Corrective Action Plans

Finding 382463 (2023-061)

Material Weakness 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.332 § 200.403 § 200.430

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is ...

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is in the process of obtaining affidavits from all Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities who received payments under LB1014 stating that funds were used for allowable purposes. Premium Pay: We do not believe any corrective action is warranted as our files were corrected with the Auditor’s guidance and assistance in accordance with all CSLFRF eligibility requirements. Assistance to Nonprofits: For Shovel-Ready awards that have already been granted, DED will confirm prior to close-out of the grant that there is sufficient supporting documentation showing the awardee suffered a harm related and reasonably proportional to the award. Sufficient supporting documents must prove that the nonprofits suffered an economic harm, such as a decrease in revenue or an increase in expenses due to COVID-19. The evidence may include but is not limited to: • Profit and loss statements showing a decrease in revenue or an increase in expenses • Audited financial statements showing a decrease in review or an increase in expenses • Change in a line of credit • Increase in costs for projects related to COVID-19, such as construction cost data, • Decrease in written pledges related to COVID-19 • Decrease in donations related to COVID-19 • Historical fundraising comparisons University of Nebraska: The University project is ongoing. In the next six months, Military/NEMA will initiate monitoring activities to include the review and validation of expenditures for allowability as required under 2 C.F.R. part 200. Nursing Scholarships: DHHS’ current internal controls for the Nursing Scholarship program have minimized the risk of fraud as they correctly identified this case of fraud and have identified others prior to any payment being made. DHHS will continue to review payments for the Nursing Scholarship program, which uncovered the $5,000 identified in the finding. Contact: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Premium Pay: Nicole Zimmerman, Finance Director Assistance to Nonprofits: Audrey Sautter, DED Compliance Team Manager University of Nebraska: Erv Portis, Assistant Director-Nebraska Emergency Management Agency (NEMA) Nursing Scholarships: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Anticipated Completion Date: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: June 2025 Premium Pay: N/A Assistance to Nonprofits: DED will draft a policy to place the above into effect within the next 7 days. University of Nebraska: July 2024 Nursing Scholarships: June 2025

View Audit 296116 Questioned Costs: $1

Finding 382462 (2023-060)

None 2023

State of Nebraska

NE

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

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Allowability Corrective Action Plan: The Agency will continue to work with NIFA and monitor process improvement. Findings will be reviewed with management and work to eliminate errors. Contact: Erv Portis Anticipated Completion Date: o...

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Allowability Corrective Action Plan: The Agency will continue to work with NIFA and monitor process improvement. Findings will be reviewed with management and work to eliminate errors. Contact: Erv Portis Anticipated Completion Date: ongoing

View Audit 296116 Questioned Costs: $1

Finding 382460 (2023-058)

Material Weakness 2023

State of Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.405

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Allowability & Eligibility & Period of Performance Corrective Action Plan: Continue process improvement to identify and correct assistance payments that are in accordance with the approved timelines and federal regulations. Contact: Er...

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Allowability & Eligibility & Period of Performance Corrective Action Plan: Continue process improvement to identify and correct assistance payments that are in accordance with the approved timelines and federal regulations. Contact: Erv Portis Anticipated Completion Date: Ongoing

View Audit 296116 Questioned Costs: $1

Finding 382396 (2023-057)

Significant Deficiency 2023

State of Nebraska

NE

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.305 § 200.511

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency will increase continued trend analysis efforts and shift functional responsibilities back to the State Services Support Division for more detailed...

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency will increase continued trend analysis efforts and shift functional responsibilities back to the State Services Support Division for more detailed oversight moving forward now that vacancies have been filled. The Agency will explore the feasibility of increased frequency of funding requests to decrease the amount of time between the Federal draw and the disbursement of funds by the State. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

View Audit 296116

Finding 382389 (2023-032)

None 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403 § 200.405

Program: AL 93.658 – Foster Care Title IV-E; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.659 – Adoption Assistance – Allowable Costs/Cost Principles Corrective Action Plan: DHHS will assign RMTS Administrator rolls to Program staff to ...

Program: AL 93.658 – Foster Care Title IV-E; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.659 – Adoption Assistance – Allowable Costs/Cost Principles Corrective Action Plan: DHHS will assign RMTS Administrator rolls to Program staff to better monitor the RMTS process. Contact: Patrick Werner Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382388 (2023-029)

Significant Deficiency 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403 § 200.405

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Enforcement; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.778 – Medical Assistance Program; AL 10.561 – St...

