Corrective Action Plans

Finding 565436 (2024-014)

Significant Deficiency 2024

MA

Subrecipient Monitoring § 200.303 § 200.332

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-014 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that required information is included in its subawards. Action taken in ...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-014 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that required information is included in its subawards. Action taken in response to finding: The MassHire Department of Career Services (MHDCS) has reviewed, enhanced, and revised its documented internal controls and procedures to ensure that required award information is included and provided to its sub awardees through its formal submitted documentation. Name(s) of the contact person(s) responsible for corrective action: Michael Williams- Director of MHDCS Field Management & Oversight Planned completion date for corrective action plan: MHDCS partially implemented the above referenced internal control procedures on 12/30/22, prior to the end of Fiscal Year 2023. This procedure was fully implemented on 7/1/23 (the beginning of Fiscal Year ’24). MHDCS continues the process currently in FY 2025. MHDCS has revised all Financial/Fiscal related documentation (i.e., Budget Sheets, Contracts) for sub awardees to include the Federal Award Identification Number (FAIN) identifier, Federal award date as well as the Unique Entity Identifier (UEI) and the documented internal procedures as recommended through this audit finding. The FAIN and UEI numbers are consistently included on all budget sheets, contracts and contract modifications submitted to the EOLWD Budget and Finance department for processing and submission to each local entity or sub awardee.

View Audit 359283

Finding 565433 (2024-013)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Allowable Costs / Cost Principles § 200.303 § 200.430

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-013 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to th...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-013 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Action taken in response to finding: EOLWD Finance continues to address time and effort reporting compliance through targeted training and system enhancements. Ongoing training is provided for new staff to ensure they correctly enter combo codes that align with the activities performed. To strengthen oversight, a custom report has been developed to identify employees missing combo codes each week, allowing Finance staff to proactively follow up and ensure proper time charging weekly. Looking ahead, Finance will collaborate with departments in the upcoming fiscal year to update labor distribution profiles, ensuring that employees are defaulted to the correct combo codes for accurate and efficient time reporting. Name(s) of the contact person(s) responsible for corrective action: Sarah Shannon, Ken Luke, Anna Yong, Vina Yung Planned completion date for corrective action plan: 12/31/2025

View Audit 359283

Finding 565430 (2024-012)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-012 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are allowable, approved, and accounted for properly...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-012 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are allowable, approved, and accounted for properly in the Commonwealth’s accounting system. Action taken in response to finding: During the review, supporting documentation for certain expenditure adjustments (EX) could not be located. Since then, the department has taken steps to strengthen internal controls and improve documentation practices. Under new management, enhanced oversight procedures have been implemented, requiring all expenditure adjustments to undergo review and approval by multiple levels of management and staff. To ensure transparency and audit readiness, all supporting documentation is now stored in a centralized and accessible SharePoint repository. Additionally, revised procedures are being integrated into the department's standard operating protocols to support ongoing monitoring. These updates are designed to ensure that all future adjustments are properly documented, allowable under applicable federal regulations, and readily available for review. Name(s) of the contact person(s) responsible for corrective action: Ken Luke Planned completion date for corrective action plan: 9/30/2025

View Audit 359283

Finding 565427 (2024-011)

Material Weakness 2024

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-011 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should review its procedures to ensure that ETA 9130 reports are accurate and agree with supporting documentation. We further recommend that intern...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-011 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should review its procedures to ensure that ETA 9130 reports are accurate and agree with supporting documentation. We further recommend that internal controls are enhanced to ensure that reports are reviewed for accuracy prior to submission. Action taken in response to finding: This issue occurred during a period when the preparation and submission of the ETA 9130 reports were handled by a single staff member without peer review. The lack of internal checks and collaborative review contributed to the inaccuracies. With new management and restructured team now in place, we have implemented and strengthened review processes. Moving forward, ETA 9130 reports will be jointly reviewed by Finance and program staff before submission and certification. Supporting documentation will be cross-checked for accuracy and completeness, and all relevant files will be maintained in a centralized, shared folder to ensure transparency and accountability. This multi-layered review and documentation process will be incorporated into standard quarterly reporting procedures to prevent future discrepancies and ensure federal reporting integrity. Name(s) of the contact person(s) responsible for corrective action: Sarah Shannon, Ken Luke, Vina Yung Planned completion date for corrective action plan: 8/30/2025

View Audit 359283

Finding 565424 (2024-010)

