Corrective Action Plans

Finding 386178 (2023-004)

Significant Deficiency 2023

Lincoln University of the Commonwealth System of Higher Education

PA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Action taken in response to finding: Fiscal Affairs will review reporting requirements for any funding received; communicate such requirements to the appropriate parties within the University; and coordinate with Office of Research & Sponsored Programs to ensure that the reporting requirement is me...

Action taken in response to finding: Fiscal Affairs will review reporting requirements for any funding received; communicate such requirements to the appropriate parties within the University; and coordinate with Office of Research & Sponsored Programs to ensure that the reporting requirement is met.

View Audit 298611

Finding 386131 (2023-002)

Significant Deficiency 2023

Nemaha County, Nebraska

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: Ongoing Responsibl...

Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: Ongoing Responsible Party: Mike Hall, Bryan Mellage, Michael Weiss, Nemaha County Board

View Audit 298537

Finding 386119 (2023-002)

Material Weakness 2023

Northwestern Consolidated School District of Shelby County

IN

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

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Number: 7350 Pass-Through Entity: Indiana Departm...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Number: 7350 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Costs Principles, Special Tests and Provisions-Verification of Free and Reduced Price Applications Summary of Finding: Material Weakness Internal Controls were not implemented to prevent noncompliance related to the verification of free and reduced applications and hours and wages. A new internal control procedure will be implemented for the second review of the free and reduced applications and for the hours and wages. Repeat Finding: Prior audit finding number was 2021-002. Contact Person Responsible for Corrective Action: Tammy Achenbach Contact Information: Phone: 317-835-7461 Email: tachenbach@nwshelbyschools.org Views of Responsible Officials: Management agrees with the finding. Management will ensure proper documented review of amounts billed for personnel and for the free and reduce verification 􀀃 INDIANA STATE BOARD OF ACCOUNTS 23 First ~ Best ~ Different! 􀀃 Northwestern􀀃 Consolidated􀀃School􀀃 District􀀃of􀀃Shelby􀀃County􀀃 􀀃 4920􀀃W.􀀃600􀀃N􀀃 Fairland,􀀃IN􀀃46126􀀃 􀀃 Phone:􀀃317􀍲835􀍲7461􀀃 Fax:􀀃317􀍲835􀍲4441􀀃 􀀃 www.nwshelbyschools.org􀀃 Superintendent􀀃 Mr.􀀃Chris􀀃Hoke􀀃 􀀃 Business􀀃Manager􀀃 Mrs.􀀃Tammy􀀃Achenbach􀀃 􀀃 Technology􀀃Director􀀃 Mr.􀀃Josh􀀃Landis􀀃 􀀃 Maintenance􀀃Director􀀃 Mr.􀀃Terry􀀃Coons􀀃 􀀃 Transportation􀀃Director􀀃 Mrs.􀀃Susie􀀃Childress􀀃 􀀃 Special􀀃Education􀀃Director􀀃 Mrs.􀀃Terri􀀃Branson􀀃 􀀃􀀃 School􀀃Board􀀃 Mr.􀀃David􀀃Ploog􀀃 Mrs.􀀃Brooke􀀃Lockett􀀃 Mrs.􀀃Cressa􀀃Rund􀀃 Mr.􀀃Ken􀀃Polston􀀃 Mr.􀀃Terry􀀃Morgan􀀃 Mr.􀀃Travis􀀃Hensler􀀃 Mrs.􀀃Karen􀀃Humphreys􀀃 Cont. page 2 Description of Corrective Action Plan: Review for personnel charges: During the monthly meeting to review the FSMC invoice, along with Operations Ledger, Client P&L, Monthly Reimbursements, Invoices, USDA Reconciliation, Direct Certification, The Hours and Wages will be reviewed and approved. Free and Reduced Verification: Internal Controls for the first round of Free and Reduce Applications will be verified by the Data Controller or the Business Manager and the verification of the random testing of the verifications will be done by the Business Manager or the Deputy Treasurer. Anticipated Completion Date: The district will start the new internal control procedure March 2024 to correct for the 23-24 school year.

View Audit 298525

Finding 386045 (2023-101)

Material Weakness 2023

Navajo County

AZ

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.278 WIOA Dislocated Worker Formula Grants Contact Person: Jeremy Flowers, WIOA Executive Director Anticipated completion date: June 30, 2024 Concur. To ...

