Corrective Action Plans

Finding 35456 (2022-026)

Significant Deficiency 2022

VA

Significant Deficiency Internal Control / Segregation of Duties § 200.303

Responsible Contact Person(s): David Portner, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under ?2.2-3705.2 (9.) of the Code of Virginia. Fed...

Responsible Contact Person(s): David Portner, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under ?2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled ?Applicable Management Contacts for Findings and Questioned Costs? to request the corrective action planned from the applicable entity. Estimated Completion Date: 4/30/2023

View Audit 36377

Finding 35447 (2022-089)

Significant Deficiency 2022

Commonwealth of Virginia

VA

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

Responsible Contact Person(s): Lisa Hawkins, Director - Information Technology Business Administration Corrective Action Planned: DSS has 15 applications that are in active oversight, IT Business Administration is in receipt of 14 of the 15 required SOC reports, the final SOC report is due at the e...

Responsible Contact Person(s): Lisa Hawkins, Director - Information Technology Business Administration Corrective Action Planned: DSS has 15 applications that are in active oversight, IT Business Administration is in receipt of 14 of the 15 required SOC reports, the final SOC report is due at the end of Q1 2023. Estimated Completion Date: 2/1/2023

View Audit 36377

Finding 35407 (2022-002)

Material Weakness 2022

National Safety Council

IL

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.320 § 200.326

Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a ...

Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Corrective Actions Taken or Planned: Recently we implemented and communicated a revised Procurement policy that reinstates the requirement of 3 competitive bids if the requisition amount is over $10K. NSC will ensure reinforcement of this policy through multiple layers of review (Legal, Accounting and Executives). Although, the policy was recently reinstated NSC will ensure that it will abide to the policy as much as is possible for all purchases prior to November 1st. In order to facilitate and implement the new procurement policy, NSC will utilize ERP system AVID which helps create approval routings through automated workflows. Accounting, Legal and up to the VP level will ensure and review proper documentation. The CFO and COO will be the final line of review prior to ultimate approval for all purchases above the VP delegation level of authority. The following approvals are required for procurements for items up to: 15K by VP?s of business units 50K by CFO, 100K by COO, Over $100K by CEO. A thorough review of Federal grants will be performed and a new standard operating procedure created, to ensure that all federal ruled are properly being followed as part of the procurement policy. Finally, multiple training sessions and communications to all affected staff will be conducted in order to ensure future compliance at all levels. Anticipated completion date: October 27th 2022 Individual Responsible: Ron Hausner, CFO

View Audit 31952

Finding 35376 (2022-004)

Significant Deficiency 2022

Meeker County

MN

Procurement, Suspension & Debarment § 200.303

SUSPENSION AND DEBARMENT Recommendation: The County should design procedures and controls to ensure compliance with suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The count...

SUSPENSION AND DEBARMENT Recommendation: The County should design procedures and controls to ensure compliance with suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The county has procedures for Suspension and Debarment requirements, the business was checked at the initial purchase but not on a preceding purchase at which time the Sam.gov search had expired. Going forward staff will be made aware to note the expiration date. Name of the contact person responsible for corrective action: Sharon Euerle, County Treasurer Planned completion date for corrective action plan: December 31, 2023

View Audit 26710

Finding 35369 (2022-004)

Significant Deficiency 2022

Edna Martin Christian Center, Inc.

IN

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

2022-004 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in p...

2022-004 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met and the organization?s records are complete to support all reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Grant Manager utilizes fluxx grant management system which documents all submission of grant reports and maintains documentation support. Finance as well has organized a filing system organized by department and then list accounting function as well as report assistance for grants. Name of the contact person responsible for corrective action: Anthony Conley Grant Manager / Compliance Specialist Planned completion date for corrective action plan: 12/31/2023

View Audit 24189

Finding 35342 (2022-002)

Significant Deficiency 2022

Marshfield Clinic Health System, Inc.

WI

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Finding 2022-002 Name of Contact Person: Debra Hansen, Accounting Manager ? Grants and Gifts Corrective Action Plan: Effective May 2023, MMC ? Dickinson converted to the MCHS, Inc accounting systems and its accounting staff fully joined the MCHS, Inc centralized accounting team by August 2023, su...

Finding 2022-002 Name of Contact Person: Debra Hansen, Accounting Manager ? Grants and Gifts Corrective Action Plan: Effective May 2023, MMC ? Dickinson converted to the MCHS, Inc accounting systems and its accounting staff fully joined the MCHS, Inc centralized accounting team by August 2023, such that the MCHS system of controls now extend to MMC-Dickinson. Specifically with these changes, grant accounting duties are also transitioning to the MCHS grant accounting team which extends MCHS system of controls over grant accounting to MMC-Dickinson to ensure accurate and timely completion of the Schedule. Proposed Completion Date: December 31, 2023

View Audit 24187

Finding 35340 (2022-004)

Significant Deficiency 2022

Marshfield Clinic Health System, Inc.

