Corrective Action Plans

Finding 538460 (2024-038)

Significant Deficiency 2024

State of Maine

ME

Cash Management Significant Deficiency § 200.302 § 200.303

Department: Health and Human Services Administrative and Financial Services Title: Internal control over WIC cash balances needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will contact the Federal Awarding Agency to identify steps neede...

Department: Health and Human Services Administrative and Financial Services Title: Internal control over WIC cash balances needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will contact the Federal Awarding Agency to identify steps needed to resolve the cash discrepancy. Completion Date: September 30, 2025 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

View Audit 349360

Finding 538458 (2024-037)

Significant Deficiency 2024

State of Maine

ME

Cash Management Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.305

Department: Health and Human Services Title: Internal control over WIC subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in comp...

Department: Health and Human Services Title: Internal control over WIC subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of the funds. Payments are made as close as administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1). That same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Anthony Madden, Deputy Director of Audit, DHHS, 207-287-2834

View Audit 349360

Finding 538453 (2024-036)

Significant Deficiency 2024

State of Maine

ME

Cash Management School Nutrition Programs Internal Control / Segregation of Duties § 200.302 § 200.303

Department: Education Administrative and Financial Services Title: Internal control over CNC cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has developed and implemented new procedures to confirm that batch payments a...

Department: Education Administrative and Financial Services Title: Internal control over CNC cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has developed and implemented new procedures to confirm that batch payments are paid on time. Completion Date: March 15, 2025 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360

Finding 538448 (2024-035)

Significant Deficiency 2024

State of Maine

ME

Reporting School Nutrition Programs Equipment & Real Property Management § 200.303

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will follow up on open CNPWeb tickets for completion. The Department will work with the vendor to create a n...

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will follow up on open CNPWeb tickets for completion. The Department will work with the vendor to create a new computerized system to receive tickets and print them automatically to remove the manual process of writing tickets. The Department will initiate meetings each month to compare inventory numbers, if they do not match. The Department will work with the vendor to replace any missing item from their inventory with an equal product each month. Completion Date: March 31, 2025 first item, December 1, 2025 second item and April 30, 2025 third and fourth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360

Finding 538443 (2024-034)

Significant Deficiency 2024

State of Maine

ME

Reporting School Nutrition Programs Internal Control / Segregation of Duties § 200.303 § 200.502

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has updated the SEFA Review Procedure to include more speci...

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has updated the SEFA Review Procedure to include more specific information regarding the calculation of amounts reported for the Special Milk Program and noncash assistance and the classification of payments made to a school as direct payments rather than subrecipient expenditures. Completion Date: March 10, 2025 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

View Audit 349360

Finding 538433 (2024-032)

Material Weakness 2024

State of Maine

ME

School Nutrition Programs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.332

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement a monthly status check of the current tracking tool to ensure compliance with the ...

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement a monthly status check of the current tracking tool to ensure compliance with the review The Department will update the current high-risk procedure. The Department will develop a procedure for evaluating base year reviews and add a procedure for timelines for adjustments to the claims. Completion Date: July 1, 2025, September 1, 2025, and June 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360

Finding 538428 (2024-031)

Material Weakness 2024

State of Maine

ME

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

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition ...

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition Services will create a procedure for reviewing applications and making sure they are approved prior to participation. For the Summer Food Service Program (SFSP), the Child Nutrition Services will create an additional application, outside of CNPWeb to further assess non-congregate operations and eligibility to prevent duplicative services. Child Nutrition Services has submitted a ticket to create an edit check on the SFSP Application to ensure that all specific eligibility information is submitted. Child Nutrition Services will create a procedure to address that session specific information is received prior to claim approval for sites. Child Nutrition Services will require a site sheet for SFSP applications for each location and each enrollment period. Child Nutrition Services will submit a ticket to CNPWeb to allow for documentation to be added to the site information sheet when revisions are made to the system. Child Nutrition Services will add documentation to the activities tab, while we wait for the enhancement to be completed. Child Nutrition Services will create a procedure to ensure that allocations to schools fall between $50.00 - $75.00. Child Nutrition Services has provided training to the National School Lunch Program reviewers on the Fresh Fruit and Vegetable Program questions within the Administrative Review process to ensure that those questions are asked during the Administrative Review. Completion Date: May 1, 2025, first and fourth items, April 1, 2025, second, fifth, sixth, and seventh items, June 1, 2025, third item, March 1, 2025, eight item, and February 10, 2025, for nineth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360 Questioned Costs: $1

