Corrective Action Plans

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Finding 22979 (2022-004)
Material Weakness 2022
FINDING 2022-004 Contact Person Responsible for Corrective Action: Cheryl Alcorn, County Auditor Contact Phone Number: 574-753-7700 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Auditor and Commissioner will work together to ensure Project and Expe...
FINDING 2022-004 Contact Person Responsible for Corrective Action: Cheryl Alcorn, County Auditor Contact Phone Number: 574-753-7700 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Auditor and Commissioner will work together to ensure Project and Expenditure Amounts are properly reported to the Department of Treasury. The corrective plan of action will include the guidance of financial advisors to ensure reporting to be complete and accurate. Anticipated Completion Date: Corrective action plan will start immediately.
Finding 22978 (2022-003)
Material Weakness 2022
FINDING 2022-003 Contact Person Responsible for Corrective Action: Cheryl Alcorn, County Auditor Contact Phone Number: 574-753-7700 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Plan of action has been implemented to include procedures and controls...
FINDING 2022-003 Contact Person Responsible for Corrective Action: Cheryl Alcorn, County Auditor Contact Phone Number: 574-753-7700 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Plan of action has been implemented to include procedures and controls to ensure vendor contracts include suspension and debarment compliance clause. If suspension and debarment clause is not included the Auditor will research suspension debarment findings through the SAM Exclusions website. Research results will be reviewed and documented by Commissioner President. Plan of action includes recording of Procurement process, history of obtaining sales/services contracts. Anticipated Completion Date: Corrective action plan will start immediately.
Allowable Activities and Costs - Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority reviews the established internal control procedures over charging expenses to programs and ensure the policies are followed for all expenses charged to the program. Add...
Allowable Activities and Costs - Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority reviews the established internal control procedures over charging expenses to programs and ensure the policies are followed for all expenses charged to the program. Additionally, we recommend that the Authority reviews the payroll procedures to ensure all timesheets are approved prior to payment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Finance Dept lost 3 key positions. New CFO in place now for two weeks and will implement allocation for all expenses and procedure to oversee that all transactions are recorded properly and have sufficient backup. Will work with HR and Payroll Staff Accountant to implement required authorization before processing. Name(s) of the contact person(s) responsible for corrective action: Shannon Sterling, CFO Planned completion date for corrective action plan: September 30, 2023
View Audit 22393 Questioned Costs: $1
Finding 22682 (2022-001)
Significant Deficiency 2022
Finding 2022-001: Timely Enrollment Report The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Corrective Action Pla...
Finding 2022-001: Timely Enrollment Report The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Corrective Action Plan Management has immediately implemented the ad hoc reporting option, which includes the Associate Director of Registration and Student Records notifying the NSLDS of student withdrawals at time of withdrawal. This policy will ensure timely reporting of withdrawals and will be included in the standard procedure process for the withdrawal of a student. Contact Person Leanne Beaudoin Ryan Director of Research, Records and Registration lbeaudoinryan@erikson.edu Anticipated Completion Date February 2023
Allowable Activities and Costs - Public and Indian Housing ? Assistance Listing Number 14.850 Recommendation: We recommend the Authority reviews the established internal control procedures over charging expenses to programs and ensure the policies are followed for all expenses charged to the program...
Allowable Activities and Costs - Public and Indian Housing ? Assistance Listing Number 14.850 Recommendation: We recommend the Authority reviews the established internal control procedures over charging expenses to programs and ensure the policies are followed for all expenses charged to the program. Additionally, we recommend that the Authority reviews the payroll procedures to ensure all timesheets are approved prior to payment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Finance Dept lost 3 key positions. New CFO in place now for two weeks and will implement allocation for all expenses and procedure to oversee that all transactions are recorded properly and have sufficient backup. Will work with HR and Payroll Staff Accountant to implement required authorization before processing. Name(s) of the contact person(s) responsible for corrective action: Shannon Sterling, CFO Planned completion date for corrective action plan: September 30, 2023
View Audit 22393 Questioned Costs: $1
2022-005 Reporting Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2908-000 Award Period: July 1, 2021 ? June...