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.278 WIOA Dislocated Worker Formula Grants Contact Person: Jeremy Flowers, WIOA Executive Director Anticipated completion date: June 30, 2024 Concur. To help ensure the County meets the WIOA Cluster’s earmarking requirement to spend no less than 20 percent of WIOA Youth Activities funds allocated to the County to provide in-school and out-of-school youth with paid and unpaid work experiences (WEX), the County has revised its process for tracking work experience expenditures. The County will utilize the revised process and provide technical assistance to the sub-recipient, Chicanos Por La Causa (CPLC) to implement procedures that will lead to an increase in Youth enrollments and placement into WEX to ensure at least 20 percent of the WIOA Youth Activities funds allocated to the County are used to provide in-school and out-of-school youth with paid and unpaid WEX. County staff are currently working with CPLC staff to implement a different approach to attaining the WEX requirements. The recommended solutions include improved tracking and monitoring of the WIOA Youth WEX activities to include both paid and unpaid work experiences, increasing all youth outreach, partnering with other local youth programs, and enrolling youth with barriers pursuant to current policy. The County will be tracking Youth progress and will be revising strategies as needed. The County’s goal is to see a significant increase in Youth WEX program activities by the end of fiscal year 23-24.

View Audit 298417 Questioned Costs: $1

Finding 386039 (2023-003)

Material Weakness 2023

Paoli Community School Corporation

IN

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

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required ...

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Greg Walker, Superintendent Contact Phone Number and Email Address: 812-723-4717 and walkerg@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent will enter information into the annual data report required for ESSER and once completed the Corporation Treasurer will review the information entered for accuracy. The Corporation Treasurer will sign off that the information entered is correct and then the Superintendent will submit the data report. Anticipated Completion Date: Projected date of completion is April 2024.

View Audit 298416

Finding 386017 (2023-007)

Significant Deficiency 2023

Idaho State University

ID

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

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Ma...

2023-007: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the intuition and are reported timely. We also recommend that the University implement a formal review procedure to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During our discussion, it became apparent that a significant portion of the findings pertaining to the Office of the Registrar stemmed from enrollment status change not being reported to NSLDS within 60 days. To remedy this, we have added three new automated enrollment uploads right after the upload of the graduation file respectively in Fall, Spring and Summer. The three automated enrollment uploads to be sent to NSLDS are scheduled as follows: 1. On February 16; 2. On June 3; 3. On September 1. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: Implemented in February 2024

View Audit 298414

Finding 385996 (2023-006)

Material Weakness 2023

Idaho State University

ID

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

2023-006: Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Material Weakness Other Matters Recommendation: ISU should evaluate its procedure...

2023-006: Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Material Weakness Other Matters Recommendation: ISU should evaluate its procedures around disbursement of loans and ensure that notifications of disbursements are sent and contain all of the required elements outline in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To meet requirements outlined in 34 CFR 668.165, ISU includes information in a student’s award notification email and in their MyISU portal of pertinent Direct Loan information including their “Award Payment Schedule” and what steps to take to accept, decline or modify their award offers. Additionally, in July 2023, ISU implemented an automated email notification in our daily job scheduler, AppWorx, that is sent on each date of disbursement to student Direct Loan borrowers and parent borrowers of Direct Parent PLUS (added Feb 2024) notifying them of the disbursement and reminding them what they need to do to revise or cancel the loan disbursement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid Planned completion date for corrective action plan: Implemented in December 2023.

View Audit 298414

Finding 385975 (2023-005)

Significant Deficiency 2023

Idaho State University

ID

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matte...

2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should review the requirements and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU reopened the prior financial aid years in COD and completed returns of federal aid funds via G5/6 from identified outstanding checks. ISU has implemented the following monitoring controls: At the beginning of each month finance runs check reissue forms for all checks that the check date is 180 days or older. These are mailed to the check recipient. Around the 15th of the month any checks containing Title IV funds that have not been reissued will be turned to the financial aid office. Financial Aid is provided with the date by which the funds need to be returned. Financial Aid attempts to work with the student to get the checks cashed if they are not successful will return funds before the 240-day limit. They will then notify Finance to cancel the original check. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller, James Martin, Director of Financial Aid Planned completion date for corrective action plan: Implemented in 2020.

View Audit 298414 Questioned Costs: $1

Finding 385817 (2023-004)

Significant Deficiency 2023

Idaho State University

ID

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

2023-004: Suspension Debarment Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Rec...

2023-004: Suspension Debarment Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to insure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 sanction and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be imitated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented in April 2024.

View Audit 298414

Finding 385660 (2023-003)

Significant Deficiency 2023

Idaho State University

ID

Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.319 § 200.320

2023-003: Procurement Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendati...