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Enforcement; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: Training will be completed that highlights the importance of complete and accurate Journal Entries and how they may affect Federal Funding. Contact: Patrick Werner Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382363 (2023-002)

Significant Deficiency 2023

Crosspoint Human Services

IL

Questioned Costs Allowable Costs / Cost Principles § 200.303

Management will enhance its internal controls to ensure payroll allocation costs are properly calculated and costs are charged to the federal program properly.

View Audit 296051 Questioned Costs: $1

Finding 382357 (2023-008)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal A...

FINDING 2023-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. Context: The School Corporation had not designed, nor implemented a system of internal control to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling $4,000,000 was paid from the Education Stabilization Fund grant funds during the audit period. The single contract was tested and it did not contain the required prevailing wage rate clause. Additionally, certified payrolls were not obtained until after the School Corporation was issued an ESSER Construction Monitoring Report in late 2023. The School Corporation only obtained "sample" of certified payrolls and did not obtain all of the certified payrolls for the work performed within the grant period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Officer and Grant Director will ensure that all future construction contracts contain the prevailing wage rate clause required by the program. Additionally, the Chief Financial Officer will review and approve all certified payrolls and compliance statements submitted by contractors and subcontractors in order to ensure compliance with the program. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382355 (2023-007)

Material Weakness 2023

Lake Ridge Schools

IN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.400 § 200.403

FINDING 2023-007 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425...

FINDING 2023-007 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Akers, Treasurer Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cakers@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: A number of transfer adjustments were made during the audit period from Corporation fund 7923 (ESSER III) to fund 7941 (CARES Ed Stabilization). These transfers were made move payroll disbursement activity for reimbursement. Support for these adjustments was traced to School Corporation’s records to verify the Gross Payroll activity moved for all but one transaction, which totaled $27,824. The supporting documentation for this transaction exceeded the amount of the transaction. Inquiry with School Corporation officials and review of the documentation determined that the amount transferred in this transaction was based on the remaining grant budget amounts in the grant fund 7941. The transaction was not based on actual payroll disbursements as all other transfer adjustments were. The $27,824 without supporting documentation is considered questioned costs. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For future transfers of payroll disbursements, both the Treasurer and Grant Director will ensure that the amount transferred corresponds to actual, documented payroll expenses and not an aggregate salary and/or benefit expenditure. The Chief Financial Officer shall review and approve these transfers to ensure compliance. Anticipated Completion Date: Immediate

View Audit 296034 Questioned Costs: $1

Finding 382353 (2023-006)

Material Weakness 2023

Lake Ridge Schools

IN

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

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Numbe...

FINDING 2023-006 Information on the federal program: Subject: Title I Grants to Local educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Bajmakovich, Principal Calumet HS Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cbajmakovich@lakeridgeschools.net Condition: 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 Annual Report Card, High School Graduation compliance requirement. Context: One individual was involved in collecting the High School student documentation for withdrawal, reviewing the documentation, and removing the student from the cohort. Other review of knowledgeable individual was not documented to ensure all students that were removed from the graduation cohort, had the appropriate documentation to do so. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The high school principal shall review and approve withdrawal documentation collected by the registrar prior to the removal of the student from the graduation cohort. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382351 (2023-005)

Material Weakness 2023

Lake Ridge Schools

IN

Internal Control / Segregation of Duties Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numb...

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numbers: S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Regin Johnson, Title I Director Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net Condition: This finding addresses two issues. First, an effective internal control system 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. Second, The School Corporation has established a process of receiving and reviewing the listing of students from the Private Schools in order to be entered into the Title I application. However, the internal controls were determined not effective since the School Corporation only requested to receive eligible students listing and not enrolled students. Context: The School Corporation has not established a process of review of the Eligibility Summary in the Title I application for the student enrollment and poverty. Real time report October 1 count is used for the eligibility summary in the Title I application. Additionally, the examiner could not determine if the enrolled private school number was correct because the School Corporation did not request the information. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will review and sign off on the Real Time October 1 report to ensure that the student enrollment and poverty numbers reconcile with what is submitted in the Eligibility Summary. Additionally, the Title I Director will solicit both eligible and total enrollment figures from private schools that wish to participate in Title I. Anticipated Completion Date: The Corrective Action will be implemented immediately and completed upon the filing of the next Real Time report and Eligibility Summary.

View Audit 296034

Finding 382343 (2023-004)

Material Weakness 2023

Lake Ridge Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistanc...

