Corrective Action Plans

Finding 1937 (2023-001)

Significant Deficiency 2023

AK

Reporting Subrecipient Monitoring Significant Deficiency § 200.303

Finding 2023-001 Lack of Internal Control over Reporting Name of Contact: Jim Holien Corrective Action Plan: Corrective Action Plan: The district will develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. ...

Finding 2023-001 Lack of Internal Control over Reporting Name of Contact: Jim Holien Corrective Action Plan: Corrective Action Plan: The district will develop FFATA reporting policies and procedures to submit subaward award information through FSRS to ensure compliance with FFATA requirements. Proposed Completion Date: June 30, 2024

View Audit 3360

Finding 1731 (2023-001)

Significant Deficiency 2023

St. Mary's University of San Antonio, Texas

TX

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

To correct this error and ensure all disbursement notifications are sent, the following corrective actions have been implemented. 1. Modified the FA_RZLNDSB_Loan_Process_to_BDM script (weekly job that emails students with loan disbursements within the last 7 days) by removing the logic that used aid...

To correct this error and ensure all disbursement notifications are sent, the following corrective actions have been implemented. 1. Modified the FA_RZLNDSB_Loan_Process_to_BDM script (weekly job that emails students with loan disbursements within the last 7 days) by removing the logic that used aid year to identify which year to use when pulling disbursement records and instead allows all disbursed loans that occurred within the last 7 days, regardless of aid year, to be pulled for notification. 2 Created a new FA_RZLNDSB_Loan_Process_to_BDM_Weekly Error script, that identifies students that do not have an email entry on RUAMAIL form (GURMAIL table) for disbursed loans. This script then generates the email and PDF to be sent to the student.

View Audit 3005

Finding 1728 (2023-002)

Significant Deficiency 2023

St. Mary's University of San Antonio, Texas

TX

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

To eliminate student data input errors, the following corrective actions will be implemented: 1. For TRiO SSS program, the University will automate student data information migration from the existing ERP Banner system into the program database. This database automation/migration will minimize stud...

To eliminate student data input errors, the following corrective actions will be implemented: 1. For TRiO SSS program, the University will automate student data information migration from the existing ERP Banner system into the program database. This database automation/migration will minimize student data entry points that are currently keyed in manually. Each of the TRIO programs will perform additional reviews on the student data. The following procedures will be implemented: For all data entered manually into a program’s database, the data will be reviewed by the person who keyed in the data or a separate individual based on staffing availability. The individual will review the data input for accuracy and sign off indicating the data has been reviewed and is correct. Every month each program’s PD will pull a random sample of 25 student records for error verification. If a single data error is found in a program, then the random sample will be expanded by another 25 student records. If an additional data error is found, all the remaining new student records entered that month will be verified by the PD. All errors identified will be corrected before submission of the APR. For all programs, error message reports and subsequent data revisions will be printed, saved, and reviewed by the PDs to verify accuracy of corrections.

View Audit 3005

Finding 1383 (2023-001)

None 2023

Lake Forest College

IL

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

Finding 2023-001: Perkins Loan Recordkeeping and Retention Finding: Lake Forest College had two instances where the original promissory could not be located for a student who received a Federal Perkins Loan. Cause: Attributing to human error, the College was unsuccessful in finding the original p...

Finding 2023-001: Perkins Loan Recordkeeping and Retention Finding: Lake Forest College had two instances where the original promissory could not be located for a student who received a Federal Perkins Loan. Cause: Attributing to human error, the College was unsuccessful in finding the original promissory notes. Over the course of the past 20 years numerous staff changes, along with transitioning from physical paper MPN’s to electronic copies has resulted in the potential misplacement of these two MPN’s. Corrective Actions Taken or Planned: In 2018 the College transitioned from keeping physical paper copies of MPN’s, to a digital/electronically managed system, hosted through ECSI, a third-party that specializes in managing Perkins loans. The College believes this migration has and will continue to aid the maintenance of Perkins Loan records. Additionally, the College will self-audit its Perkins Loans files to identify which records are maintained onsite vs. electronically through ECSI and determine if there are any other paper records that have been misplaced. Contact Person Responsible: AJ Rodino, Controller arodino@lakeforest.edu Anticipated Completion Date: May 2024

View Audit 2597

Finding 1367 (2023-002)

Significant Deficiency 2023

Knox County

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

Corrective Action Planned: The County has discussed checking the SAM (System for Award Management formerly Excluded Parties Listing System (EPLS), which is maintained by the General Services Administration to ensure vendors are not suspended or debarred before entering a transaction. Anticipated C...