2023-003: Procurement Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to document reasons for obtaining competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Accounting and Purchasing will both review requisitions within Jaggaer to make sure appropriate bids, and or exemptions are documented or attached. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: Implemented in February 2024.

View Audit 298414 Questioned Costs: $1

Finding 385659 (2023-002)

Significant Deficiency 2023

Idaho State University

ID

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

2023-002: Cash Management-Subrecipient Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matt...

2023-002: Cash Management-Subrecipient Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented in FY24

View Audit 298414

Finding 385654 (2023-001)

Significant Deficiency 2023

Idaho State University

ID

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 ...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-001: Reporting Federal Program Titles: Every Student Succeeds/Preschool Development Grants Primary Care Training and Enhancement Assistance Listing Number: 93.884 & 93.434 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: ISU should implement formal review procedures to document review and approvals over required reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU had a formal review procedure in place, but due to personnel changes it was not being followed. Staff has been trained and procedures will be followed. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented FY24

View Audit 298414

Finding 385621 (2023-002)

Material Weakness 2023

South Spencer County School Corporation

IN

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

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: For three vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justi...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: For three vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Contact Person Responsible for Corrective Action: Food Service Director, Maggie Caudill Contact Phone Number and Email Address: (812) 649-2591 / maggie.caudill@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Small Purchase Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385615 (2023-001)

Material Weakness 2023

South Spencer County School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent...

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

View Audit 298337

Finding 385601 (2023-002)

Significant Deficiency 2023

Butler County

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has implemented a process to ensure when a contractor is paid with federal funds that the vendor will be looked up on sam.gov to verify the entity has ...

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has implemented a process to ensure when a contractor is paid with federal funds that the vendor will be looked up on sam.gov to verify the entity has not been suspended or debarred, upon which time a printout will be printed and put with the claim that is being paid as well as attaching the verification to the ARPA binder that has a copy of all claims paid with the ARPA funds. Anticipated Completion Date: Completed 3/13/2024. Responsible Party: Butler County Board of Supervisors: Anthony Whitmore, Scott Steager, Tony Krafka, Scot Bauer, Robert Coufal, Jan Sypal, and Ryan Svoboda.

View Audit 298323

Finding 385592 (2023-009)

Significant Deficiency 2023

Clarkson College

NE

Reporting Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

2023-009 Higher Education Emergency Relief Funding (HEERF) – Assistance Listing No. 84.425 Recommendation: We recommend the College establish a review process to ensure accurate submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken ...

2023-009 Higher Education Emergency Relief Funding (HEERF) – Assistance Listing No. 84.425 Recommendation: We recommend the College establish a review process to ensure accurate submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will ensure that review procedures are in place to ensure accurate submission. Name(s) of the contact person(s) responsible for corrective action: Robyn Hansen Planned completion date for corrective action plan: March 2024

View Audit 298311

Finding 385529 (2023-002)

Significant Deficiency 2023

Clarkson College

NE

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

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagre...

2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College will review, revise and implement procedures for cost of attendance, awarding of financial aid offers, and R2T4, in addition to the review of the process of all monthly reconciliations related to Pell, Direct Loan, SEOG and FWS along with G5 drawdowns annotated and reconciled with the Finance Department. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: July 2024

View Audit 298311

Finding 385519 (2023-010)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting 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 preventin...

FINDING 2023-010 Finding Subject: COVID -19 - Education Stabilization Fund – Reporting 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. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

View Audit 298302

Finding 385517 (2023-009)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.208 § 200.302 § 200.303 § 200.305 § 200.328

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in prev...

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385513 (2023-008)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation...

FINDING 2023-008 Finding Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Allowable Activities and Allowable Costs/Cost Principles compliance requirements. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee to ensure all costs are correct and allowable before giving their approval. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the Schools Corporation’s fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will be checking for Allowable Activities and Allowable Costs/Cost Principles and verifying that they meet compliance. During the reimbursement process the grants person will also make sure all sections of the grant have been properly expended. Anticipated Completion Date: March 2024

View Audit 298302

Finding 385511 (2023-007)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-007 Finding Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Earmarking, Period of Performance Summary of Finding: Activities Allowed or Unallowed and Allowable Costs/Cost Principles The School Corporation did not have adequat...

