into the student information software system. Verifications of Free and Reduced Price Applications The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ensure that the verification process was properly performed. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 32 Description of Corrective Action Plan: Eligibility - Income guidelines will be entered by the Director of Food Services and reviewed by the Director of School Finance to ensure accuracy. Review by the Director of School Finance will be noted on the July monthly checklist completed by the Director of School Finance. Direct certification - The direct certification process will be completed monthly by the Director of Food Services and will be reviewed by the Director of School Finance. Review by the Director of School Finance will be noted on the monthly checklist completed by the Director of School Finance. Review of Applications - The Director of Food Services will compile and maintain a spreadsheet of all free and reduced applications received. The spreadsheet will include pertinent information from the application as well as information regarding what benefits were assigned to the student based on the application. The spreadsheet will be reviewed periodically by the Director of School Finance and that review will be documented on the spreadsheet. Verification - Verification will be completed by the Student Data Coordinator and a review of the verification documentation will be completed by the Director of Food Services evidenced by signature on the documentation. Anticipated Completion Date: This Corrective Action Plan will be put in effect March 2024.

View Audit 297573

Finding 384431 (2023-002)

Material Weakness 2023

Linton-Stockton School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement The School Corporation failed to award contracts to four vendors totaling $314,783, which were considered small purchases. For small purchases of over $10,000 but less...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement The School Corporation failed to award contracts to four vendors totaling $314,783, which were considered small purchases. For small purchases of over $10,000 but less than $150,000, an informal process allows securing rate quotations from an adequate number of sources; however, the process still requires a written contract between the vendor and the school corporation. Suspension and Debarment The School Corporation failed, due to the lack of effective internal controls, to provide adequate oversight of the suspension/debarment process to ensure compliance to the process prior to paying vendors that were expected to be paid an amount equal to or exceeding $25,000. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement When quotes for small purchases are received, the Director of School Finance will acknowledge a quote provided by a vendor that will be accepted by the corporation by written letter acknowledging the school corporation’s acceptance of the quote. The contract as well as the quote will be retained by the Director of School Finance and the Director of Food Services for comparison to invoices. INDIANA STATE BOARD OF ACCOUNTS 30 Suspension and Debarment On an annual basis, all vendors that are expected to be paid in excess of $25,000 will be searched by the Director of School Finance for suspension or debarment or the vendor will provide certification, either as a separate document, or as part of a written contract, that the vendor is not excluded or disqualified to receive federal funds. Those searches or other documentation will be reviewed by the Superintendent and acknowledged by signature. Anticipated Completion Date: This Corrective Action Plan will be put in effect March 2024.

View Audit 297573

Finding 384429 (2023-009)

Material Weakness 2023

Rush County Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: Eligibility determinations were made by the Cafeteria Secretary, and are now reviewed by the Food Service Director. However, this control was not in place for the majority of the audit period. Contact P...

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: Eligibility determinations were made by the Cafeteria Secretary, and are now reviewed by the Food Service Director. However, this control was not in place for the majority of the audit period. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Since the 2019 audit, the responsibility of the Free/Reduced lunch applications was shifted to the middle school cafeteria secretary, Connie Amos. Mrs. Amos reviews information in the application and designates if it meets the criteria for Free, Reduced, or Paid lunches. The Food Service Director, Nancy Schroeder will also review the applications and confirm the results calculated by Mrs. Amos. This control was brought to our attention late in the application process so only part of the applications were reviewed. Now 100% of all applications will be reviewed by two people. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384428 (2023-008)

Material Weakness 2023

Rush County Schools

IN

School Nutrition Programs Eligibility Material Weakness § 200.303

FINDING 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price ap...

FINDING 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price applications. While the verification was reviewed by a second person, that control was not effective. All six of the required verified applications in the fiscal year 2022-23 were tested. Two of the six verified applications were calculated incorrectly resulting in improper eligibility status changes. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The middle school cafeteria secretary, Connie Amos, will contact parents regarding verification of their free/reduced lunch application. This information will then be reviewed by the Food Service Director, Nancy Schroeder, to determine the information is accurate. Parents are always notified on any changes to the lunch status. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384421 (2023-007)

Material Weakness 2023

Rush County Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related...