Finding 538423 (2024-030)

Material Weakness 2024

State of Maine

ME

Questioned Costs School Nutrition Programs Allowable Costs / Cost Principles § 200.303

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, ...

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, eligibility and non-congregate plan requirements. The Department will develop procedures for Revisions on Claims and Applications. For the Summer Food Service Program, the Department will request an edit check enhancement in CNPWeb to add actual enrollment be added to claims. Completion Date: May 1, 2025, first and second item, and May 1, 2026, third item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360 Questioned Costs: $1

Finding 538402 (2024-026)

Significant Deficiency 2024

State of Maine

ME

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.303

Department: Health and Human Services Title: Internal control over DHHS special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Division of Contract Management will work with program staff and the Service Center Grants Team to ensure gr...

Department: Health and Human Services Title: Internal control over DHHS special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Division of Contract Management will work with program staff and the Service Center Grants Team to ensure grant information is captured and recorded timely and accurately. The Department will establish meetings to ensure DCM, Service Center and Program staff establish policies to ensure accuracy in FFATA reporting process. Completion Date: September 30, 2025 and May 31, 2025, respectively Agency Contact: Jeanne Garza, Deputy Director, DCM, DHHS, 207-287-1848

View Audit 349360

Finding 538400 (2024-025)

Significant Deficiency 2024

State of Maine

ME

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Special Tests & Provisions § 200.303

Department: Health and Human Services Title: Internal control over SNAP EBT card security needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department agrees with this finding. During the audit period, the process ...

Department: Health and Human Services Title: Internal control over SNAP EBT card security needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department agrees with this finding. During the audit period, the process for handling returned EBT cards was assigned to one (1) individual. In response to a prior year finding, the Department implemented corrective actions effective July 1, 2024. The current process has the duties separated into 3 roles. First, an Accounting Associate I receives the returned EBT cards at OFI's Central Office. The Accounting Associate scans the card and envelope to an Office Associate II in a separate office. The Office Associate II enters the cards into a spreadsheet (returned card log) and researches the cases to determine what to do with the card. The Office Associate records the necessary information into the returned card log and makes an ACES case note to reflect any action taken. Then a response is sent back to the Accounting Associate to advise which EBT cards should be shredded and which cards should be resent. Finally, the EBT Manager conducts a periodic review of the returned card log to ensure the cards are being handled appropriately. The Department will also be hiring a new Office Associate II (Supervisor) to assist in this process. Because these procedures were implemented effective 7/1/2024, they were not captured during this single audit. No corrective action is required due to our current procedures meeting state and Federal card security requirements. Completion Date: N/A Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

View Audit 349360

Finding 538398 (2024-024)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.403

Department: Health and Human Services Title: Internal control over automated SNAP eligibility certification periods needs improvement Questioned Costs: Known: ALN 10.551 $3,973 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department believes the necessary corre...

Department: Health and Human Services Title: Internal control over automated SNAP eligibility certification periods needs improvement Questioned Costs: Known: ALN 10.551 $3,973 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department believes the necessary corrective action has been taken and will be reflected in the SFY25 audit. The Department implemented the following corrective action steps: 1) Returned to normal batch processing following the suspension of closures and pushing out of renewal dates related to the PHE and unwinding period. 2) Enhanced renewal appointment functionality in ACES to allow each program to be processed independently. 3) Runs monthly queries to identify cases that had their periodic reports withdrawn in error and reestablish them. Completion Date: October 1, 2024, first and second item, and June 30, 2024, third item Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

View Audit 349360 Questioned Costs: $1

Finding 538396 (2024-023)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.403

Department: Health and Human Services Title: Internal control over SNAP deceased client cases needs improvement Questioned Costs: Known: ALN 10.551 $11,080 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The MaineCare Program Manager will assign Death Match work to th...