WI

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303

Finding 2022-004 Name of Contact Person: Dan Fischer, Internal Consultant (former Controller) Corrective Action Plan: In early 2022, the team calculating physician compensation costs eligible for reporting in the HRSA portal experienced turnover of staff and thorough review of new staff?s work wa...

Finding 2022-004 Name of Contact Person: Dan Fischer, Internal Consultant (former Controller) Corrective Action Plan: In early 2022, the team calculating physician compensation costs eligible for reporting in the HRSA portal experienced turnover of staff and thorough review of new staff?s work was not completed for several months. Although expenses were overstated in the portal, the grant was not overcharged as lower expenses reported for physician compensation costs would have been replaced by increasing the amount related to additional eligible lost revenues. Management will implement review procedures for eligible physician compensation costs to ensure expenditures to the portal are accurate. Proposed Completion Date: December 31, 2023

View Audit 24187 Questioned Costs: $1

Finding 35212 (2022-002)

Significant Deficiency 2022

Metropolitan Community College Area

NE

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

2022-002 Higher Education Emergency Relief Funds - Student & Institutional - Assistance Listing No. 84.425E & F Recommendation: We recommend the College establish a system to retain documents to support the accuracy of the reports. Explanation of disagreement with audit finding: There is no disagr...

2022-002 Higher Education Emergency Relief Funds - Student & Institutional - Assistance Listing No. 84.425E & F Recommendation: We recommend the College establish a system to retain documents to support the accuracy of the reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Copies of archived webpages will be saved before updating webpage with new data. Name(s) of the contact person(s) responsible for corrective action: Brenda Schumacher Planned completion date for corrective action plan: Prior to Fall 2023

View Audit 24381

Finding 35167 (2022-006)

Significant Deficiency 2022

City of Woonsocket

RI

Equipment & Real Property Management Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Name of Contact Person: Alyssa McDermott Corrective Action Plan: The City of Woonsocket has experienced significant turnover over the past years. With the division of housing and community development fully staffed, a thorough review of project files has occurred. Properties that were funded throu...

Name of Contact Person: Alyssa McDermott Corrective Action Plan: The City of Woonsocket has experienced significant turnover over the past years. With the division of housing and community development fully staffed, a thorough review of project files has occurred. Properties that were funded through CDBG or HOME Entitlement funds are fully documented. Properties that are not owned by the City of Woonsocket or received funding from CDBG or HOME entitlement funds are not documented in this office. Properties owned by the Redevelopment Agency of Woonsocket, Woonsocket Housing Authority, or properties that HUD have foreclosed on are not documented by this office. Proposed Completion Date: 06/30/2023

View Audit 29946

Finding 35153 (2022-002)

Material Weakness 2022

City of Seymour

IN

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

Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of thi...

Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of this report is auto populated by the website. My responsibility was to confirm the data, respond if we are using the Standard Allowance, and a brief description of our plan to distribute. Moving forward, all US Treasury reports will be reviewed by either the Mayor or 2nd Deputy, and signed off on once submitted by the Clerk/Treasurer. A copy will be maintained with initials/signatures in the Treasury File in the Clerk/Treasure?s office. Anticipated Completion Date 7/2023

View Audit 38024

Finding 35152 (2022-001)

Material Weakness 2022

City of Seymour

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2022-001 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. Moving forward, the governing body, appointed officials, and elected officials will implement during the interview and...

Finding 2022-001 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. Moving forward, the governing body, appointed officials, and elected officials will implement during the interview and application process a policy to ensure contractors and subrecipients are eligible (not suspended, debarred, or otherwise excluded) to enter into an agreement, contract, or subaward with the City. The question of eligibility will be asked of all applicants. Anticipated Completion Date: 7/1/23

View Audit 38024

Finding 35139 (2022-001)

Material Weakness 2022

Devils Lake Public School District No. 1

ND

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

2022-001 COVID 19 - EDUCATION STABILIZATION FUND ? INTERNAL CONTROLS AND WAGE RATE REQUIREMENTS ? ALN 84.425D ? MATERIAL WEAKNESS AND MATERIAL NON-COMPLIANCE Condition: Devils Lake Public School District did not comply with the wage rate requirements applicable to the Elementary and Secondary Scho...