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement The School Corporation did not complete or submit the fiscal year 2023 Procurement Plan as required to the Indiana Department of Education. Suspension and Debarment The School Corporation was a member of the East Central Educational Service Center (ECESC) during fiscal years 2021-2022 and 2022-2023. ECESC verified that vendors were not suspended or debarred when securing bids for food, dairy, and bread products on behalf of the member schools. However, for purchases of goods and services exceeding $25,000 handled by the School Corporation, 3 of the 5 vendors selected for testing were not verified for suspension and debarment to ensure vendors were not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186 cramej@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Due to turnover in the Superintendent position and Food Service Director, position there was no access to SAM to verify vendor. This has been now been corrected and the Superintendent and Assistant Superintendent have access to SAM. They will verify for the Food Service Director any company will wish to deal with over $25,000. Future purchases will meet the school corporation’s procurement policy. All vendors in which expenditure exceed $25,000 will reviewed by the Food Service Director and either the Superintendent or Assistant Superintendent. Procurement – A 2023 procurement plan has been developed and will be sent to the Indiana Department of Education. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384419 (2023-006)

Material Weakness 2023

Rush County Schools

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-006 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: 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. After the annual data reports were prepare...

FINDING 2023-006 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: 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. After the annual data reports were prepared, they were reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction of errors prior to submission. Due to the lack of effective internal controls, two of the six annual data reports were not supported by the School Corporation’s records. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Information in the ESSER III Year 1 and Year 2 reports were entered into incorrectly. The Superintendent or Corporation Treasurer will review all ESSER reports with the Grant Coordinator, Nancy Schroeder, to ensure accuracy. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384416 (2023-005)

Material Weakness 2023

Rush County Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) - Suspension and Debarment Summary of Finding: Prior to entering into sub awards and covered transactions with program funds, recipients are required to verify that such contractors and sub recipients are not suspended, debarred, or ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) - Suspension and Debarment Summary of Finding: Prior to entering into sub awards and covered transactions with program funds, recipients are required to verify that such contractors and sub recipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusion, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not sufficient procedures in place. Three covered transactions that equaled or exceeded $25,000 were identified. All three transactions were selected for testing. For the INDIANA STATE BOARD OF ACCOUNTS 46 three transactions, the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186 cramerj@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Due to turnover in the Superintendent position and Grant Coordinator, position there was no access to SAM to verify vendor. This has been now been corrected and the Superintendent and Assistant Superintendent have access to SAM. They will verify for the Grant Coordinator any company will wish to deal with over $25,000. Future purchases will meet the school corporation’s procurement policy. All vendors in which expenditure exceed $25,000 will reviewed by the Grant Coordinator and either the Superintendent or Assistant Superintendent. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384414 (2023-004)

Material Weakness 2023

Rush County Schools

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.303

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related t...

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. There was no documentation of a review process to confirm that all appropriate staff completed assessment system security training as required. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Special Tests and Provision – Assessment System Security – All personnel who come in contact with state assessment are trained in prodigals, procedures, and security. Everyone trained has completed a security and integrity agreement, which is kept on file at each school. The School Testing Coordinators (principals) will send to the Corporation Testing Coordinator, Tanner Hedrick, a copy of the security and integrity agreement and a copy of the sign in sheet for the state assessment training. Mr. Hedrick will verify that all appropriate personnel have be adequately training and will sign the sign in sheets after he confirms the information is complete. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384412 (2023-003)

Material Weakness 2023

Rush County Schools

IN

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

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the ...

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The October 1st Real Time Report of Pupil Enrollment (PE) was used by the Indiana Department of Education to pull data into the Title I application. These numbers were then used to calculate Percent Poverty which was used to rank schools for Title I eligibility. One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. The Indiana Department of Education (IDOE) used the October 1 Real Time reports for fiscal years 2020- 2021 and 2021-2022, as provided by the School Corporation, to determine Title I Eligibility for the 2021- 2022 and 2022-2023 grant programs, respectively. There was no October 1 Real Time report presented for audit for fiscal year 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Eligibility – The Technology Director, Brevin Runnebohm will supply the Title I director with the official October 1 count each school year. This will be retained for audit and will be used by the Grant Coordinator, Nancy Schroeder, to determine the enrollment numbers in the Title I application have INDIANA STATE BOARD OF ACCOUNTS 45 been prepopulated correctly. The Grant Coordinator will sign off that she has reviewed this information and find it accurate. Anticipated Completion Date: 10/2024

View Audit 297571

Finding 384354 (2023-001)

Significant Deficiency 2023

University of Denver

CO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469 Questioned Costs: $1

Finding 384346 (2023-003)

Material Weakness 2023

Southeast Dubois County School Corporation

IN

Equipment & Real Property Management Procurement, Suspension & Debarment Material Weakness § 200.303 § 200.313

FINDING 2023-003 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include two capitalized expenditures in t...