Corrective Action Planned: The County has discussed checking the SAM (System for Award Management formerly Excluded Parties Listing System (EPLS), which is maintained by the General Services Administration to ensure vendors are not suspended or debarred before entering a transaction. Anticipated Completion Date: Ongoing Responsible Party: Krista Nix, Deputy County Clerk

View Audit 2567

Finding 1229 (2023-001)

Significant Deficiency 2023

Southern States Energy Board

GA

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

The Southern States Energy Board respectfully submits the following corrective action plan to incorporate a revision to our FY2023 policies and procedures that would provide additional tracking for the FSRS reporting requirement for subawards. The single finding is identified and discussed below. ...

The Southern States Energy Board respectfully submits the following corrective action plan to incorporate a revision to our FY2023 policies and procedures that would provide additional tracking for the FSRS reporting requirement for subawards. The single finding is identified and discussed below. Finding-Federal Award Finding: 2023 – 001 Improve Controls over Transparency Act Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Federal Agency: U.S. Department of Energy Federal Program Name: Transportation of Transuranic Wastes to the Waste Isolation Pilot Plant Assistance Listing Number: 81.106 Federal Award Identification Number and Year: DE-EM0005215 - 2020 Award Period: 7/01/2020 – 6/30/2025 Budget Period: 07/01/2022-06/30/2023 Explanation of disagreement with audit finding: There is no disagreement with the isolated audit finding. Action taken in response to finding: Management developed a checklist for subaward amendments, prior to the receipt of the finding and upon identification that this report had been overlooked for Budget Period 3 for award DE-EM0005215-2020. Effective immediately, funds obligated to subawardees through subaward agreements, will be reported per the grant requirement to the FSRS and recognized in the FFATA Financial Reporting system. The project identified is a five-year project and the first two Budget Periods were submitted in a timely manner as per the project’s reporting requirements. Due to the nature of this award being incrementally funded, obligations to subawards are continuous throughout each budget period as funds are designated by the prime award. Therefore, the typical quarterly reporting system controls did not trigger management to complete this along with all the other financial and technical quarterly and annual submissions. Therefore, the FY2023 FSRS reporting requirement for this project was overlooked due to unusual timeliness of sub modifications and the workload of the accounting department. With the revised tracking/checklist for each subaward that includes modifications for incremental funding, this will no longer be an issue. Management would also like to note that all other reporting requirements were submitted on time and consistent with financial reporting requirements and that this was an isolated issue within Budget Period 3 for award DE-EM0005215-2020. Name of the contact person responsible for corrective action: Leigh Hawkins, Assistant Director of Business Operations, and Kathy Sammons, Director of Business Operations. Current Status: The planned completion date for corrective action plan is September 30, 2023. All submissions were completed prior to the final audit report completion. Therefore, management considers this issue fully corrected.

View Audit 2296

Finding 1176 (2023-001)

Significant Deficiency 2023

City of Scottsdale, Arizona

AZ

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Complete all PR26 and PR29 for CDBG and CV by November 17, 2023. The Community Assistance Office met with Housing and Urban Development on a weekly basis to reconcile grant funds within the 2020‐2025 Five‐Year Consolidated Action Plan beginning June 9, 2023. Training was provided to Community Assist...

Complete all PR26 and PR29 for CDBG and CV by November 17, 2023. The Community Assistance Office met with Housing and Urban Development on a weekly basis to reconcile grant funds within the 2020‐2025 Five‐Year Consolidated Action Plan beginning June 9, 2023. Training was provided to Community Assistance Office staff through Housing and Urban Development and through Cloudburst Consulting to ensure key staff positions responsible for the completion of these reports is full trained. Develop a Master Calendar for the Community Assistance Office with re‐occurring reports to include the PR26, PR29 and including FFATA to ensure they are completed accurately and timely. PR26 for CDBG and PR29 for CDBG and CDBG‐CV have been submitted as of October 25, 2023, and the HUD concluded weekly meetings with the Scottsdale Community Assistance Office on October 20, 2023. PR26 for CDBG‐CV will be completed and submitted by November 17, 2023. Policies will be updated to reflect 2 CFR 170 requiring the City to submit subaward information through the Federal Funding Accountability and Transparency Act by the end of the month subsequent to an award.