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Chris Akers, Treasurer Contact Phone Number and Email Address: (219) 838-1819 cakers@lakeridgeschools.net Condition: 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 monthly sponsor claim for reimbursement. Context: School Food Authority’s (SFA) and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. The Food Service Management Company employed Food Service Director prepared the monthly claim for reimbursement on the Indiana Department of Education Child Nutrition Program website based on meal count reports from the point-of-sale system. The School Corporation did not implement a system of internal control to ensure what was claimed for reimbursement agreed to the point-of-sale system meal count reports. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Before the monthly claim for reimbursement is submitted by the FSMC, the Treasurer will reconcile the claim with the meal count report generated by the point-of-sale system. Anticipated Completion Date: Immediate

View Audit 296034

Finding 382335 (2023-003)

Material Weakness 2023

Lake Ridge Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403 § 200.421 § 200.445 § 200.467

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program fo...

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 awilkerson@lakeridgeschools.net Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles. Context: The School Corporation had not designed or implemented a system of internal control to ensure that program costs incurred by the Food Service Management Company were supported by proper documentation and were allowable. The School Corporation entered into a cost reimbursement contract with a food service management company (FSMC). The FSMC incurred costs and invoiced the School Corporation for reimbursement of the costs. Due to the lack of effective internal controls, the following errors were noted: In a test of 44 items, 22 items (50%) totaling $6,641 did not have proper documentation to support that the expenses were allowable and for the benefit of food service. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In addition to the monthly review of the FSMC invoice and budget, the Chief Financial Officer will review and approve the supporting documentation (invoices, payroll records) provided by the FSMC to ensure that expenses are allowable and for the benefit of food service. Anticipated Completion Date: Immediate

View Audit 296034 Questioned Costs: $1

Finding 382322 (2023-004)

Material Weakness 2023

Board of Education Baltimore County

MD

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

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – ...

Finding Number: 2023-004 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24) 211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22) 221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22) Compliance Requirement: Special Test Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation to support student withdrawals and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BCPS conducts regular training with the school-based staff that maintain this related student documentation. The training will include updates on collecting and maintaining written documentation to meet the requirements for removing a student form the cohort. Name(s) of the contact person(s) responsible for corrective action: Dr. Kim Ferguson, Executive Director of Student Support Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382316 (2023-003)

Significant Deficiency 2023

Board of Education Baltimore County

MD

Eligibility Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – ...

Finding Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: Title I, Part A Assistance Listing: 84.010 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24) 211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22) 221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22) Compliance Requirement: Special Test Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board revises the Student Participation process to include a step that includes matching the student grade level to the corresponding school type and a step to include a second review of the Title I School eligibility address and school type by a second staff member. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BCPS revised their procedures on Title I Equitable Services: Student Participation in early Fall 2023. Revisions outlined below will lessen the risk of potential audit findings in the future: - Revise the Student Participation process to include a step that includes matching the student grade level to the corresponding public school type. - Revise the Student Participation Process to include a second review of the Title I School eligibility address and school type by a second staff member. Name(s) of the contact person(s) responsible for corrective action: Michele Stansbury, Director of Title I Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382308 (2023-002)

Significant Deficiency 2023

Board of Education Baltimore County

MD

Allowable Costs / Cost Principles § 200.303

Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/2...

Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the event an employee is on unexpected extended leave, internal control processes were updated to ensure support staff members collect backup documentation of Pcard purchases and the fiscal supervisor or grant manager will work with fiscal services to reconcile procurement cards and print out summary sheets for review and signature. Name(s) of the contact person(s) responsible for corrective action: Michele Stansbury, Director of Title I Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 296020

Finding 382292 (2023-002)

Significant Deficiency 2023

Contoocook Valley Regional School District

NH

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

Audit Finding Reference: 2023-002 Planned Corrective Action: Review of purchasing policy and federal procurement procedures with grant managers as well as the AP/Grant reporting staff. No purchase will be processed without proper documentation. Name of Contact Person and Completion Date: Brian Cisne...

Audit Finding Reference: 2023-002 Planned Corrective Action: Review of purchasing policy and federal procurement procedures with grant managers as well as the AP/Grant reporting staff. No purchase will be processed without proper documentation. Name of Contact Person and Completion Date: Brian Cisneros (Business Administrator) Anticipated Completion Date – 4/1/24

View Audit 295998 Questioned Costs: $1

Finding 382291 (2023-001)

Significant Deficiency 2023

Contoocook Valley Regional School District

NH

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Audit Finding Reference: 2023-001 Planned Corrective Action: Onboarding procedure is being changed where employees are not able to start working until a signed contract is on file in their HR file. Name of Contact Person and Completion Date: Brian Cisneros (Business Administrator) Michael Hatfield (...

Audit Finding Reference: 2023-001 Planned Corrective Action: Onboarding procedure is being changed where employees are not able to start working until a signed contract is on file in their HR file. Name of Contact Person and Completion Date: Brian Cisneros (Business Administrator) Michael Hatfield (HR Director) Anticipated Completion Date – 4/1/24

View Audit 295998 Questioned Costs: $1

Finding 382278 (2023-001)

Material Weakness 2023

Ascension Health Alliance D/b/a Ascension

MO

Reporting § 200.303 § 200.502 § 200.510

Finding 2023-001 – Reporting Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: Aids Foundation of Chicago...