FINDING 2023-003 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include two capitalized expenditures in the amounts of $70,000 and $26,440 related to the replacement of rooftop air conditioning units. Additionally, the capital asset listing provided did not identify which assets were purchased with federal dollars nor did the assets have an assigned serial number or other identification number. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager has added the two assets referenced above to the asset records. Additionally, the Business Manager has reviewed the capital asset records and noted all capital assets that were purchased with federal funds. The School Corporation will determine a way to assign identification numbers to the assets listed on the record. Anticipated Completion Date: September 2024

View Audit 297465

Finding 384342 (2023-002)

Material Weakness 2023

Southeast Dubois County School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2023-002 Finding Subject: Child Nutrition Cluster -Procurement and Suspension and Debarment Summary of Finding: 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...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster -Procurement and Suspension and Debarment Summary of Finding: 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 with Procurement, Suspension and Debarment. The School Corporation entered into more than $50,000 of like/kind transactions with a single vendor during FY2022 and FY2023 without entering into a contract or properly verifying that the vendor was not suspended or debarred. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager will review the vendors related to covered transactions and determine if like/kind transactions with any vendor are approaching or are expected to exceed $50,000. For vendors that meet the criteria of requiring a contract, the Business manager will obtain a contract, which will be reviewed and approved by the school board. The Business Manager will upload the purchase order and quote or other documentation of any purchase over $50,000 on Indiana Gateway for Government Units (Gateway) after board approval. Southeast Dubois County School Corporation followed the corrective action that was issued during the prior audit for Suspension and Debarment. During the current audit, the State Board of Accounts indicated that the corrective action and steps that were taken to verify compliance that the School Corporation was instructed to do were not adequate. Going forward, the Business Manager will run monthly vendor reports to determine if any vendors are close to the $25,000 to get a Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion form from the IN Department of Education needs to be issued to a vendor. If a vendor is close to the $25,000 mark, the Business Manager will send the Certification to be returned prior to future payment. Anticipated Completion Date: September 2024

View Audit 297465

Finding 384322 (2023-003)

Significant Deficiency 2023

Erikson Institute

IL

Cash Management Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than ...

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than one percent of total prior year drawdowns, were not returned within a seven day tolerance period. Corrective Action Plan A Student Bursar was hired in November 2022 and onboarding included comprehensive federal funds cash management training with an outside consultant. A review of cash management policies in place was conducted at that time and monitoring procedures and reconciliations were enhanced to eliminate excess cash. Contact Person Christine Frankhauser Controller cfrankhauser@erikson.edu Anticipated Completion Date January 2023

View Audit 297439

Finding 384321 (2023-002)

Significant Deficiency 2023

Erikson Institute

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

View Audit 297439

Finding 384318 (2023-001)

Significant Deficiency 2023

Erikson Institute

IL

Internal Control / Segregation of Duties Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GL...

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GLBA) by June 9, 2023, the required date of compliance. Of the eight required elements under the GLBA, the Institute did have six written and formally documented safeguards, one is not applicable (assess apps developed by institution) and one had safeguards designed (dispose of customer information securely) but not a written policy in place. Corrective Action Plan A comprehensive formal Information Security Policy that addresses all required safeguards under the GLBA has been drafted, and as of March 2024 is in its final institutional review with approval expected in April 2024. Contact Person Ed Baker IT Director ebaker@erikson.edu Anticipated Completion Date April 2024

View Audit 297439

Finding 384236 (2023-001)

Significant Deficiency 2023

Town of Easton (the Easton Utilities Commission)

MD

Internal Control / Segregation of Duties Significant Deficiency Equipment & Real Property Management § 200.303

2023-001 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented...