2022-005 Reporting Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2908-000 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the District implement a policy to support the review and approval of CLiCs reports. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement a policy to have a review and approval process in place over the CLiCs reports. Name of the Contact Person Responsible for Corrective Action Plan: Kate Fernholz, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2023
Significant Deficiencies 2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Lis...
Significant Deficiencies 2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Condition: The Organization did not complete written policies and procedures relative to Federal Awards as required by Uniform Guidance (2 CFR 200). Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Corrective Action: The Organization will complete the written policies and procedures to comply with the Uniform Guidance. These will subsequently be adopted and implemented. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: In 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-003 Department of Veteran Affairs Federal Financial Assistance Listing 64.033, 20-SD-136-21, 20-SD-136-22, 10/1/2021-9/30/2022, 10/1/2022 ? 9/30/2023 VA Supportive Services for Veteran Families Program Eligibility Material Weakness in Internal Control over Compliance Finding Summary: Six...
2022-003 Department of Veteran Affairs Federal Financial Assistance Listing 64.033, 20-SD-136-21, 20-SD-136-22, 10/1/2021-9/30/2022, 10/1/2022 ? 9/30/2023 VA Supportive Services for Veteran Families Program Eligibility Material Weakness in Internal Control over Compliance Finding Summary: Six instances were identified in which the participant was not recertified within three months. Responsible Individuals: Teena Conrad, SSVF Program Coordinator Corrective Action Plan: Management has implemented a process for all recertifications to be calculated 90 days from the last recertification date, instead of at 90-day increments from the enrollment date. This will ensure recertification is done within three months. Anticipated Completion Date: April 17, 2023
Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time an...
Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. The Commission should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding that $582 was improperly charged to EPA 106 Account #802 on one timesheet and not caught because of a change in personnel. ICPRB notes that EPA 106 Account #802 was not overcharged because ICPRB spent $80,000 more on this project than was charged to the federal government. Action taken in response to finding: Hiring of Office Manager to review the formulas used in timesheet entries [Completed February 2023]; Blocking of employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software [Underway]. Name(s) of the contact person(s) responsible for corrective action: Michael Nardolilli, Executive Director Planned completion date for corrective action plan: March 2023 If the U.S. Environmental Protection Agency has questions regarding this plan, please call Michael Nardolilli, Executive Director at 301-274-8105.
View Audit 19157 Questioned Costs: $1
Finding 22514 (2022-003)
Material Weakness 2022
2022-003 Small Business Administration Financial Assistance Listing #59.075 COVID-19 Shuttered Venue Operators Grant Program Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Material Weakness in Internal Control over Compliance Condition: While the Organization...
2022-003 Small Business Administration Financial Assistance Listing #59.075 COVID-19 Shuttered Venue Operators Grant Program Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Material Weakness in Internal Control over Compliance Condition: While the Organization had policies and procedures in place over the review and approval of expenditures, during the testing of expenditures there were certain items that lacked the documentation of such review and approval. The Organization did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing available. The review and approval process was a collaborative process that took place in face to face meetings without documentation retained. Management?s Response and Corrective Action Plan: The Museum Deputy Directory/COO reviewed all grant expenditures in detail for accuracy and approved them before submission to the SBA, and written documentation of the review and approval of the submitted expenditures was maintained. However, written documentation of the approval of certain expenditures at the time they were actually incurred was not maintained, even though there were consistent, contemporaneous oral communications between the Deputy Director/COO, the Controller and the Payroll Administrator regarding those expenditures. As of January 2023, the CFO has implemented procedures whereby written documentation of approval of those expenditures is maintained. Responsible Individual: Robin Klung, CFO Anticipated Completion Date: January 2023
FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: In reviewing and investigating the core of this finding, it was determined that there were three reports that did...
FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: In reviewing and investigating the core of this finding, it was determined that there were three reports that did not have a secondary review signature on them. As this finding is in review of ESSER funding, it should be noted that most all guidance and direction for these grants came after they were issued. It should be noted that the three reports cited were interpreted as progress monitoring by the district and not "formal", therefore, not requiring signatures. All financial transactions related to this grant did receive a second review and signature in addition to the reporting of these grants on the annual SEFA report. Description of Corrective Action Plan: As controls are already established and the procedure for these grants established, a second signature (review) will be secured on all future reports. Anticipated Completion Date: Immediate
FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manage...
FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate
Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA #93.498 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal cont...
Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA #93.498 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Organization did not have proper review procedures in place to determine employees? qualifications for individual incentive pay that was allocated to the program. Responsible Individuals: Donna Cordova, CFO Corrective Action Plan: The CFO will review supporting documentation to provide a secondary review and approval of the summarized final expenditures listing used to claim allowable costs under federal programs. Anticipated Completion Date: This process will go into effect immediately.
Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA #93.498 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal cont...
Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA #93.498 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Organization did have two individuals involved in the reporting process, but did not have documented controls over the preparation and corresponding review of the required reporting during the period. Responsible Individuals: Donna Cordova, CFO and Cletus Thiebeau CEO Corrective Action Plan: VALLEYLIFE will add documentation in its Accounting & Finance Policies and Procedures that Federal Grant reporting will be reviewed, prior to submission to the federal granting agency, by the Supervisor of the individual preparing the reports. Anticipated Completion Date: This process will go into effect immediately and will be presented to the Finance Committee of the Board of Directors for approval at its March 2023 meeting as the VALLEYLIFE bylaws require.
FINDING 2022-006 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: I agree with the finding Description of Corrective Action Plan: The county will create a Certification to supply to any contractor with an expected purcha...
FINDING 2022-006 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: I agree with the finding Description of Corrective Action Plan: The county will create a Certification to supply to any contractor with an expected purchase to exceed $25,000.00. If the contractor does not submit the certification the Auditor will check the Sam?s for any suspension, disbarment or exclusion and sign the certification. Anticipated Completion Date: July 28, 2023
FINDING 2022-005 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: The Auditor will document the reviewing and approving of project and expenditures report. An...
FINDING 2022-005 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: The Auditor will document the reviewing and approving of project and expenditures report. Anticipated Completion Date: April 30, 2023
The district will implement procedures to ensure that personnel paid from federal funding complete single funding certifications and/ or time and effort logs.
The district will implement procedures to ensure that personnel paid from federal funding complete single funding certifications and/ or time and effort logs.
View Audit 20899 Questioned Costs: $1
FINDING 2022-003 Contact Person Responsible for Corrective Action: Sharon Fowler Contact Phone Number: (765) 358-4006 Views of Responsible Official: The Superintendent and Corporation Treasurer felt that expenses of $15,787.31 were justifiable due to the lack of fund raiser dollars for prom because ...
FINDING 2022-003 Contact Person Responsible for Corrective Action: Sharon Fowler Contact Phone Number: (765) 358-4006 Views of Responsible Official: The Superintendent and Corporation Treasurer felt that expenses of $15,787.31 were justifiable due to the lack of fund raiser dollars for prom because of COVID. Part of that expense amount was for Esports Club chairs. These chairs are used for Esports only after school, and used during the day in regular classrooms. As for the Freshman Class Sponsor, Assistant Wrestling Coach, and Elementary Talen Show Sponsor, these contracts were paid from ESSER. The ECA positions were inadvertently added to teachers? contracts, as usual, and not taken out of the Education Fund. Description of Corrective Action Plan: Beginning with the 2022-23 fiscal year, we will be more careful with what we spend from ESSER Funds. Anticipated Completion Date: July 2023
View Audit 21466 Questioned Costs: $1
Finding No. 2022-001 Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the fe...