Material Weakness 2024

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-010 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should implement procedures and internal controls to ensure that all required subawards are reviewed, approved and subsequently reported timely to ...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-010 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: The Department should implement procedures and internal controls to ensure that all required subawards are reviewed, approved and subsequently reported timely to FSRS no later than the end of the month following the month of issuance. Documentation of implemented controls should be readily available for auditors. Action taken in response to finding: EOLWD Finance has finalized a Standard Operating Procedure (SOP) to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. FFATA reporting as of FY 2025 has been transitioned to SAM.gov, providing a more streamlined and user-friendly platform for managing and tracking subaward reporting. To support timely submissions, a calendar reminder has been implemented to prompt monthly checks of reporting activity. The next phase of implementation will focus on expanding staff training to ensure more team members are equipped to complete FFATA reporting tasks accurately and efficiently. Ongoing monitoring will continue to ensure reporting remains timely and accurate, with periodic reviews conducted to assess performance and identify any needed updates to the SOP. Name(s) of the contact person(s) responsible for corrective action: Sarah Shannon, Ken Luke Planned completion date for corrective action plan: 9/30/2025

View Audit 359283

Finding 565422 (2024-006)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Special Tests & Provisions Eligibility Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT Unemployment Insurance, COVID-19 – Unemployment Insurance - Assistance Listing No. 17.225 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that RESEA program requirements are met. We further recommend...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT Unemployment Insurance, COVID-19 – Unemployment Insurance - Assistance Listing No. 17.225 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that RESEA program requirements are met. We further recommend the Department develop a formal process to review quarterly performance reports for accuracy prior to submission. Action taken in response to finding: MDUA’s legacy system had a known issue with maintaining documents. In some instances, the legacy system did not keep a copy of correspondence. In May 2025, MDUA implemented a new, modernized UI administrative system known as EMT. During the integration process, memorializing documents the system generated was a priority. Now with a fully implemented system, all documents will be saved. In addition, the RESEA program has a required reporting standard administered through the federal SUN system. Although MDUA has an established process for completing this work, MDUA does not have an audit trail to show it was completed. Moving forward, MDUA will enhance this procedure to ensure MDUA has documentation to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: John Saulnier, Director of Benefit Performance Planned completion date for corrective action plan: 9/30/2025

View Audit 359283

Finding 565420 (2024-005)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-005 Unemployment Insurance, COVID-19 – Unemployment Insurance - Assistance Listing No. 17.225 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that BAM case investigations are completed timely in...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-005 Unemployment Insurance, COVID-19 – Unemployment Insurance - Assistance Listing No. 17.225 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that BAM case investigations are completed timely in accordance with the time limits established in the ET Handbook No. 395. Action taken in response to finding: Analysis showed that BAM Investigators spend a minimum of 20% of work hours devoted to clerical tasks necessary to develop an investigatory file. As part of MDUA’s modernized UI system, the new system features an electronic BAM casefile which should reduce clerical work 5% or below, and, in turn, allow additional time to investigate and complete case work. BAM has always relied on postal mail as a primary methodology to contact interested persons. By integrating the BAM casefile into the UI system, investigators can send questionnaires and notifications to interested persons through the system. In turn, interested persons may complete questionnaires and upload information into the system thereby reducing time between issuance of documents and response. Name(s) of the contact person(s) responsible for corrective action: Susan Saulnier, Director of UI Performs Planned completion date for corrective action plan: June 2026 This statistic is compiled for a year of data. Because BAM was not an on-line program, all cases prior to May 18, 2025 remain in the old format, and, therefore were not placed in the new system. As of May 19, 2025 and moving forward, all BAM cases will be held in the electronic case file. By June 2026, MDUA will have a year of data with improvements to BAM investigative methodology.

View Audit 359283

Finding 565418 (2024-009)