2023-001 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In July 2022, EUC implemented a process in which the Supervisor of Velocity Plant Operations reviews material requisitions before the paper requisitions move to Accounting for entry into the accounting system. In March of 2023, EUC implemented the requirement for material requisitions to be initialed in order to document the review process. In May 2023, EUC moved to an electronic material requisition process which does not allow material requisitions to be available for Accounting to enter until they have been approved by a designated approver. All costs are additionally reviewed by the Senior Staff Accountant and the Chief Financial Officer before being submitted for reimbursement to the USDA. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: Corrective action was taken March 2023.

View Audit 297379

Finding 384231 (2023-003)

Significant Deficiency 2023

St. Luke's Home and St. Luke's Home Foundation

ND

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

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve funds or debt service coverage ratio for the federal program ....

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve funds or debt service coverage ratio for the federal program .. Responsible Individual: Amy Kreidt, CEO/Administrator and Brenda Thronburg, Accountant Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the Organization's reserve fund and debt service coverage ratio is completed with formal documentation noting the review. Anticipated Completion Date: 3/31/2024

View Audit 297360

Finding 384217 (2023-004)

Significant Deficiency 2023

Hill Top Home of Comfort, Inc.

ND

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

Finding 2023-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund or financial covenant calculations...

Finding 2023-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund or financial covenant calculations. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program’s reserve fund and financial covenant calculations is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account and on the financial covenant calculation worksheets. Anticipated Completion Date: 03/31/2024

View Audit 297302

Finding 384139 (2023-006)

Significant Deficiency 2023

Concordia University, St. Paul

MN

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

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to p...

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will communicate with our third party servier to understand when they believe their SSAE 18 report will be issued. If it will be late, we will coordinate with them to perform the necessary testing to ensure we can perform the due diligence. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: June 30, 2024

View Audit 297264

Finding 384093 (2023-004)

Significant Deficiency 2023

Cloud County Health Center, Inc.

KS

Special Tests & Provisions Student Financial Aid Cash Management § 200.303

Federal Award Finding Finding 2023-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number - Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in c...

Federal Award Finding Finding 2023-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number - Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in compliance with the terms of the loan agreements related to the reserve funds. Responsible Individuals: Ron Harrington, CFO Corrective Action Plan: The CFO will create the appropriate reserve accounts, as required under the loan agreements. This item will be discussed with our contact person at USDA to ensure the hospital will be in compliance with the loan agreements and letter of conditions since the closing of the loans in 2022. Additionally, management will implement a control process to enusre the monthly deposits are made as required, until the accounts are fully funded. Anticipated Completion Date: Ongoing

View Audit 297221

Finding 384060 (2023-001)

Significant Deficiency 2023

South Central Regional Medical Center

MS

Allowable Costs / Cost Principles § 200.303 § 200.430

Management has implemented a policy and process whereby all corrected time cards are required to be approved by a supervisor prior to payroll being generated.

View Audit 297158

Finding 384004 (2023-001)

Significant Deficiency 2023

Clarke County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303 § 200.305 § 200.307 § 200.403

FA 2023-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Cash Management Program Income Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Departm...

FA 2023-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Cash Management Program Income Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 Questioned Costs: $309,623 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School emergency Relief Fund Program. Corrective Action Plans: No after-school program expenditures have been or will be included int eh ESSER expenditures for FY2024. Estimated Completion Date: July 1, 2024 Contact Person: Chris Griner, Chief Financial Officer Telephone: 706-546-7721 Email: grinerc@clarke.k12.ga.us

View Audit 297005 Questioned Costs: $1

Finding 383995 (2023-009)

Material Weakness 2023

School City of East Chicago

IN

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

FINDING 2023-009 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃Wage􀀃Rate􀀃Requirements􀀃 Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action:...

FINDING 2023-009 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃Wage􀀃Rate􀀃Requirements􀀃 Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID – 19 ESSER Funds are reported accurately to the State and Federal Department of Education regarding Department of Labor rules and regulations on pay wages on construction projects completed with Federal funds. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

View Audit 296995

Finding 383989 (2023-008)

Material Weakness 2023

School City of East Chicago

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2023-008 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email ...

FINDING 2023-008 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID – 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

View Audit 296995

Corrective Action Plans

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