View Audit 2251

Finding 652 (2023-004)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

Subrecipient Monitoring § 200.303

Identifying Number: 2023-004 Finding: The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline...

Identifying Number: 2023-004 Finding: The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Corrective Action Planned: The grant team consisting of Grant Accounting, Resource Development, and the Grant Manager will meet to discuss the proposed sub-recipient’s risk prior to issuing a proposal to the subrecipient. The team will utilize the current version of Moraine Valley’s subrecipient monitoring tool before issuing future subawards and ensure all risk assessment forms are completed. In addition, the College will monitor compliance of spending activity monthly by review of the subrecipient’s invoices sent to the College. This will ensure the subrecipient is monitored throughout the contract. Anticipated Completion Date: June 30, 2024 Responsible Persons: Darren Howard, Manager of Grants Accounting and Compliance Howardd46@morainevalley.edu Theresa Pallanti, Director of Resource Development Pallantit@morainevalley.edu John Sands, Professor and Department Chair – Computer Integrated Technologies Sands@morainevalley.edu

View Audit 1222

Finding 647 (2023-003)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

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

Identifying Number: 2023-003 Finding: For one out of one subawards tested, the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Corrective Action Planned: The Director of Resource Development will collect from each su...

Identifying Number: 2023-003 Finding: For one out of one subawards tested, the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Corrective Action Planned: The Director of Resource Development will collect from each subrecipient all required data needed for the Federal Funding Accountability and Transparency Act and report the information on the FSRS website at the time the subaward is being issued. The Manager of Grants Accounting and Compliance will submit any changes needed to subrecipient data on the FSRS website. Anticipated Completion Date: June 30, 2024 Responsible Persons: Theresa Pallanti, Director of Resource Development Pallantit@morainevalley.edu Darren Howard, Manager of Grants Accounting and Compliance Howardd46@morainevalley.edu

View Audit 1222

Finding 642 (2023-002)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

Subrecipient Monitoring Cash Management Allowable Costs / Cost Principles § 200.303 § 200.305

Identifying Number: 2023-002 Finding: For one out of two subrecipient payments tested, the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Corrective Action Planned: The College will update its subrecipient invoice payment procedure to establish st...

Identifying Number: 2023-002 Finding: For one out of two subrecipient payments tested, the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Corrective Action Planned: The College will update its subrecipient invoice payment procedure to establish stronger internal controls related to tracking subrecipient invoice approval routing. The College will ask each subrecipient to include the Manager of Grants Accounting and Compliance on any requests for reimbursements. If a subrecipient’s invoice meets Moraine Valley’s criteria for performance and fiscal compliance, the Manager of Grants Accounting and Compliance will monitor the approval process to make sure it is properly approved by the grant’s Principal Investigator, the Director of Resource Development, and the Manager of Grants Accounting and Compliance. This additional monitoring will help ensure all subrecipient invoices are paid within 30 days of receipt. If the invoice does not meet the College’s criteria including all proper supporting documentation, the invoice will be returned to the subrecipient for corrections. Anticipated Completion Date: June 30, 2024 Responsible Person: Darren Howard, Manager of Grants Accounting and Compliance Howardd46@morainevalley.edu

View Audit 1222

Finding 636 (2023-005)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

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

Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. ...

Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Corrective Action Planned: Moraine Valley Community College will evaluate all certificates that are standalone programs. Financial Aid will receive a list of these programs and work with IT to identify students enrolled in those programs. Financial Aid will also update our policies and procedures to ensure that all clock to credit hour conversion formulas are being applied and documented per Uniform Grant Guidance (34 CFR 688.8). Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

View Audit 1222

Finding 630 (2023-001)

Significant Deficiency 2023

Moraine Valley Community College District Number 524

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Plann...