Material Weakness 2024

Commonwealth of Massachusetts

MA

Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-009 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: We recommend the Department implement its corrective action plan from the prior year. Procedures and internal controls over reporting should be sufficient t...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-009 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: We recommend the Department implement its corrective action plan from the prior year. Procedures and internal controls over reporting should be sufficient to ensure that reports are accurate and supported by documentation. Action taken in response to finding: Finance has developed a new Expenditure Detail Report (EDR) with their internal Finance Data Mart. This new report is designed to mirror the structure of federal quarter filings and improve the traceability between reported expenditures and source documentation. Beginning in FY26, phase codes associated with federal grant activity will be further disaggregated and mapped in MMARS screen BQ87 (Federal Grant Phase Budget Status). This enhancement will improve the accuracy and clarity of budget-to-actual comparisons by providing a clearer breakout of expenditures by phase. It will also strengthen internal controls and facilitate better alignment between MMARS, Finance Data Mart, and federal reporting requirements. Finance and DCS will continue to conduct joint reviews of the EDR each quarter to ensure data consistency across systems and compliance with federal reporting standards. Name(s) of the contact person(s) responsible for corrective action: Sarah Shannon, Ken Luke, Vina Yung, Sacha Stadhard Planned completion date for corrective action plan: 12/31/2025

View Audit 359283

Finding 565416 (2024-008)

None 2024

Commonwealth of Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-008 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: We recommend the Department develop and document internal controls over reporting earmarking requirements to ensure that reports are accurate and that earma...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-008 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: We recommend the Department develop and document internal controls over reporting earmarking requirements to ensure that reports are accurate and that earmarking requirements are met. Action taken in response to finding: EOLWD Finance has developed a new Expenditure Detail Report (EDR) within their internal Finance Data Mart. This new report is designed to mirror the structure of federal quarter filings and improve the traceability between reported expenditures and source documentation. Beginning in FY26, phase codes associated with federal grant activity will be further disaggregated and mapped in MMARS screen BQ87 (Federal Grant Phase Budget Status). This enhancement will improve the accuracy and clarity of budget-to-actual comparisons by providing a clearer breakout of expenditures by phase. It will also strengthen internal controls and facilitate better alignment between MMARS, Finance Data Mart, and federal reporting requirements. Finance and DCS will continue to conduct joint reviews of the EDR each quarter to ensure data consistency across systems and compliance with federal reporting standards. Name(s) of the contact person(s) responsible for corrective action: Dave Manning and Ken Luke Planned completion date for corrective action plan: 12/31/2025

View Audit 359283

Finding 565414 (2024-007)

Material Weakness 2024

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-007 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: The Department should implement procedures and internal controls to ensure that all required subawards are reviewed, approved, and subsequently timely submi...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-007 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: The Department should implement procedures and internal controls to ensure that all required subawards are reviewed, approved, and subsequently timely submitted to FSRS no later than the end of the month following the month of issuance. Documentation of implemented controls should be readily available for auditors. Action taken in response to finding: EOLWD Finance needs to update the Standard Operating Procedure (SOP) to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. FFATA reporting as of FY 2025 has been transitioned to SAM.gov, providing a more streamlined and user-friendly platform for managing and tracking subaward reporting. To support timely submissions, a calendar reminder has been implemented to prompt monthly checks of reporting activity. The next phase of implementation will focus on expanding staff training to ensure more team members are equipped to complete FFATA reporting tasks accurately and by establishing a more accurate subaward report. Ongoing monitoring will continue to ensure reporting remains timely and accurate, with periodic reviews conducted to assess performance and identify any needed updates to the SOP. Name(s) of the contact person(s) responsible for corrective action: Sarah Shannon, Ken Luke Planned completion date for corrective action plan: 9/30/2025

View Audit 359283

Finding 565412 (2024-004)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Subrecipient Monitoring § 200.303 § 200.332

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2024-004 Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation: The Department should review and enhance internal controls and procedures to ensure that required information is obtained prior to entering into a subrecipient ...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2024-004 Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation: The Department should review and enhance internal controls and procedures to ensure that required information is obtained prior to entering into a subrecipient agreement. Action taken in response to finding: The Office for Food and Nutrition Programs (FNP) has confirmed the 19 CACFP subrecipients (out of 327) that either do not have a UEI or have one but has not registered it in SAM.gov. FNP will notify the subrecipients that their federal reimbursements will be put on hold until they take action and provide DESE with sufficient documentation that they have completed the tasks. Name(s) of the contact person(s) responsible for corrective action: Rob Leshin, Director, Food and Nutrition Programs Planned completion date for corrective action plan: July 15, 2025

View Audit 359283

Finding 565411 (2024-003)

Material Weakness 2024

Commonwealth of Massachusetts

MA

Special Tests & Provisions Procurement, Suspension & Debarment Eligibility § 200.303

DEPARTMENT OF TRANSITIONAL ASSISTANCE 2024-003 SNAP Cluster - Assistance Listing No. 10.551, 10.561 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that documentation for EBT reconciliations is maintained in accordance with the federal program require...

