Corrective Action Plans

Finding 524390 (2024-002)

Significant Deficiency 2024

IL

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

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-002 Finding: Improper Controls Over Personnel Expenses Applicable Regulation: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that a...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-002 Finding: Improper Controls Over Personnel Expenses Applicable Regulation: Uniform Grant Guidance (2 CFR 200.430(g)(1)(i)) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Finding: A KHSU supervisor did not properly document approval for one employee’s personnel activity reports. Corrective Action Taken or Planned: Upon being notified by the auditors of this specific issue, the organization took immediate steps to address the finding. The missing documentation for the personnel activity report was located and the supervisor provided retroactive written approval. The updated Personnel Activity Report was submitted to KDADS. This corrective action resolved the specific instance during the audit. In addition, the following will be implemented: 1. Development and Implementation of a Standard Operating Plan • A SOP for reviewing and documenting approvals of personnel activity reports (PARs) will be developed. • The procedure will include detailed steps for supervisors to review, approve, and retain documentation of PARs. 2. Training for Supervisors • All supervisors responsible for approving PARs will have one-on-one training on the new SOP by the Chief Financial Officer, emphasizing the importance of proper documentation to comply with internal controls and audit standards. • Training sessions will be scheduled. 3. Implementation of Monitoring Controls • A secondary review process will be introduced to ensure compliance with the new procedures, including review by the Principal Investigator. • The Grants Management Office or an equivalent oversight body will conduct periodic audits of PAR documentation to verify proper approvals. Contact Person: Matt Ankenbrandt, Chief Financial Officer mankenbrandt@kansashsc.org Anticipated Completion Date: 2/15/25

View Audit 343627

Finding 524389 (2024-001)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

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

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, oth...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343627

Finding 524368 (2024-004)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating memb...

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

View Audit 343584

Finding 524366 (2024-003)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were ...

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

View Audit 343584

Finding 524362 (2024-002)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

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

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was respo...

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was responsible for the preparation and submission of the Form 9. There were no documented internal controls in place such as an oversight, review, or approval process to ensure expenditures were correctly reported. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding 􀁹􀈱EVERY􀈱CHILD􀈱􀁹􀈱EVERY􀈱CHANCE􀈱􀁹􀈱EVERY􀈱DAY􀈱􀁹 JAC􀈬CEN􀈬DEL􀈱COMMUNITY􀈱SCHOOLS CENTRAL OFFICE HIGH SCHOOL / ATHLETICS ELEMENTARY SCHOOL 723 N Buckeye Street 4586 N US 421 4544 N US 421 Osgood, Indiana 47037 Osgood, Indiana 47037 Osgood, Indiana 47037 Telephone: (812) 689-4114 Telephone: (812) 689-4643 Telephone: (812) 689-4144 www.jaccendel.k12.in.us Fax: (812) 689-7423 Fax: (812) 689-5632 Fax: (812) 689-5909 INDIANA STATE BOARD OF ACCOUNTS 26 Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for. I actually printed the Form 9 transmittal report that has the accounts and amounts on it and had the Superintendent review it and sign off on it for the December 2024 Form 9. This will be our process moving forward. Anticipated Completion Date: With the completion of the most recent form 9 December 31, 2024.

View Audit 343584

Finding 524336 (2024-001)

None 2024

South Cook County Intermediate Service Center #4

IL

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant...

CONDITION: The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant requirements, we noted the following: For Public Safety Partnership and Community Policing Grants - • One of 2 (50%) quarterly federal financial reports were submitted 36 days late. • One of 1 (100%) semi-annual performance report was submitted 47 days late. For McKinney-Vento Education for Homeless Children and Youth - • Four of 4 (100%) quarterly expenditure reports and the Grant Accountability and Transparency Act (GATA) reports were submitted but the South Cook Intermediate Service Center #4 was unable to provide proof of submission; therefore, we were unable to determine if the required reports were submitted timely or at all. • South Cook Intermediate Service Center #4 did not formally establish a Community Advisory Group. PLAN: Management will develop more formal and comprehensive grant monitoring procedures that will include a checklist for all the necessary reporting and compliance requirements. Specifically for the Mc-Kinney Vento grant, formal documentation for the established Community Advisory Group will be obtained in consultation with the grantor. ANTICIPATED DATE OF COMPLETION: June 30, 2025 CONTACT PERSON: Dr. Anthony Marinello, Executive Director

View Audit 343535

Finding 524224 (2024-002)

Significant Deficiency 2024

Staywell Healthcare, Inc.