Finding 2023-001 – Reporting Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: Aids Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Views of responsible officials: The System will enhance its grant management award processes by revising its onboarding procedures and add additional controls to monitor the accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting. Award amounts were changed on the Schedule after management’s review was executed. Management will implement preventive controls to lock down market Schedule templates after management final review. Responsible Official: Rob Madsen, Director of Accounting and Reporting, Grants & Research COE Anticipated completion date: May 31, 2024

View Audit 295994

Finding 382277 (2023-002)

Significant Deficiency 2023

Bowling Green Independent School District

KY

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

In regard to the 2023-002 COVID-19 Education Stabilization Fund, a payroll record failed to be updated to the new rate per the FY2023 salary schedule and, as a result, extraduty performed by this employee was underpaid by $91 throughout the entirety of FY2023. Management had already identified the i...

In regard to the 2023-002 COVID-19 Education Stabilization Fund, a payroll record failed to be updated to the new rate per the FY2023 salary schedule and, as a result, extraduty performed by this employee was underpaid by $91 throughout the entirety of FY2023. Management had already identified the internal control error in August of 2023, identified the root cause of the error, and had implemented both preventative and detective controls as of August 2023. The controls will be adhered to with the strictest of oversight. If the Kentucky Department of Education has questions regarding this plan, please call Shaunna Cornwell

View Audit 295993

Finding 382273 (2023-004)

Material Weakness 2023

Rensselaer Central School Corporation

IN

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

Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entit...

Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion Condition: An effective internal control system 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 – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the corrective action plan which will be implemented by June 30, 2024.

View Audit 295986

Finding 382265 (2023-003)

Material Weakness 2023

Rensselaer Central School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award...

Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative Schools Service has developed a written procedure of documenting expenditures related to the proportionated share earmarking requirement and validate the earmarking requirement to met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The correction action plan has been put into place for the 2023-24 school year. Treasurer, Dawn Claussen and Director of Cooperative School Services, Sarah Claton, will oversee the corrective action plan.

View Audit 295986

Finding 382259 (2023-002)

Material Weakness 2023

Rensselaer Central School Corporation

IN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.303

Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Fede...

Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Two Cooperative School Service employees will check and initial the procurement and Suspension and Debarments documentation. Management of the School Corporation will request supporting documentation from Cooperative School Services to validate procurement and suspension and debarment procedure where performed to satisfy federal regulations. Responsible Party and Timeline for Completion: The corrective action plan has been put into place by both parties. Sarah Claton, Director of Cooperative Schools Services and the Treasurer, Dawn Claussen, will oversee the corrective action plan.

View Audit 295986

Finding 382253 (2023-004)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or de...

FINDING 2023 - 004 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not 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 to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports—a total of six reports. However, the School Corporation failed to submit all six required reports. We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: The transition in the Corporation’s Business Manager position resulted in a failure to properly identify and train the person responsible for submitting final expenditure reports for ESSER grants. The Business Manager will prepare the final expenditure reports, and the Grant Specialist will review and compare the report to the ledger to verify that it is correct. After the review, the Business Manager will submit the final expenditures reports. Additionally, the Business Manager and Grant Specialist have developed a shared calendar that includes all report due dates. Anticipated Completion Date: This corrective action plan was implemented beginning February 2024 and will be implemented moving forward.

View Audit 295985

Finding 382246 (2023-003)

Material Weakness 2023

Plymouth Community School Corporation

IN

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

FINDING 2023 - 003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or de...

FINDING 2023 - 003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance over eligibility and suspension and debarment. We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: As part of month-end procedures and the documents sent to the Business Manager, the Food Services Director will include the list of students newly certified for free or reduced meals from CNPweb, Indiana’s portal for the Child Nutrition Program. The Food Services Director will also include the list of students newly certified for free or reduced meals from NutriKids. The Business Manager will review and verify the list when balancing the food program’s monthly receipts, expenditures, and reimbursements. Before contracts are awarded to vendors, the Food Services Director shall use SAM.gov to verify that vendors have not been suspended or disbarred from contracting with Indiana public schools. The Business Manager shall review and verify that the vendors have not been suspended or disbarred, and once verified, contracts will be awarded. Anticipated Completion Date: The Food Services Director and Business Manager have collaboratively reviewed and modified the month-end procedures to ensure that they prevent, detect, and correct eligibility errors, and the new procedures were implemented for February 2024 and will be used for subsequent months.

View Audit 295985

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