DEPARTMENT OF TRANSITIONAL ASSISTANCE 2024-003 SNAP Cluster - Assistance Listing No. 10.551, 10.561 Recommendation: We recommend the Department review and enhance procedures and controls to ensure that documentation for EBT reconciliations is maintained in accordance with the federal program requirements. Action taken in response to finding: Starting July 2025, the Accounting Director (or Deputy Accounting Director when hired) will sign and date the reconciliation documentation (and retain) when reviews are performed. The standard operating procedures will be clarified that preparer and reviewer typing their names and date within the reconciliation documentation is an acceptable form of sign-off upon completion of the reconciliations and reviews. Name(s) of the contact person(s) responsible for corrective action: Keivon Spencer, Director of Accounting | DTA Finance Planned completion date for corrective action plan: June 30, 2025 and forward – Sign and date reconciliation reviews October 30, 2025 – Standard operating procedures

View Audit 359283

Finding 565358 (2024-001)

Significant Deficiency 2024

Community Loan Fund of New Jersey, Inc.

NJ

Reporting Internal Control / Segregation of Duties § 200.303 § 200.502

Corrective Action Plan Year Ended September 30, 2024 Findings Related to Federal Awards 2024-001 SEFA Control Deficiency Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Program (ALN 21.033) Federal Gra...

Corrective Action Plan Year Ended September 30, 2024 Findings Related to Federal Awards 2024-001 SEFA Control Deficiency Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Program (ALN 21.033) Federal Grant Numbers: 22ERP061418 Contact Person: Steven Kaczynski, Controller; skaczynski@newjerseycommunitycapital.org; 732-640-2061 Corrective Action: As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied. Anticipated Completion Date: September 30, 2025

View Audit 359200

Finding 565338 (2024-002)

Significant Deficiency 2024

Cook County, Illinios

IL

Subrecipient Monitoring § 200.303 § 200.332 § 200.339 § 200.521

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Rev...

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Review and Clarification: The department will review and revise its internal policies and procedures to align more closely with federal guidelines and institutional expectations. Clear protocols for sub-recipient monitoring activities will be disseminated to relevant personnel. 3. Ongoing Oversight: Upon implementation, the Department will conduct periodic reviews of sub-recipient monitoring activities to ensure compliance and for purposes of identifying any areas requiring further improvement. These actions are intended to strengthen compliance efforts and prevent similar issues in the future. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 - Nicole Kramer, Director of Programs and Development, nicole.kramer@cookcountysao.org, 312.603.1879 The department plans on completing the above corrective action on 8/30/2025

View Audit 359160

Finding 565180 (2024-001)

Significant Deficiency 2024

University of Guam

GU

Subrecipient Monitoring Special Tests & Provisions § 200.303

Finding NO. 2024-001 Special Tests and Provisions – Gramm-Leach-Bliley Act–Student Information Security View of the University of Guam and Corrective Action Plan: The University’s Office of Information Technology is developing a written Information Security Program that complies with the requireme...

Finding NO. 2024-001 Special Tests and Provisions – Gramm-Leach-Bliley Act–Student Information Security View of the University of Guam and Corrective Action Plan: The University’s Office of Information Technology is developing a written Information Security Program that complies with the requirements of the Gramm-Leach-Biley Act applicable to universities. The Information Security Program will be reviewed annually to ensure minimum requirements are met. Name of Contact Person: Vincent Dela Cruz, Chief Information Officer Proposed Completion date: January 30, 2026

View Audit 359091

Finding 565159 (2024-002)

Significant Deficiency 2024

Kaskaskia Community College District #501

IL

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

Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members ha...

Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members have been trained on the updated procedure for processing student course withdrawals. The Office of Institutional Research has reviewed and updated the procedures used to generate reports sent to National Student Clearinghouse. IR staff members will ensure that the last date of attendance is reported for student course withdrawals. The office of Institutional Research has contacted National Student Clearinghouse for guidance on the enrollment reports needed to ensure that student enrollment is reported to NSLDS accurately and timely. An additional enrollment report will now be sent to National Student Clearinghouse for reporting graduated students. This will ensure that students that have graduated are reported as no longer enrolled within the required reporting timeframe.

View Audit 359072

Finding 565155 (2024-001)

Significant Deficiency 2024

Kaskaskia Community College District #501

IL

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

Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 t...

Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 term has already been built in Colleague to reflect a five day fall break. The Fall 2023 term was built in Colleague by the previous Director of Financial Aid. The current Director of Financial Aid has recognized a five-day break when building the fall terms in Colleague and will continue this practice for future terms. In following our recently updated R2T4 process, all Financial Aid staff members have been trained and are able to perform R2T4 calculations. R2T4 calculations for the 2024-2025 academic year have been performed by Financial Aid staff and have been reviewed for accuracy and approved by the Director of Financial Aid.

View Audit 359072

Finding 565127 (2024-004)

Material Weakness 2024

West Virginia School of Osteopathic Medicine Clinic, Inc. D/b/a Robert C. Byrd Clinic

WV

Allowable Costs / Cost Principles Material Weakness Period of Performance § 200.303

Finding 2024-004 Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Activities Allow...

Finding 2024-004 Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Finding Summary: Some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. The Clinic also calculated their indirect cost rate based on the total grant budget and claimed an equal amount of indirect costs per month instead of calculating the indirect cost rate per direct expenditures for each month. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we have implemented procedures to retain expenditure listings and other support for federal awards as well as the related review. The Clinic began retaining expense reconciliations for all Grants. Anticipated Completion Date: July 1, 2024

View Audit 359059

Finding 565126 (2024-003)

Material Weakness 2024

West Virginia School of Osteopathic Medicine Clinic, Inc. D/b/a Robert C. Byrd Clinic

WV

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

Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Cash Management Finding Summary: ...

Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Cash Management Finding Summary: The cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we have implemented procedures to understand program requirements related to cash draws. The Clinic began requesting funds only for expenditures already incurred or that would be paid within three days. Anticipated Completion Date: Ongoing

View Audit 359059

Finding 565013 (2024-001)

Significant Deficiency 2024

City of Daytona Beach, Florida

FL

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.303

2024-001 GRANT REPORTING U.S. Department of Treasury ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds Contract No. 23.saa.900.46 (2023) Passed through the Florida Department of State 2024 Funding Repeat Finding Criteria: 2 CFR 200.303 requires non-federal entities to establish and main...

2024-001 GRANT REPORTING U.S. Department of Treasury ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds Contract No. 23.saa.900.46 (2023) Passed through the Florida Department of State 2024 Funding Repeat Finding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports and reimbursement requests should be subject to independent review for the full fiscal year to verify completeness, validity and timeliness of submission. The grant agreement requires quarterly progress reports to be filed with the pass through entity, Florida Department of State. Condition: Review of quarterly reports was not always documented by City officials before submittal by their third party consultant. Cause of condition: The department at the City that is responsible for managing the grant did not originally have a process in place to document their review of progress reports submitted to the Florida Department of State by their third party consultant. Potential effect of condition: Reports submitted to the Florida Department of State may be incomplete, include errors, or be submitted late. Perspective: After this condition was reported as a finding for the fiscal year ending September 30, 2023, the City’s department that is responsible for managing the grant implemented a review process, but it was not in place for the full fiscal year 2024. Questioned costs: None. Recommendation: The City’s department responsible for the grant should continue to perform the review process that was put in place late in fiscal year 2024. Management’s Response: The City updated its control process to ensure that reports prepared by thirdparty consultant are reviewed by City staff prior to being submitted to the grantor. Responsible Parties: Natalia Eckroth, CFO and Christine Aiken, Assistant Finance Director. Anticipated Completion: December 31, 2024.

View Audit 358881

Finding 564744 (2024-002)

Material Weakness 2024

City of Oxford, Mississippi

MS

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

2024-002 a. Contact person responsible for corrective action: Police Chief Jeff McCutchen and Kim Richardson b. Description of corrective action to be taken: The City has already implemented additional controls for verification of attendance lodging and travel reimbursements. c. Anticipated com...

2024-002 a. Contact person responsible for corrective action: Police Chief Jeff McCutchen and Kim Richardson b. Description of corrective action to be taken: The City has already implemented additional controls for verification of attendance lodging and travel reimbursements. c. Anticipated completion date of corrective action: This was implemented on October 11, 2024.

View Audit 358818 Questioned Costs: $1

Finding 564659 (2024-003)

Material Weakness 2024

McIntosh Senior Living

MN

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

Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Assistance Listing: #10.766 Finding Summary: The Organization did not have an adequate internal control policy in place to ensure the reserve account was separately trac...

Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Assistance Listing: #10.766 Finding Summary: The Organization did not have an adequate internal control policy in place to ensure the reserve account was separately tracked and a documented review and approval over the reserve fund occurred. Responsible Individuals: Sharlene Knutson, Administrator Corrective Action Plan: We have adopted a policy to enhance internal control to ensure the reserve fund reconciliation has a secondary review and approval that is documented. Anticipated Completion Date: 6/30/2025

View Audit 358780

Finding 564651 (2024-004)

Material Weakness 2024

Teach.org Inc.

CA

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

Auditor’s Recommendation: Internal control should be documented to ensure compliance with the reporting compliance requirement. Documentation should include a signed certification by the preparer and a reviewer that the requests for payment, written summaries of reporting-specific meetings with gran...

Auditor’s Recommendation: Internal control should be documented to ensure compliance with the reporting compliance requirement. Documentation should include a signed certification by the preparer and a reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and any other reporting activities are complete, accurate, and agree to supporting records of expenditures or other accounting or database information. Written policies and procedures should be designed and implemented for documentation of internal controls performed for reporting. Corrective Action: TEACH.org will write a policy to address internal controls for reporting. TEACH staff will obtain training on documentation of internal controls performed for reporting related to Federal awards. After training, TEACH staff will review all documentation of internal controls and make changes to our policies as needed to properly document our internal controls. Responsible for Corrective Action: TEACH.org Deputy Chief of Staff will obtain training on internal controls documentation for Federal grants. Once training is completed, DCoS will review all fiscal policies and add or edit our policies as needed to address proper documentation of internal controls performed for reporting. Anticipated Completion Date: TEACH.org DCoS will obtain training by September 30, 2025 and conclude their review of TEACH fiscal policies by December 31, 2025.

View Audit 358749

Finding 564650 (2024-003)

Material Weakness 2024

Teach.org Inc.

CA

Allowable Costs / Cost Principles § 200.303

Auditor’s Recommendation: All disbursements charged to the federal award should have documentation to support internal controls performed for allowable activities and cost principles. Written policies and procedures should be designed and implemented for documentation of internal controls performed ...

Auditor’s Recommendation: All disbursements charged to the federal award should have documentation to support internal controls performed for allowable activities and cost principles. Written policies and procedures should be designed and implemented for documentation of internal controls performed for allowable activities and cost principles. Corrective Action: TEACH.org will write a policy to address internal controls for allowable activities and cost principles. TEACH staff will obtain training on allowable activities and cost principles related to Federal awards. After training, TEACH staff will review all documentation of internal controls and allowability and make changes to our policies as needed to properly document our internal controls. Responsible for Corrective Action: TEACH.org Deputy Chief of Staff will review documentation on Federal grant allowable activities and cost principles. Once the review is completed, DCoS will review all fiscal policies and add or edit our policies as needed to address proper documentation of internal controls performed for allowable activities and cost principles. Anticipated Completion Date: TEACH.org DCoS will conclude review of available documentation by September 30, 2025 and conclude their review of TEACH fiscal policies by December 31, 2025.

View Audit 358749

Finding 564598 (2024-002)

Significant Deficiency 2024

National Indian Youth Council, Inc.

NM

Eligibility Significant Deficiency § 200.303 § 200.430

Recommendation Implement a centralized, access-controlled digital system for participant file storage. Additionally, management should require the use of a standardized eligibility checklist and conduct periodic file audits to ensure documentation completeness and compliance with WIOA requirements. ...

Recommendation Implement a centralized, access-controlled digital system for participant file storage. Additionally, management should require the use of a standardized eligibility checklist and conduct periodic file audits to ensure documentation completeness and compliance with WIOA requirements. Management Response Corrective Action: In response to this incident, we have reinstated the Eligibility Determination and Intake (EDIR) Form. This form clearly states the participant identification information, the characteristics tracked by our program data management tool (GPMS), and states what has been provided by the participant to determine their eligibility for the program. Provided in a check list format, the form clearly demonstrates what makes the participant eligible for our program services. The form also lists the documentation included in the application that has been provided by the participant. This form added to the program application and maintained in the participant's official record will ensure that all WIOA eligibility documentation has been received, reviewed, and approved at the time of intake. Due Date of Completion: Completed as of May 31, 2025 Responsible Person(s):Director of Programs and Development is responsible for re-instating the use of the form and the Field Office Managers and Job Developers are responsible for filling out the form and including it in the participant's official record.

View Audit 358729

Corrective Action Plans

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