CT

Eligibility Subrecipient Monitoring Significant Deficiency § 200.303

2024.02 - Eligibility Recommendation We recommend that management provide training to those responsible for verifying eligibility to ensure that documentation and internal control over eligibility is maintained. Action Taken 1) To ensure patient eligibility is properly assigned to patients, the Dir...

2024.02 - Eligibility Recommendation We recommend that management provide training to those responsible for verifying eligibility to ensure that documentation and internal control over eligibility is maintained. Action Taken 1) To ensure patient eligibility is properly assigned to patients, the Director of Clinical Operations will perform random audits on a Monthly basis of patients that are assigned. 2) The Director of Clinical Operations will also ensure proper training to those that are assigning eligibility to ensure that proper documentation is obtained and properly stored. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Eric Newman, CFO at (203) 756-8021 x 3015. Sincerely yours, Eric Newman Chief Financial Officer

View Audit 343418

Finding 524210 (2024-006)

Significant Deficiency 2024

Montcalm Community College

MI

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

2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College ...

2024-006 – Common Origination and Disbursement (COD) Reporting. Auditor Description of Condition and Effect. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Auditor Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Corrective Action. I have a procedure in place to report graduates as soon as they are confirmed with academics. Responsible Party. Financial Aid Director, Jennifer Stimson. Anticipated Completion Date. January 2025.

View Audit 343397

Finding 524171 (2024-001)

Material Weakness 2024

Louisiana Delta Service Corps

LA

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Management Response: Due to the size of LDSC’s administrative staff, complete segregation of duties is not economically feasible. We will ensure the areas recommended above are added to our current policy to the extent it is economically feasible.

View Audit 343346

Finding 524152 (2024-005)

Material Weakness 2024

City of Santa Fe

NM

Equipment & Real Property Management § 200.303 § 200.313

Auditor recommendation: The auditor recommends the City enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory should be trained to ensure understanding of ...

Auditor recommendation: The auditor recommends the City enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory should be trained to ensure understanding of the Uniform Guidance requirements relevant to equipment and real property management. Periodic review should also be designed to evaluate compliance with relevant requirements. Views of Responsible Oﬃcials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this ﬁnding. During FY24 the Airport Manager hired a Heavy Equipment Mechanic. This posi􀀁on is responsible for tracking, maintaining, and repairing Airport equipment. Logbooks are now being kept for all equipment. In CY25 the Finance Director, the Accoun􀀁ng Oﬃcer, and the Grants team will work with the Airport team to improve internal controls over equipment purchased with federal funds. Policies and procedures will be developed to ensure that an accurate physical inventory that contains the informa􀀁on required by the Uniform Guidance is conducted at year-end. The City is in the process of contrac􀀁ng with a vendor to assist the Airport with federal compliance and provide training for Airport staﬀ on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures related to equipment management. Tools will be developed to facilitate tracking and maintaining equipment purchased with federal funds. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly. The Grant Accountant will also work with the Airport Heavy Equipment Mechanic to ensure that the inventory lis􀀁ng includes the funding source used for the purchase (i.e. federal or non-federal). In CY25 the City plans to provide Uniform Guidance to staﬀ which will include capital assets and equipment informa􀀁on, and the speciﬁc requirements for the year-end inventory. Responsible Official: Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

View Audit 343340

Finding 524151 (2024-004)

Significant Deficiency 2024

City of Santa Fe

NM

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

Auditor recommendation: The auditor recommends that the City implement a final review for potential duplicated costs prior to approving reimbursement requests, and adjust the general ledger for any such items noted. Views of Responsible Oﬃcials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this...

