Corrective Action Plans

Finding 529023 (2024-015)

Significant Deficiency 2024

ND

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. The issue has already been corrected as stated in the finding. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: The issue has already been corrected.

View Audit 346994 Questioned Costs: $1

Finding 528989 (2024-017)

Significant Deficiency 2024

State of North Dakota

ND

Subrecipient Monitoring Period of Performance § 200.303 § 200.332

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. We have updated our grant award templates to include all required information. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This has already been implemented effective 2/1/2025.

View Audit 346994

Finding 528981 (2024-016)

Significant Deficiency 2024

State of North Dakota

ND

Subrecipient Monitoring § 200.303 § 200.311 § 200.331 § 200.521

Department of Public Instruction Response/Corrective Action Plan: DPI agrees with the finding. We have split the duties of subrecipient review among two employees. One person does the administrative functions and responses to subrecipients who have no findings. The other employee works on the ...

Department of Public Instruction Response/Corrective Action Plan: DPI agrees with the finding. We have split the duties of subrecipient review among two employees. One person does the administrative functions and responses to subrecipients who have no findings. The other employee works on the more complex audit reviews. We feel that this change along with the increase to the audit threshold and the end of the COVID related federal funding will allow us to stay in compliance of federal regulations. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This was implemented January 2, 2025

View Audit 346994

Finding 528980 (2024-014)

Significant Deficiency 2024

State of North Dakota

ND

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.208 § 200.303 § 200.339

Department of Public Instruction Response/Corrective Action Plan: We agree with the issues identified. 1. NDDPI acknowledges the late reports in FSRS.gov from October 2022 to September 2023. As stated in the finding, the reports were initially reported, but according to the Helpdesk with FSRS.go...

Department of Public Instruction Response/Corrective Action Plan: We agree with the issues identified. 1. NDDPI acknowledges the late reports in FSRS.gov from October 2022 to September 2023. As stated in the finding, the reports were initially reported, but according to the Helpdesk with FSRS.gov, they required removal to re-submit using the corrected FAIN numbers. NDDPI administrators were not aware that the reports initially filed would be deleted from the records, versus the incorrect reports becoming labeled as inactive and saved for historical purposes. Kim Vega, Administrative Officer with NDDPI will review current archive processes and determine where changes may be needed. The FSRS website will be eliminated as the reporting application for FFATA in the Spring of 2025, and from that time forward, will be performed in the SAM.gov application. Currently, NDDPI administrators are participating in training and presentations for the test website and will continue to watch for any changes to administrative tasks. An introduction of the new website’s capabilities did address enhancing the feature for deleted reports as a part of the user’s tasks rather than the Helpdesk’s responsibility. NDDPI will continue to follow this development while in training for SAM.gov reporting. With the changes in application sites, the future enhancement in ND Foods will include an Application Programming Interface (API) for FFATA reporting. This API will provide the capability of real-time reporting, eliminate most manual tasks, increase report accuracy, and improve team member productivity and efficiency. The new website also mentions the zip code validation as an upgraded process. This process in the current system has been an intense time drain for staff members who enter FFATA by manual entry or batch upload, so improved functionality in this area is a much-needed upgrade. 2. NDDPI acknowledges the submission of the late report leading up to March 2024 as stated in item number 1. Reports for the meal claims were not reported in FSRS.gov until the FAIN numbers and programming were corrected in ND Foods, and a new Excel report was written with the corrections. Therefore, the report was not submitted within the required deadline. NDDPI Administrative officer worked with the Child Nutrition Administrative Staff Officer and NDIT programmers to correct the programming and process new reports for batch upload. 3. NDDPI acknowledges the missing reports for November and December 2023. During the transition from one claim year to the following, multiple reports must be run in ND Foods to complete the block FFATA reports. In 2023, NDDPI administrators were not aware of the overlap of claim years and how it would affect reporting, and therefore, only the current-year reports were processed. Currently, ND Foods has been upgraded to include an automated feature for FFATA reporting to include the final claims from the prior year and the new year’s claims in its reports for batch upload. Every effort was made to report both the old claim year and the new claim year in 2024. 4. NDDPI administrators have reviewed the reporting dates and the obligation date for claims in the CN block reporting, and we have agreed on the federal guidance which indicates the awards are obligated in advance will have the date of signature or acceptance at NDDPI, and the batch upload for payments made to an award will have the action or obligation date of the approval date for payment. This process will correct the reporting dates for claim payment processing (10.559, 10.555, 10.558, 10.556, 10.553) or reporting month for an obligated award (10.582) and its required obligation date. NDDPI staff members should be able to test and implement a programming change in our current reporting system in the next 2 months. If this change proves to be more intense than planned, we will wait on a quick fix until the upcoming interface upgrade with Sam.gov. We know the interfacing upgrade will require an even greater amount of time, energy, and money, and it will be a change we must complete; therefore, if the quick fix proves to be ineffective and time-consuming, the change in reporting will wait until the programming begins for the API Interface. Currently, federal officials are reporting the transfer between reporting sites will be ‘Spring of 2025’ but are not giving users a specific date. We have consolidated the coordination of FFATA reporting to a single individual rather than having each area do their own. We will prepare and implement procedures for the FFATA reporting. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: June 30, 2025