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Planned: Enrollment Services staff have created a shared logbook that will track and compile NSC transactions. This logbook is saved to a shared drive with access given to appropriate staff, VP of Student Development and Dean of Enrollment Services. Additionally, any extended gaps in reports being verified, submitted and/or responses by either College staff or NSC staff will be followed up with by the Assistant Dean of Enrollment Services and logged in the NSC logbook for audit purposes. Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

View Audit 1222

Finding 305 (2023-002)

Significant Deficiency 2023

Vermont Student Assistance Corporation

VT

Cash Management Allowable Costs / Cost Principles § 200.303

Recommendation: We recommend management perform a documented review of the federal drawdowns to ensure the benefits reimbursement rate is timely updated in accordance with the requirements of new grant awards. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...

Recommendation: We recommend management perform a documented review of the federal drawdowns to ensure the benefits reimbursement rate is timely updated in accordance with the requirements of new grant awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has directed the Finance Department to review all draw down worksheets to insure that draw down parameters agree with all grant proposal, budget and award documents. Name(s) of the contact person(s) responsible for corrective action: Bruce Hicken, Controller Planned completion date for corrective action plan: No later than October 31, 2024.

View Audit 579

Finding 292 (2023-002)

Significant Deficiency 2023

Dawson County

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

Finding 2023-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Corrective Action Planned: The County has put procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarr...

Finding 2023-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Corrective Action Planned: The County has put procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred. Anticipated Completion Date: August 21, 2023 Responsible Party: Karla Zlatkovsky, County Clerk

View Audit 519

Finding 124 (2023-001)

Significant Deficiency 2023

Regional Food Bank of Oklahoma

OK

Procurement, Suspension & Debarment § 200.303

At the beginning of FY23, the following steps were initiated to ensure board review and approval of all contracts over an annual value of $500,000 per internal financial policy: - The CFO will flag all contracts in excess of the stated threshold and notify the CEO, Executive Assistant, and board Tr...

At the beginning of FY23, the following steps were initiated to ensure board review and approval of all contracts over an annual value of $500,000 per internal financial policy: - The CFO will flag all contracts in excess of the stated threshold and notify the CEO, Executive Assistant, and board Treasurer that an action of the board will be required. - A standing agenda item will be added for the board finance committee to discuss any notable contracts and potential board approval requirements at each meeting. To prevent the case in which a contract is overlooked due to multiple contracts requiring consideration at the same time, the organization will seek out an automated solution such as electronic workflows or contract lifecycle management software to be implemented in FY24 in combination with the previously established actions above.

View Audit 182

Finding 1225676 (2022-007)

Material Weakness 2022

Quileute Tribal School

WA

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

Condition/Context: For 3 of the 3 samples selected for testing, the School did not provide support for review and approval of the monthly bank reconciliations Corrective action taken: Quileute Tribal School will establish effective internal controls for the monthly bank reconciliations and adhere to...

Condition/Context: For 3 of the 3 samples selected for testing, the School did not provide support for review and approval of the monthly bank reconciliations Corrective action taken: Quileute Tribal School will establish effective internal controls for the monthly bank reconciliations and adhere to the internal controls. Person responsible for corrective action: Bob Harmon, Superintendent NOTE: In addition, Quileute Tribal School has engaged an independent CPA firm to assist with account reconciliations and audit readiness to help ensure that financial information is complete, accurate, and properly reported. Implementation Date: July 30, 2026

View Audit 408537

Finding 1225675 (2022-006)

Material Weakness 2022

Quileute Tribal School

WA

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

Condition/Context: For 1 of the 3 samples selected for testing, the school did not provide support for review and approval of the Character Investigations. Corrective action taken: Quileute Tribal School will establish effective internal controls for the Character Investigations compliance requireme...

Condition/Context: For 1 of the 3 samples selected for testing, the school did not provide support for review and approval of the Character Investigations. Corrective action taken: Quileute Tribal School will establish effective internal controls for the Character Investigations compliance requirement and adhere to the internal controls. Person responsible for corrective action: Bob Harmon, Superintendent Implementation Date: July 30, 2026

View Audit 408537

Finding 1225674 (2022-005)

Material Weakness 2022

Quileute Tribal School

WA

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.326

Condition/Context: During testing the following was noted: • 1 of 1 Individually Important Items tested did not have bidding documentation or sole source justification. • 2 of 2 samples tested did not have bidding documentation or sole source justification. Corrective action taken: Quileute Tribal S...