2022-001 COVID 19 - EDUCATION STABILIZATION FUND ? INTERNAL CONTROLS AND WAGE RATE REQUIREMENTS ? ALN 84.425D ? MATERIAL WEAKNESS AND MATERIAL NON-COMPLIANCE Condition: Devils Lake Public School District did not comply with the wage rate requirements applicable to the Elementary and Secondary School Emergency Relief Fund (ESSER) funding received for the renovation of a current building into a childcare and preschool center. Further, Devils Lake Public School District did not establish and maintain effective internal controls to ensure certified payrolls are received from the contractors. Corrective Action Plan: We agree, Devils Lake Public Schools will make sure to check with North Dakota Department of Public Instruction and correct federal departments to insure that we are following the proper guidelines and requirements of the grant. Anticipated Completion Date:. We will start implementation on 7/1/2023 and continue with this moving forward.

View Audit 37113

Finding 35138 (2022-002)

Material Weakness 2022

Devils Lake Public School District No. 1

ND

Subrecipient Monitoring § 200.303 § 200.332

2022-002 STRIVING READERS COMPREHENSIVE LITERACY/COMPREHENSIVE LITERACY STATE DEVELOPMENT ? SUBRECIPIENT MONITORING ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 84.371 ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE Condition: Devils Lake Public School District did not pre...

2022-002 STRIVING READERS COMPREHENSIVE LITERACY/COMPREHENSIVE LITERACY STATE DEVELOPMENT ? SUBRECIPIENT MONITORING ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 84.371 ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE Condition: Devils Lake Public School District did not prepare subrecipient grant agreements that included the elements as outlined in 2 CFR 200.332(a) for the Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development programs. In addition, Devils Lake Public School District did not have procedures in place to ensure subrecipient grant agreements were prepared for all subrecipients and included all the required elements. Corrective Action Plan: We agree, Devils Lake Public School will make sure to sit down with any subrecipients and review all the requirements of the grant for their particular allocation. Anticipated Completion Date: We will start implementation on 7/1/2023 and continue with this moving forward.

View Audit 37113

Finding 35121 (2022-001)

Significant Deficiency 2022

The Institute of World Politics

DC

Student Financial Aid Allowable Costs / Cost Principles Cash Management § 200.303

Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management ...

Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management agrees with the recommended corrective action for which the Institute immediately began to remediate. This relates to the National Student Loan Data System (NSLDS) site modernization resulting in NSLDS functionality/operational pauses that included the data flow from National Student Clearinghouse (NSC) to NSLDS. This issue has been resolved. The Institute has established a procedure to ensure this does not happen again. It should also be noted that as of December 2022, the Director of Financial Aid and Registrar have implemented procedures and controls to ensure that all required reporting to the NSLDS is performed accurately and in a timely manner. Each month?s enrollment data submission to National Student Clearinghouse by the Registrar will be reviewed by the Director of Financial Aid to verify the consistency of the data in NSLDS; The Director of Admissions and the Registrar will review submission of the 10 business days after the original submission and on the 14th of each month prior to the submission of the next batch of enrollment data to the National Student Clearinghouse. This will allow IWP to correct any inaccurate reporting and verify timely submissions to both systems, providing a preventive control in addition to the resolution of the NSLDS functionality pause.

View Audit 30178

Finding 35110 (2022-013)

Material Weakness 2022

Our Katahdin and Subsidiary

ME

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

Our Katahdin will implement a process where their employee enters all payments due, and the Board Treasurer will review and approve those payments. Because of limited staff, both of these individuals will be authorized signers, which is partially mitigated through the dual control over reconciliatio...

Our Katahdin will implement a process where their employee enters all payments due, and the Board Treasurer will review and approve those payments. Because of limited staff, both of these individuals will be authorized signers, which is partially mitigated through the dual control over reconciliations and review. Our Katahdin will also assign a board member without account signing authority to perform a monthly activity review. Responsible official: Nancy DeWitt, Treasurer (207) 618-9187 Expected completion date: October 31, 2023

View Audit 33040

Finding 34938 (2022-002)

Material Weakness 2022

Nexus Family Healing

MN

Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.4...

Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Summary: Responsible Individuals: Corrective Action Plan: The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost was not subjected to formal review or approval by a separate individual outside of the preparer. Dr. Kenneth D. Varble ? Corporate Controller When summarizing lost revenue for submission, a secondary review of the summary spreadsheet prepared from the underlying supporting records will be documented. This policy will reflect the procedures needed for proper internal controls to provide assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Anticipated Completion Date: December 31, 2023

View Audit 35230

Finding 34936 (2022-001)

Material Weakness 2022

Lebanon Community School Corporation

IN

Questioned Costs Internal Control / Segregation of Duties Cash Management § 200.303

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: 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 grant agreement and the eligibility compliance...