View Audit 346994

Finding 528977 (2024-019)

Significant Deficiency 2024

State of North Dakota

ND

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.332 § 200.405 § 200.414

State Treasurer’s Office Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that our grant award template did not make subrecipients aware of all required grant award information for the Mineral Leasing Act as required. The Office of State Treasurer will revie...

State Treasurer’s Office Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that our grant award template did not make subrecipients aware of all required grant award information for the Mineral Leasing Act as required. The Office of State Treasurer will review and update its grant award templates to ensure that subrecipients are made aware of all required grant award information. Contact Person: Nicole Krivoruchka, Director of Finance Anticipated Completion Date: December 31, 2025

View Audit 346994

Finding 528974 (2024-018)

Significant Deficiency 2024

State of North Dakota

ND

Reporting Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.502

Office of Management and Budget Response/Corrective Action Plan: The Office of Management and Budget agrees with this finding. OMB agrees but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting perio...

Office of Management and Budget Response/Corrective Action Plan: The Office of Management and Budget agrees with this finding. OMB agrees but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. Contact Person: Elizabeth Roger, Account Budget Specialist Anticipated Completion Date: December 2026

View Audit 346994

Finding 528965 (2024-003)

Material Weakness 2024

Dekalb County Central United School District

IN

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

FINDING 2024-003 Finding Subject: Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; COVID-19 - Special Education Grants to States; Special Education Pr...

FINDING 2024-003 Finding Subject: Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125 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. INDIANA STATE BOARD OF ACCOUNTS 32 3326 CR 427, Waterloo, IN 46793 p 260-920-1011 f 260-837-7767 Steven E. Teders, Ed.S., Superintendent Loraine K. Vaughn, Ed.S., Assistant Superintendent Mark W. Rohm, Chief Financial and Operations Officer Personalized Pathways for Success 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. 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

View Audit 346961

Finding 528949 (2024-004)

Significant Deficiency 2024

Galena City School District

AK

School Nutrition Programs Reporting Cash Management § 200.303

Finding 2024-004 Reporting – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan This occurrence was due to a change in management and the error was corrected when it was identified. Since then, all the documentation was submitted within parameters of ...

Finding 2024-004 Reporting – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan This occurrence was due to a change in management and the error was corrected when it was identified. Since then, all the documentation was submitted within parameters of the grant. Expected Completion Date 12/21/2023

View Audit 346942

Finding 528948 (2024-003)

Material Weakness 2024

Galena City School District

AK

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding 2024-003 Reporting – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan The District acknowledges the finding regarding failure to retain source check documentation supporting student count certification for the Impact Aid program. In resp...

Finding 2024-003 Reporting – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan The District acknowledges the finding regarding failure to retain source check documentation supporting student count certification for the Impact Aid program. In response to this issue, which pertained to source check forms from FY22 that were subject to review when payment was made in FY24, we have already implemented corrective measures. Under the oversight of our Director of Federal Programs, the District established and implemented comprehensive records retention procedures compliant with 2 CFR 200.303, including clear documentation requirements for federally connected children, a centralized digital repository for all Impact Aid records, a verification checklist system, and staff training on proper documentation protocols. This implementation was completed in June 2024, ensuring all records are now maintained in accordance with federal uniform guidance requirements. Expected Completion Date 07/01/2024

View Audit 346942

Finding 528885 (2024-011)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Guidance email was provided to program supervisors in February 2025, reiterating the requirement that all RESEA Checklists must be completed by staff and supervisors. Yearly file reviews – Bureau of Workforce Partnership and Operations (BWPO) is currently conducting case file reviews of the local o...