Auditor recommendation: The auditor recommends that the City implement a final review for potential duplicated costs prior to approving reimbursement requests, and adjust the general ledger for any such items noted. Views of Responsible Oﬃcials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this ﬁnding. A reimbursement request was submi􀀂ed 3/18/24 in the amount of $634,532.45. It was later iden􀀁ﬁed that the reimbursement request included duplicate payroll expenditures in the amount of $2,694. One of the duplicated items, totaling $1,115, was iden􀀁ﬁed through internal review within the City of Santa Fe a􀀃er the reimbursement request was submi􀀂ed. A credit memo has been processed in the FAA’s Delphi system and the City has repaid the $1,115 amount that was duplicated. The other item, totaling $1,579, was iden􀀁ﬁed through the external audit. The City will process an addi􀀁onal credit memo and repay the $1,579 amount promptly. The Finance Director, the Accoun􀀁ng Oﬃcer, and the Grants team are working with the Airport team to strengthen policies and procedures and ensure a full review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement requests being submi􀀂ed. A secondary review by the Finance Department of all Airport requests for reimbursement is now occurring prior to submission to FAA. In addi􀀁on, we have started using employee pay advices as addi􀀁onal suppor􀀁ng documenta􀀁on for reimbursement requests. In the past excel spreadsheets were used as suppor􀀁ng documenta􀀁on, and the Finance Department review some􀀁mes happened a􀀃er the reimbursement request was submi􀀂ed. Vacancies in key posi􀀁ons resulted in a lack of robust review of reimbursement requests prior to submission. These key posi􀀁ons have now been ﬁlled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The Accoun􀀁ng Oﬃcer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been ﬁlled, and the Grants Division is now fully staﬀed. More robust staﬃng is allowing Finance to work more closely with the Airport team. One of the primary du􀀁es of the new Accoun􀀁ng Financial Analyst in the Grants Division is to support the administra􀀁on of Airport grants. The City is in the process of contrac􀀁ng with a vendor to assist the Airport with federal compliance and provide training for Airport staﬀ on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. The Finance Department will con􀀁nue to perform a secondary review of Airport requests for reimbursement prior to submission to FAA. In CY25 the City plans to provide Uniform Guidance training for staﬀ which will include internal controls related to ac􀀁vi􀀁es allowed and allowable costs. Responsible Official: Emily Oster, Finance Director, James Harris, Airport Manager, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

View Audit 343340 Questioned Costs: $1

Finding 524150 (2024-003)

Significant Deficiency 2024

City of Santa Fe

NM

Cash Management Reporting Significant Deficiency § 200.302 § 200.303

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Oﬃcials and Planned Correc􀀁ve Ac􀀁on: The ...

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Oﬃcials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this ﬁnding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not suﬃcient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been ﬁlled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Oﬃcer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been ﬁlled, and the Grants Division is now fully staﬀed. More robust staﬃng is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staﬀ. Filling these key posi􀀁ons and retaining qualiﬁed staﬀ is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staﬀ on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staﬀ which will include internal controls related to cash management. Responsible Oﬃcial:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

View Audit 343340

Finding 524021 (2024-005)

Significant Deficiency 2024

Northwestern Health Sciences University

MN

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

Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: F...

Documentation of Review Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will send a reconciliation to the Controller by the 10th business day. The controller will review and approve by the 15th business day. Name of the contact person responsible for corrective action: Scott Roelke, Director of Financial Aid Planned completion date for corrective action plan: 2/4/2025

View Audit 343204

Finding 523623 (2024-002)

Material Weakness 2024

Union Township School Corporation

IN

Procurement, Suspension & Debarment § 200.303

FINDING 2024-002 Finding Subject: Special Education Cluster - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Allen Cochran Contact Phone Number and Email Address: 219-759-2531, acochran@union.k12.in.us Views of Responsi...

FINDING 2024-002 Finding Subject: Special Education Cluster - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Allen Cochran Contact Phone Number and Email Address: 219-759-2531, acochran@union.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Business Manager will work with the Special Education Coop to ensure compliance with the Suspension and Debarment requirement. Anticipated Completion Date: February 28, 2025

View Audit 343018

Finding 523587 (2024-004)

Significant Deficiency 2024

Lyford Consolidated Independent School District

TX

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Reference Number: 2024-004 Proper review of payroll charges to grant funds Corrective Action Plan: The District will review the current policies and procedures of internal controls over payroll charges related to federal awards and implement controls that will adequately monitor the activity charg...

Reference Number: 2024-004 Proper review of payroll charges to grant funds Corrective Action Plan: The District will review the current policies and procedures of internal controls over payroll charges related to federal awards and implement controls that will adequately monitor the activity charged to programs. Contact Person: Vicki Perez, CFO Implementation Time Frame: August 31, 2025

View Audit 342909

Finding 523550 (2024-003)

Material Weakness 2024

Middlebury Community Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.400

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: Material Weakness, Other Matters The School District is required to set aside a reasonable amount of funds to meet the needs of the homeless population in the school community. These funds...