FINDING 2023-007 Finding Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Earmarking, Period of Performance Summary of Finding: Activities Allowed or Unallowed and Allowable Costs/Cost Principles The School Corporation did not have adequate procedures in place to ensure that only employees performing duties for the Special Education Program were being paid out of the grant funds. The Corporation Treasurer was reviewing a total amount paid from each fund account; however, a detailed payroll report was not being reviewed that would have identified the employees being paid from the grant fund. Earmarking The School Corporation did not have internal controls in place to ensure that they were in compliance with the earmarking requirements. The Special Education Director and Corporation Treasurer compiled and reviewed the proportionate share reports that get sent to Indiana Department of Education to track non-public school expenses, however, that control was not able to be verified as the reports were not retained. Period of Performance The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. During this meeting they will also review payroll (salary and benefits) to identify employees who are included in the grant. All reimbursements and proportionate share documents are reviewed, signed and filed in an individual grant binder, housed in the special education office. Special education director will code initial expenditures to grant appropriation lines and submit to payroll and corporation treasurer. Payroll then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: April 2024

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Finding 385509 (2023-006)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-006 Finding Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative). During fiscal year 2021-2022. The School Corporation was responsible for ensuring and providing oversight...

FINDING 2023-006 Finding Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative). During fiscal year 2021-2022. The School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation to ensure compliance with the Procurement compliance requirement. Two vendors exceeded the small purchase threshold during the audit period and both vendors were selected for testing. For both vendors only the quote that was utilized was retained and no other audit evidence could be provided to show that additional quotes as required were obtained. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not retained for audit for either purchase. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We do not concur with the finding. Explanation and Reasons for Disagreement: The two instances cited in this finding were the results of a purchase made through the cooperative purchasing agency. Silver Creek chose this vendor that IAESC manages. IAESC serves as a governmental body in which SCSC is allowed to enter into an agreement to form a cooperative purchasing organization per IC 5-22-4-7. We can provide evidence that the cooperative purchasing agency has properly conducted an RFP for these two purchases. After reviewing the purchases for CDW Government and School Outfitters, SCSC does not recognize these as small purchases since these items were listed separately on the voucher and did not cross the threshold of $10,000.00.

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Finding 385507 (2023-005)

Material Weakness 2023

Silver Creek School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a ...

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation is no longer part of the Special Education Cooperative. The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. The Special education director will code initial expenditures to grant appropriation lines and submit to accounts payable specialist. Accounts payable specialist then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: March 2024

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Finding 385505 (2023-004)

Material Weakness 2023

Silver Creek School Corporation

IN

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

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Findings: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The Cooperative did no...

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Findings: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The Cooperative did not have internal controls in place over payroll transactions to ensure expenditures were allowable and in conformance with the cost principles. The Treasurer reviewed a report which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee being paid from the grant fund. For vendor disbursements, although the Deputy Treasurer matched the invoice to the purchase order and provided it to the Corporation Treasurer for review and signature of the accounts payable voucher prior to payment, the control was not effective and did not detect or allow correction of errors. In the initial sample of 6 vendor disbursements, one claim was unable to be provided. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education, Tamara Swarens, Director of Elementary Curriculum and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school tswarens@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The AP Specialist makes sure that there is an appropriate claim for each payment we make, there are two signatures on each claim and the claims are approved by the Treasurer. Check processing is completed by the Deputy Treasurer as the third check. The AP Specialist now scans each invoice to the FMS accounting system to ensure that we have all back up for the claims. With the new Directors of Curriculum and Special Education, we only reimburse for positions that are charged to the federal grant that have gone through a multi-step process to ensure that they get coded to the right place. The process is also reviewed at the time a request for reimbursement is made. Anticipated Completion Date: March 2024

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Finding 385503 (2023-003)

Material Weakness 2023

Silver Creek School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2023-003 Finding Subject:􀀃Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation did not have internal controls in place to ensure that...

FINDING 2023-003 Finding Subject:􀀃Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Non-Public Proportionate Share expenditures for all grant awards were not expended as required by IDOE for the individual member schools. The Cooperative categorized each expenditure by location and the total amount did not meet or exceed the required proportionate share as outlined on the award letter. The Cooperative was required to spend a total of $59,633 for 20611-158-PN01 and $35,470 for 20619-158- PN01. $32,798 was identified as being spent for 20611-158-PN01, which was less than the required proportionate share. The Cooperative was unable to provide documentation to identify the expenditures spent for 20619-158-PN01. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The Special Education Director has a beginning of the year consultation with the private school principal to discuss and finalize the proportionate share budget. The Corporation Treasurer and Special Education Director will review and co-complete the semi-annual prop share workbook to ensure that private school funding is expended in a timely manner. Anticipated Completion Date: March 2024

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