Department: Health and Human Services Title: Internal control over SNAP deceased client cases needs improvement Questioned Costs: Known: ALN 10.551 $11,080 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The MaineCare Program Manager will assign Death Match work to their team. The MaineCare Program Manager and their team will develop a Standard Operating Procedure for matches with vital statistics at Maine CDC. Completion Date: July 16, 2025 Agency Contact: Michael E. Downs, Senior Program Manager — SNAP, DHHS, 207-592- 4850

View Audit 349360 Questioned Costs: $1

Finding 538394 (2024-022)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303 § 200.403

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: ALN 10.551 $12,335 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will automate the i...

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: ALN 10.551 $12,335 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will automate the issuance of the TANF funded resource guide at Application and Recertification (existing ticket AO-4039). (Business Technology Lead) The Department will keep SNAP applications from being opened in batch runs such as mid-month and end-of-month mass change. (Business Technology Lead) The Department will provide updated training/reminders about start and end dating records including income records to retain the information used for benefit runs. (Training Team and Senior SNAP Program Manager) Completion Date: August 31, 2025, first item, and September 30, 2025, second and third items Agency Contact: Michael E. Downs, Senior Program Manager — SNAP, DHHS, 207-592- 4850

View Audit 349360 Questioned Costs: $1

Finding 538365 (2024-016)

Significant Deficiency 2024

State of Maine

ME

Reporting Internal Control / Segregation of Duties § 200.303 § 200.510

Department: Labor Administrative and Financial Services Title: Internal control over Unemployment Insurance financial reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Security and Employment Service Center will further expand the proced...

Department: Labor Administrative and Financial Services Title: Internal control over Unemployment Insurance financial reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Security and Employment Service Center will further expand the procedures used to prepare and review the SEFA. Completion Date: August 1, 2025 Agency Contact: Marilyn Leimbach, Director, Security and Employment Service Center, DFPS, DAFS, 207-248-2556

View Audit 349360

Finding 538349 (2024-007)

Significant Deficiency 2024

Hood College of Frederick, Maryland and Affiliates

MD

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Identifying Number: Finding No. 2024-007 – Student Credit Balances from Title IV Awards Finding: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. T...

Identifying Number: Finding No. 2024-007 – Student Credit Balances from Title IV Awards Finding: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances. Corrective Actions Taken or Planned: Responsible Official: Judy Byrd, Controller Anticipated Completion Date: April 1, 2025 View of Responsible Individuals: Once the student refunds are imported to the accounting software, the Refund Export Log report along with the Charge/Credit Import report will be given to Controller/Director of Finance. The AP Coordinator will deliver the student refund checks to Controller/Director of Finance. The Controller/Director of Finance will compare the refund log list against the actual printed checks to verify that all checks have been printed. A signature and date on the refund log report will indicate that the review was completed and that all required refund checks have been printed. Signed report and backup will be stored in the AP files under the title “Student Refunds”.

View Audit 349356

Finding 538335 (2024-004)

Material Weakness 2024

Hood College of Frederick, Maryland and Affiliates

MD

Allowable Costs / Cost Principles § 200.303

Identifying Number: Finding No. 2024-004 – Payroll Controls around Timesheets/Time and Effort Reports Finding: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor. Corrective Actions Taken or Planned: ...