Condition/Context: During testing the following was noted: • 1 of 1 Individually Important Items tested did not have bidding documentation or sole source justification. • 2 of 2 samples tested did not have bidding documentation or sole source justification. Corrective action taken: Quileute Tribal School will follow our written procurement policies and maintain proper supporting documentation. QTS implemented an electronic procurement system. This system provides clarity with the documentation and approval of procurements. The transition from paper to digital formats will provide enhanced internal controls to ensure that procurement transactions are documented and approved. Person responsible for corrective action: Bob Harmon, Superintendent Implementation Date: July 30, 2026

View Audit 408537

Finding 1225673 (2022-004)

Material Weakness 2022

Quileute Tribal School

WA

Equipment & Real Property Management § 200.303 § 200.313

Condition/Context: During the audit we noted that a physical inventory of the school’s property had not been taken and reconciled with the property records within the last two years. Corrective Action Taken: Quileute Tribal School requires a physical inventory of the school’s property at least once ...

Condition/Context: During the audit we noted that a physical inventory of the school’s property had not been taken and reconciled with the property records within the last two years. Corrective Action Taken: Quileute Tribal School requires a physical inventory of the school’s property at least once every two years and reconcile the results of the inventory to the property records. As of the 2025-26 school year, the physical inventory has been completed and is now up to date. Person responsible for corrective action: Bob Harmon, Superintendent Implementation Date: July 30, 2026

View Audit 408537

Finding 1224365 (2022-003)

Material Weakness 2022

Russellville Hospital, Inc.

AL

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303 § 200.512

The hospital will work with an outside consultant with more in-depth understanding of the reporting requirements prior to additional submissions. We are also catching up on the audit submissions and will remain on task with timely submission. Anticipated completion date: 09/30/2026

View Audit 407672

Finding 1223983 (2022-005)

Material Weakness 2022

NEW YORK MORTGAGE COALITION, INC.

NY

Subrecipient Monitoring § 200.303 § 200.332

Management will review and enhance their current procedures to ensure that monitoring procedures are documented and maintained for the subrecipients.

View Audit 407388

Finding 1223980 (2022-002)

Material Weakness 2022

NEW YORK MORTGAGE COALITION, INC.

NY

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

Management will review its policies and procedures to ensure that all quarterly reports and the supporting documentation used to prepare the reports are retained for audit purposes. All the reports will be reviewed and approved by someone other than the preparer prior to submission.

View Audit 407388

Finding 1222694 (2022-002)

Material Weakness 2022

Veterans Transition Center of California

CA

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

Management response and corrective action Personnel responsible for corrective action: Evan Heath, CFO Anticipated completion date for corrective action: April 30, 2026 In response to Finding No. 2022-SA2, management agrees with the finding. Corrective actions will be implemented in subsequent fisca...

Management response and corrective action Personnel responsible for corrective action: Evan Heath, CFO Anticipated completion date for corrective action: April 30, 2026 In response to Finding No. 2022-SA2, management agrees with the finding. Corrective actions will be implemented in subsequent fiscal years. CFDA numbers for new federal awards will be identified, along with the applicable compliance requirements in accordance with the OMB Compliance Supplement (Matrix of Federal Compliance Requirements). Policies and procedures will be established for each applicable compliance requirement and will be communicated to employees responsible for monitoring and ensuring compliance.

View Audit 406305

Finding 1216173 (2022-010)

Material Weakness 2022

Virgin Islands Port Authority

VI

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

The Authority will retain emails between preparers and reviewers for forms that cannot be signed.

View Audit 402648

Finding 1216172 (2022-009)

Material Weakness 2022

Virgin Islands Port Authority

VI

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

The Authority will continue to make progress in meeting required review processes and submission timelines. For the reports where the submission requirement is unclear, the Authority will consult with its federal partner to obtain a determination.

View Audit 402648

Corrective Action Plans

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