Guidance email was provided to program supervisors in February 2025, reiterating the requirement that all RESEA Checklists must be completed by staff and supervisors. Yearly file reviews – Bureau of Workforce Partnership and Operations (BWPO) is currently conducting case file reviews of the local offices. Once the review is completed, each area will get a results email with concerns and recommendations. These reviews started in September 2024 and will continue until they are completed. Anticipated completion is November 2025. Quarterly meetings were held for all local areas (2/4/25, 2/5/25 & 2/6/25). Next quarterly meetings will be held in May 2025. These meetings will reiterate the importance of following the RESEA process as detailed in the RESEA desk guide. Anticipated Completion Date: 11/30/2025 Contact Name: Dorraine Rauch, Division Chief

View Audit 346904

Finding 528884 (2024-010)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing...

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing the following from the list: - Those who registered for work. - Those exempt for other reasons. - Those denied benefits for other reasons. - Those with no payments for weeks beyond the 4th week of the claim. - The remaining individuals’ payments for the fifth week of the claim and later were totaled in January 2025: - 3,481 individuals - $22,597,596.92 - These amounts are described as “maximum” because only an individual review of each claim would reveal if the person was truly not properly registered and if weeks of benefits should be overpaid. - The Department is choosing to waive these individuals’ requirement to register based on UC law section 401(b)(6): The department may waive or alter the requirements of this subsection in cases or situations with respect to which the secretary finds that compliance with such requirements would be oppressive or which would be inconsistent with the purposes of this act. Since the individuals would currently be told of requirements they needed to meet in the past and, as a result, given debts to repay, this is oppressive in nature and inconsistent with the purpose behind the registration requirement. Anticipated Completion Date: Completed Contact Names: Stacy Walter, Management Analyst 2, Special Projects, Office of UC Service Centers; Rick Plesnarski, Management Supervisor, Special Projects Unit & Quality Assurance, Office of UC Service Centers

View Audit 346904 Questioned Costs: $1

Finding 528878 (2024-006)

Significant Deficiency 2024

Commonwealth of Pennsylvania

PA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.405 § 200.406

1. All offices will ensure timely and effective communication. The WIC Finance staff will meet with Budget Office (BO) Analysts monthly to review SAP forms, expenditure adjustments, Grant Status Reports and other fiscal items for accuracy and action. Program, budget and comptroller staff will meet a...

1. All offices will ensure timely and effective communication. The WIC Finance staff will meet with Budget Office (BO) Analysts monthly to review SAP forms, expenditure adjustments, Grant Status Reports and other fiscal items for accuracy and action. Program, budget and comptroller staff will meet at least quarterly to review expenditures, processes and needed actions for federal grants. BO and program office staff have agreed to the following verbally: Program staff will submit a final federal report three months after the end of the grant period. Program staff will monitor all active federal grant internal orders paying careful attention to expenditures that post after the close of federal grant budget period. If there is a late expenditure, program staff will revise the final report and submit it to the DOH BO for review using the BO workflow. The DOH BO will also monitor all active internal order numbers and alert the program office of any unusual transactions. The DOH BO will inform the program office of unusual transactions and add them to regular meeting agendas for further discussion and planning. DOH will create a bulletin to outline federal grant management policies and procedures and disseminate to all DOH program offices. 2. BO staff that made the error were notified and counseled on ways to minimize errors. BO shall update the workflow and expenditure adjustment instructions in coordination with the program office. 3. The credit was largely due to overcharges of costs for a Software License Agreement that was not allowed to be charged to the grant. The IT staff that initiated the overcharge and directed the program office to make the adjustment has been counseled on policy and procedures for charging expenditures to a federal source. All fiscal transactions for IT expenditures are reviewed by program staff as well as BO staff via the BO workflow. Policies and procedures specific to IT expenditures charged to a federal fund will be reviewed and updated to ensure information and instructions are robust and clear. Updated policies and procedures will be disseminated to all DOH staff with a responsibility in the process. Anticipated Completion Date: 05/31/2025 Contact Names: Steven Marsden, Audit Resolution Manager; Andrea Race, Chief Financial Officer

View Audit 346904

Finding 528827 (2024-003)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Nu...