Identifying Number: Finding No. 2024-004 – Payroll Controls around Timesheets/Time and Effort Reports Finding: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor. Corrective Actions Taken or Planned: Responsible Official: Jaime Cacciola, Director of Grants; Tim Pollak Director of Finance Anticipated Completion Date: March 31, 2025 View of Responsible Individuals: Timesheets will be reviewed bi-weekly for electronic signatures of supervisor/PI. Any missing signatures will require manual signature by PI. Our updated Time & Effort policy and procedures, includes the following: Time & Effort Certification On an annual basis, principal investigators (PIs) on federally funded awards must confirm that the salaries and wages of individuals charged to their respective projects are reasonable, allowable, properly allocated, and accurate based on the work performed. Throughout the year, though, PIs must regularly review compensation reports to ensure that the final amounts charged to federal awards are reasonable, accurate, allowable, and properly allocated. This regular monitoring of payroll charges throughout the budget period is central to Hood’s compliance program. The annual time and effort reports cover August 15th – August 14th and are released for review and signature after the fiscal year end close process is complete. Signed reports should be returned to the GRASP Office by August 31st. Who Needs to Complete: • All salaried employees working on the project should complete a report. • Hourly employees and student workers are not required to complete a time and effort certification as their time is certified via time sheets. PIs must also review and certify all of their workers’ time sheets by providing a signature on the document.

View Audit 349356

Finding 538320 (2024-002)

Material Weakness 2024

The Phalen Leadership Academy - Indiana, Inc.

MA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

2024-002 Special Tests and Provisions Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with audit finding: There is no disagreement with the aud...

2024-002 Special Tests and Provisions Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PLA will train operations and business office staff on the compliance requirements under Davis-Bacon to ensure construction contracts are entered into with qualified contractors and obtain and retain appropriate certified payroll documentation during the construction period. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Larkins, Director of Finance & Accounting; Javier Dimas, Vice-President of Operations; Martha Arellano, Procurement Manager and Buyer. Planned completion date for corrective action plan: January 30, 2025.

View Audit 349344 Questioned Costs: $1

Finding 538313 (2024-002)

Significant Deficiency 2024

Meals on Wheels of the Monterey Peninsula, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.302 § 200.303

Finding Number: 2024-002 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure of Federal Funds: Controller and/or bookkeeper will develop a process and procedures that will identify the amount, so...

Finding Number: 2024-002 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure of Federal Funds: Controller and/or bookkeeper will develop a process and procedures that will identify the amount, source, and expenditure of Federal funds for all Federal awards; that track and verify expenditures and income. Yearly reviews of the identification and tracking process will be conducted to ensure accuracy and relevance. 2. Federal Award Compliance: Controller and/or bookkeeper will develop a process and procedures to verify compliance with Federal statues, regulations, and the terms and conditions of each Federal award. Yearly reviews of the verification process will be conducted to ensure accuracy and relevance. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by February 28, 2025 and these procedures will be in full effect for the fiscal year 2025.

View Audit 349343 Questioned Costs: $1

Finding 538304 (2024-007)

None 2024

Governors State University

IL

Allowable Costs / Cost Principles § 200.303 § 200.431

2024-007 FINDING: NONCOMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS AND COST PRINCIPLES REQUIREMENTS Corrective Action Plan: The University has implemented more stringent review procedures to prevent the recurrence of this issue. Responsible University Personnel: Andrea Mid...

2024-007 FINDING: NONCOMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS AND COST PRINCIPLES REQUIREMENTS Corrective Action Plan: The University has implemented more stringent review procedures to prevent the recurrence of this issue. Responsible University Personnel: Andrea Middleton, Director of Financial Services/Assistant Controller; Villalyn Baluga, Associate Vice President for Finance. Anticipated completion date: Already implemented.

View Audit 349333

Finding 538302 (2024-005)

None 2024

Governors State University

IL

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

2024-005 FINDING: FAILURE TO RETAIN ADEQUATE DOCUMENTATION OF INTERNAL DIRECT LOANS RECONCILIATION Corrective Action Plan: The University has revised existing procedures to require the retention of internal reconciliation records on a monthly basis. Responsible University Personnel: Linda There...

2024-005 FINDING: FAILURE TO RETAIN ADEQUATE DOCUMENTATION OF INTERNAL DIRECT LOANS RECONCILIATION Corrective Action Plan: The University has revised existing procedures to require the retention of internal reconciliation records on a monthly basis. Responsible University Personnel: Linda Theres-Jones, Director of Financial Services/Chief Accountant; Villalyn Baluga, Associate Vice President for Finance. Anticipated completion date: Already implemented.