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: 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 grant agreement and the eligibility compliance requirements that are performed by the Special Education Cooperative on behalf of the School Corporation. Context: The School Corporation participates in a Special Education Co-op. In 2015, the Co-op provided an avenue through a third-party company, for the member school districts to obtain reimbursement for Medicaid services. It was discovered in 2021 that the yearly parental disclosure statements had not been completed for Medicaid eligibility compliance. Due to this oversight, each member school has had to voi transactions through the third-party company and pay back the amount of these transactions from August 9, 2015 through April 23, 2021. The School Corporation?s amount owed was $481,276 for the period identified during 2015-2021. The School Corporation completed a Voluntary Self-Disclosure of Provider of Overpayments Packet through the Indiana Family & Social Services Administration?s Office of Medicaid Policy and Planning Office to reimburse the amounts owed. The amount related to this period July 1, 2020 through June 30, 2022 was indeterminable. The full amount was paid back prior to June 30, 2021. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Parental disclosure statements are completed annually for Medicaid eligibility compliance. This has already been implemented. Responsible Party and Timeline for Completion: Madeline Sandberg, Director of BCNWH Joint Services, 7/1/2021

View Audit 32733 Questioned Costs: $1

Finding 34911 (2022-006)

Material Weakness 2022

Lebanon Community School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.318

FINDING 2022-006 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Audit Findings: Material Weakness, Adverse Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to th...

FINDING 2022-006 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Audit Findings: Material Weakness, Adverse 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 equipment requirements of the Procurement and Suspension and Debarment compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify whether purchases were made by the Cooperative with federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34910 (2022-005)

Material Weakness 2022

Lebanon Community School Corporation

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.309 § 200.343 § 200.461

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: 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 grant agreement and the equipment ...

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: 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 grant agreement and the equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34909 (2022-004)

Material Weakness 2022

Lebanon Community School Corporation

IN

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

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: 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 grant agreement and the equipment r...

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: 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 grant agreement and the equipment requirements of the Equipment and Real Property Management compliance requirement. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it indeterminable whether equipment purchases were made by the Cooperative with federal funds, or to identify equipment expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds was properly recorded and maintained in the School Corporation's equipment records. The Cooperative also did not maintain records for the disposition of equipment purchased with federal grant funds. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34908 (2022-003)

Material Weakness 2022

Lebanon Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.430

FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements relate...

FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: 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 grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34904 (2022-002)

Material Weakness 2022

Lebanon Community School Corporation

IN

Procurement, Suspension & Debarment School Nutrition Programs § 200.303

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspen...

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: The School Corporation contracts with a food service management company for the majority of food costs, labor costs, and operational costs, however in some cases the School Corporation will handle their own additional minor procurements outside of the food service management company. During the audit period, the School Corporation made one purchase between $10,000 and $150,000 which fell under the small purchase method for federal and state procurement regulations and was charged to Fund 0800 ? School Lunch Fund. For that purchase, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. The transaction was incurred in July 2021 in the amount of $21,668. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quotes will be sought for all purchases that fall within the small purchase threshold according to federal and state procurement regulations. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2022

View Audit 32733

Finding 34902 (2022-003)

Material Weakness 2022

Garrett-Keyser-Butler Community School District

IN

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

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description ...

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls to make sure all timesheets have been received and signed by supervisors prior to payroll being completed. Anticipated Completion Date: Garrett-Keyser-Butler Community School District is no longer the LEA for the Head Start Program. However, this will be implemented immediately at the corporation.

View Audit 32731

Finding 34898 (2022-002)

Significant Deficiency 2022

Garrett-Keyser-Butler Community School District

IN

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

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Bu...

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

View Audit 32731

Finding 34897 (2022-001)

Significant Deficiency 2022

Emergycare Inc.

PA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Finding 2022-001: Federal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to est...

Finding 2022-001: Federal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the federal award to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Recipients of Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and Context: The Organization did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. The Organization inadvertently excluded from their reporting certain amounts attributable to implicit price concessions. The adjustment needed within the PRF report to correct the exclusion of implicit price concessions decreased cumulative total year over year lost revenues from $2,727,305 to $2,471,405 on total cumulative reported on distributions of PRF funding of $1,161,130. Corrective Action Plan: EmergyCare Inc. agrees with the finding and has implemented controls sufficient to identify and correct errors prior to the completion of PRF reporting, which will include a review of the most recent guidance published by HRSA as well as a separate formal review and approval of the information being reported by an individual with an appropriate amount of knowledge surrounding the Provider Relief Fund. EmergyCare Inc. will update revenue the amounts reported in the Provider Relief Fund reporting portal during the next available reporting period. Contact Person: Abigail Johnson, Director of Finance 1926 Peach Street Erie, PA 16502 Expected Date of Resolution: The policies are expected to be updated effective March 1, 2023. The Provider Relief Fund reporting portal will be updated in the next available reporting period which ends March 31, 2023.

View Audit 32339

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