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context : The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY22 time period ($230,281) did not agree to the underlying expenditure records ($4,290 for the period of July 1, 2021 through June 30, 2022). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Finance will review financial statements and ensure they agree to amounts reported on the annual data reports. Reviews will be documented with a signature. FTE documentation will be retained. Anticipated Completion Date: When the next report is due

View Audit 346885

Finding 528824 (2024-002)

Material Weakness 2024

Frankton Lapel Community School Corporation

IN

Allowable Costs / Cost Principles School Nutrition Programs Internal Control / Segregation of Duties § 200.303 § 200.430

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying...

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context : For 18 selections, in a sample of 40 payroll transactions, the School Corporation based the employees’ time charged to the grant on an annual time and effort log. The employee’s time was split with a non-federal fund. The School Corporation allocated the employee’s time based on a time and effort log completed in September of each year which was reviewed by the Superintendent. The School Corporation did not complete time and effort logs more frequently than annually to ensure the amounts being charged to food service were based on worked performed for each payroll period. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of doing a time study, we will fully implement an analysis of percentages paid by the school lunch program on a monthly basis. Anticipated Completion Date: Beginning of April 2025, fully implemented and corrected by the end of May 2025.

View Audit 346885

Finding 528820 (2024-004)

Material Weakness 2024

Clinton Prairie School Corporation

IN

Internal Control / Segregation of Duties School Nutrition Programs Eligibility § 200.303

FINDING 2024-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or...

FINDING 2024-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Contact Phone Number: • Jill Pollard, 765-654-4473, ext 401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: • There will be dual control on all applications Anticipated Completion Date: • 12/31/2025

View Audit 346869

Finding 528817 (2024-003)

Material Weakness 2024

Clinton Prairie School Corporation

IN

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

FINDING 2024-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or...

FINDING 2024-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context: Crowe noted there was no review of all 35 timecards selected for testing in a sample of 40 payroll transactions. The other 5 sample payroll transactions for salaried employees were tested without error. Contact Person Responsible for Corrective Action: Contact Phone Number: • Linda Burkhalter, 765-659-1339, ext 113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: • We will have dual control on all timesheets. Anticipated Completion Date: • 3/17/2025

View Audit 346869

Finding 528783 (2024-002)

Material Weakness 2024

Latin American Association, Inc.

GA

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.430

We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, a new policy was implemented that requires employees to record their time as a percentage across all grants in which they work. The employee records this allocation at least ...

We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, a new policy was implemented that requires employees to record their time as a percentage across all grants in which they work. The employee records this allocation at least weekly within a time keeping software system. Employees and supervisors are now required to review and acknowledge payroll allocations across grants by signing weekly timesheets. Timesheets will be retained and used as backup by the Grants Department when invoicing the Grantor for expense reimbursement. In addition, we have updated our Policy and Procedures Manual to reflect this policy. An additional policy was implemented in November 2024 requiring one Accounting staffer and one Grant staffer review employee timecards versus invoices prior to submission. The Policy and Procedures Manual has been updated to reflect this policy. Responsible Parties: Kimberly Yoo, CFO Whitney Gillis, Director of RD Mary Guzman, Accounting Supervisor Date Corrected: November 2024

View Audit 346843

Finding 528774 (2024-003)

None 2024

Saline County, Nebraska

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

The County will set up procedures to ensure reviews are performed that vendors are not excluded or disqualified.

View Audit 346806

Finding 528773 (2024-002)

Material Weakness 2024

Saline County, Nebraska

NE

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

County will implement procedures to ensure reporting is completed correctly.

View Audit 346806

Finding 528724 (2024-003)

Material Weakness 2024

North Miami Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Context: For the two projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the fed...