View Audit 349333

Finding 538293 (2024-003)

Significant Deficiency 2024

Governors State University

IL

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

2024-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University has recently completed the development of the written incident response plan during Fiscal Year 2025. Responsible University Personnel: Charles Pustz, Associate Vice President for Information Tech...

2024-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University has recently completed the development of the written incident response plan during Fiscal Year 2025. Responsible University Personnel: Charles Pustz, Associate Vice President for Information Technology Services and Chief Information Officer; David Weissbohn, Director of Information Security and Compliance. Anticipated completion date: Already implemented.

View Audit 349333

Finding 538292 (2024-002)

Significant Deficiency 2024

Governors State University

IL

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

2024-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: Following consultation with the National Student Clearinghouse (NSC), guidelines were provided for handling various status change scenarios. These guidelines will enhance the accuracy of enrollment status change reporting, particularl...

2024-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: Following consultation with the National Student Clearinghouse (NSC), guidelines were provided for handling various status change scenarios. These guidelines will enhance the accuracy of enrollment status change reporting, particularly for students with changes occurring before or after the subsequent enrollment file submission. Status changes are now being reported to the NSLDS in a timely and accurate manner, in accordance with the NSC guidelines. The University has also implemented a reporting timeline and review protocols to ensure status changes are reported to the U.S. Department of Education’s National Student Loan Data System (NSLDS) in a timely manner. Additionally, the University will collaborate with its Information Technology Services and representatives from the NSC and NSLDS to verify the accuracy of the file layouts and the data flow of the information provided. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Partially implemented. The University is collaborating with its Information Technology Services and representatives from the NSC and NSLDS on accurate reporting of the program start date, which is expected to be completed during Fiscal Year 2026.

View Audit 349333

Finding 538271 (2024-001)

Material Weakness 2024

Anne Arundel Economic Development Corporation

MD

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.327

2024-001Coronavirus State and Local Recovery Relief Funds – Assistance Listing No. 21.027 Recommendation: We recommend that management develop and implement written procurement policies and implement controls and procedures to ensure it maintains documentation of suspension and debarments checks and...

2024-001Coronavirus State and Local Recovery Relief Funds – Assistance Listing No. 21.027 Recommendation: We recommend that management develop and implement written procurement policies and implement controls and procedures to ensure it maintains documentation of suspension and debarments checks and that the documentation is available for the audit. Explanation of disagreement with audit ﬁnding: There is no disagreement with the audit ﬁnding. Action taken in response to the ﬁnding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 24, 2025.

View Audit 349286 Questioned Costs: $1

Finding 538253 (2024-008)

Material Weakness 2024

East Noble School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-008 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Title I Grants to Local Education Agencies – Eligibility Contact Person Responsible for Corrective Action: Holly Singleton, Heidi Moreno Contact Phone Number and Email Address: 260-347-2502 hsingleton@eastnob...

FINDING 2024-008 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Title I Grants to Local Education Agencies – Eligibility Contact Person Responsible for Corrective Action: Holly Singleton, Heidi Moreno Contact Phone Number and Email Address: 260-347-2502 hsingleton@eastnoble.net , hmoreno@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the Grants Coordinator and Deputy Treasurer work on completing the Title I Application, they will cross reference the pre-populated numbers provided by the DOE with the DEX report from the October 1st count date. If the numbers are both accurate, they will both sign documentation verifying that the numbers matched. If there is a discrepancy with the numbers, East Noble will reach out to the DOE representative. Anticipated Completion Date: July 1st, 2025 or when the next Title 1 Application is initiated

View Audit 349240

Finding 538249 (2024-007)

Material Weakness 2024

East Noble School Corporation

IN

Procurement, Suspension & Debarment § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2024-007 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Emai...

FINDING 2024-007 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.” Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

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