Finding No. 2022-001 Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: SAH selected option I to calculate lost revenue, which consists of a comparison of actual results during the period of availability to the base calendar year of 2019. For all periods reported in SAH?s Period 2 submission, the reported patient service revenue amounts did not agree to the underlying internal financial statements. Furthermore, SAH did not report actual revenue for Quarter 3 2021 and Quarter 4 2021. Planned Corrective Action: Management will continue to refine processes to more diligently review the lost revenue calculation to ensure such amounts are in accordance with the terms and conditions of the federal award. However, SAH incurred and reported eligible expenses and lost revenue that had the errors in the lost revenue calculation been identified and corrected prior to reporting, SAH would have satisfactorily incurred eligible expenses and lost revenue in excess of the PRF funds received, including interest earned on such funds. Planned Completion Date: Ongoing Person Responsible: Karrie Beach, VP of Finance
Finding 2022 001 Corrective Action Plan: Due to the cumulative nature of lost revenues, amended reports are not allowed and future reports should include the accurate information. The Health System will accurately present lost revenues and allowable expenditures in the period 5 PRF rep...
Finding 2022 001 Corrective Action Plan: Due to the cumulative nature of lost revenues, amended reports are not allowed and future reports should include the accurate information. The Health System will accurately present lost revenues and allowable expenditures in the period 5 PRF reports. We also plan to improve our report review process by reconciling all information in the report even those amounts from prior period reports. Contact Person: Teri Larsen, System Controller Anticipated Completion Date: September 30, 2023
View Audit 19517 Questioned Costs: $1
FINDING 2022-001 Contact Person Responsible for Corrective Action: Lori Phillips, Clerk Treasurer Contact Phone Number: 260-726-9395 x 224 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, management will implement a stronger internal c...
FINDING 2022-001 Contact Person Responsible for Corrective Action: Lori Phillips, Clerk Treasurer Contact Phone Number: 260-726-9395 x 224 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, management will implement a stronger internal controls system over Federal Grants. This includes segregation of duties for proper oversight and approval. More specifically, management will receive and review all certified payrolls from the contractor to verify that the Wage Rate Requirements are being adhered to. Anticipated Completion Date: 8/28/2023
The Daleville City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the numbe...
The Daleville City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 ? Special Tests and Provisions ? Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective January 1, 2023, stating that the Chief School Financial Officer, Linda Harper, will review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.
The items in question were included on the same purchase order as other COVID-19 related supplies and were incorrectly charged to the grant. Going forward, the Organization will ensure the individuals accumulating allowable expenses ensure they understand the nature of all items being charged to ens...
The items in question were included on the same purchase order as other COVID-19 related supplies and were incorrectly charged to the grant. Going forward, the Organization will ensure the individuals accumulating allowable expenses ensure they understand the nature of all items being charged to ensure compliance with the program requirements.
View Audit 25483 Questioned Costs: $1
The error identified during the audit was the result of a miscommunication with HRSA personnel. When management reached out to the agency regarding the recording of excess revenues for certain quarters, the Organization was directed to offset lost revenues in other quarters. This led to the underrep...
The error identified during the audit was the result of a miscommunication with HRSA personnel. When management reached out to the agency regarding the recording of excess revenues for certain quarters, the Organization was directed to offset lost revenues in other quarters. This led to the underreporting of lost revenues. If the Organization has future PRF reporting requirements, these quarters will be revised to reflect the corrected amounts.
The Lurleen B. Wallace Community College (the College) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned...
The Lurleen B. Wallace Community College (the College) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 ? Suspension and Debarment Higher Education Emergency Relief Fund (HEERF) ? CFDA # 84.425E, 84.425F, & 84.425M U.S. Department of Education Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment prior to payment being made. We recommend management implement procedures to monitor and document the compliance of vendors for suspension and debarment. The Chief Financial Officer, Lisa Carnley, should review documentation for suspension and debarment monitoring as part of the bid process prior to expenditures being made. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 relating to covered transactions and ensuring no such transactions are made with parties that are suspended or debarred and agrees with the recommendation. Management has implemented additional procedures, effective November 14, 2022, stating that the Chief Financial Officer will review documentation for suspension and debarment monitoring as part of the bid process prior to expenditures being made.
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