Context: For the two projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have contracts with the company that included the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $447,034 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: 765-985-3891 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: If NMCS enters into contractual agreements where Davis-Bacon rules will apply we make arrangements before the contract is signed to meet all of the necessary requirements. Anticipated Completion Date: 3/1/2025

View Audit 346755

Finding 528723 (2024-002)

Significant Deficiency 2024

North Miami Community Schools

IN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Context: For 4 selections, in a sample of 40 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support ...

Context: For 4 selections, in a sample of 40 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the ESSER III fund. The sample amount charged to the grant for split-funded employees without time and effort logs was $1,375. Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: 765-985-3891 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will implement time and effort logs for all split-funded employees. Currently we do not have any split funded employees. Anticipated Completion Date: 3/1/2025

View Audit 346755 Questioned Costs: $1

Finding 528722 (2024-001)

Significant Deficiency 2024

Froedtert Health, Inc. and Affiliates

WI

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

Corrective Actions Relating to Federal Awards: Finding 2024 001 Lack of review and approval of Time and Effort Reporting Corrective Actions Manual processes will be ...

Corrective Actions Relating to Federal Awards: Finding 2024 001 Lack of review and approval of Time and Effort Reporting Corrective Actions Manual processes will be reinforced regarding time and effort reporting (T/E) and Operations (Ops) will be instructed to hold each drawdown until all processes are completed and approved by the Grant Program Manager. Grant Program Manager will also conduct more frequent internal monitoring of completeness of records, and create an e-learning for all team members involved in the grant process regarding the steps that need to be followed. The Froedtert ThedaCare Health (FTCH) compliance team has created a proposal to implement a Grant Management Software solution. The software solution will have mechanisms for facilitating automated and streamlined processes to support time and effort documentation requirements. Specific actions to be taken include: Party Responsible Laurie Moore, Grant Program Manager Corrective Action Reinforce T/E and implement hold practice with each Ops owner expensing salaries Anticipated Completion Date April 1, 2025 Party Responsible Laurie Moore, Grant Program Manager Corrective Action Increase internal monitoring frequency for grants expensing salaries Anticipated Completion Date Beginning April 15, 2025 and ongoing thereafter Party Responsible Laurie Moore, Grant Program Manager Corrective Action Create e-learning Anticipated Completion Date Create Learning: May 1, 2025 Implementation: June 1, 2025 (If not able to do e-learn, will publish PowerPoint)

View Audit 346753

Finding 528720 (2024-001)

Significant Deficiency 2024

Seattle University

WA

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

Finding 2024-001: Department of Education Common Origination and Disbursement (COD) Reporting Corrective Action The University has reviewed its reporting controls. The responsible department has strengthened its audit process to ensure the disbursement reporting is received by the COD within the of ...

Finding 2024-001: Department of Education Common Origination and Disbursement (COD) Reporting Corrective Action The University has reviewed its reporting controls. The responsible department has strengthened its audit process to ensure the disbursement reporting is received by the COD within the of 15 day window requirement. Anticipated Date of Completion: June 2024 Person Responsible for Corrective Action Plans Joe Cater, Assistant Vice President for Finance and Controller (206) 220-8283 caterj@seattleu.edu

View Audit 346746

Finding 528682 (2024-004)

Material Weakness 2024

Central Noble Community School Corporation

IN

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

FINDING 2024-004 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 Views of Responsible Officials: We...

FINDING 2024-004 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 Views of Responsible Officials: We concur with the finding. 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. 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

View Audit 346685

Finding 528676 (2024-003)

Material Weakness 2024

Central Noble Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING: 2024-003 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Baumgartner Contact Phone Number and Email Address: 260-636-2175 baumgartnerk@centralnoble.k12.in.us Views of Responsible Officials: We concur with the fin...

FINDING: 2024-003 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Baumgartner Contact Phone Number and Email Address: 260-636-2175 baumgartnerk@centralnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review its internal control process for checking if a vendor is suspended or debarred prior to doing business with that vendor. All future expenditures triggering suspension and debarment requirements will include implementing the following procurement policies. The Business Manager will initial the supporting documentation for verifying a vendor to provide proof of compliance. Reference Suspension and Debarment Standards 2 CFR 180.300 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) Anticipated Completion Date: July 2025

View Audit 346685

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