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: Material Weakness, Other Matters The School District is required to set aside a reasonable amount of funds to meet the needs of the homeless population in the school community. These funds cannot be used for any other purpose than the needs of the homeless population. At the end of the grant period, unspent funds must be carried forward to the next grant year. If the school district meets the obligation of attempting to spend the homeless set-aside funds, the funds may be carried over into the general Title I award for the next grant. The funds are not required to go back into the homeless reservation. The 2021-2022 grant award homeless reservation was $8,600. The School Corporation did not spend any of these funds, but was determined to have met their obligation based on documentation provided. The School Corporation did not provide evidence that the $8,600 was carried over to the next school year. However, it was determined that $276 of the $8,600 was used inappropriately in the current school year for other Title I, Part A activities, and not for the needs of the homeless student population. This noncompliance and lack of internal controls was isolated to the 2022-23 school year. Contact Person Responsible for Corrective Action: Kari Dyer Contact Phone Number and Email Address: (574)825-9425; dyerk@mcsin-k12.org Views of Responsible Officials: The School District concurs with this finding. Homeless Reservation funds should only be used for the needs of the homeless student population. Description of Corrective Action Plan: The School District is implementing new monitoring procedures for the Title I Fund to verify unspent funds for the Homeless Reservation are not used for any other Title I expenses. After the 2022-23 school year, the School District changed the way in which it expends the Homeless Reservation by utilizing these funds for salary and benefits of a Homeless Laision. Monitoring these expenditures requires dual signature approvals by the Business Assistant and the Title I Program Director prior to being released. Anticipated Completion Date: Immediate

View Audit 342839

Finding 523549 (2024-002)

Material Weakness 2024

Middlebury Community Schools

IN

Internal Control / Segregation of Duties Eligibility Material Weakness § 200.303

FINDING 2024-002 􀀃 􀀃 Finding Subject: Title I Grants to Local Education Agencies – Internal Controls Over Eligibility 􀀃 Summary of Finding: Material Weakness:􀀃 Though no errors were found in the Title I application, a documented internal control plan needs to be in place to ensure that the Enrollmen...

FINDING 2024-002 􀀃 􀀃 Finding Subject: Title I Grants to Local Education Agencies – Internal Controls Over Eligibility 􀀃 Summary of Finding: Material Weakness:􀀃 Though no errors were found in the Title I application, a documented internal control plan needs to be in place to ensure that the Enrollment ad Poverty numbers inputted into the Title I Application by the IDOE matches the School Corporation’s internal records (Real Time Reports). This checks and balances for monitoring the Enrollment and Poverty numbers on the Title I application could reduce the risk of errors. 􀀃 Contact Person Responsible for Corrective Action: Kari Dyer 􀀃 Contact Phone Number and Email Address: (574)825-9425, dyerk@mcsin-k12.org Views of Responsible Officials: We concur with the finding. Though no discrepancies were found between the LEA and the Enrollment and Poverty numbers populated by the IDOE in the Title I Application, a checks and balances needs to be in place to ensure accuracy in the Title I application, reducing the risk for error and ensuring the LEA allocates funds appropriately. Description of Corrective Action Plan: The School Corporation plans to take the following action: 􀁸 Develop a dual signature page requiring verification from Title I Program Director and MCS Data Manager that IDOE Enrollment and Poverty numbers populated in the Title I Application match the LEA internal records from the October 1 count day of the previous school year. This internal control document will be titled Enrollment and Poverty Verification. 􀁸 Utilize and maintain record of the Enrollment and Poverty Verification signature form during the Title I Application period to ensure the alignment of IDOE data and LEA enrollment and poverty numbers in the Title I application. Verification from both the Title I Program Director and the MCS Data Manager will be required. o Upon submission of Oct. 1 ADM, the MCS Data Manager will supply ADM information on the Enrollment and Poverty Verification form to the Title I Program Director. o During the creation of the Title I budget application, Title I Program Director will cross-reference and verify Oct. 1 ADM data with the Enrollment and Poverty numbers populated by the IDOE in the Title I application, addressing discrepancies with the IDOE Title Grant Specialist should they occur. Anticipated Completion Date: Winter 2025: Internal Control process written for Enrollment and Poverty Verification Winter 2025: Creation of Enrollment and Poverty Verification signature form. Annually: Utilization of the Enrollment and Poverty Verification process and signature form during the October ADM process and during the Title I Application process. The first use of the form will be in winter, 2025 to document Oct.1, 2024 enrollment and poverty numbers with the first verification occurring during the fall, 2025 Title I Budget Application process for SY25-26.

View Audit 342839

Finding 523534 (2024-003)

Material Weakness 2024

Boys and Girls Club of Dane County, Inc.

WI

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Recommendation: Procedures should be designed, implemented, and documented for matching requirements to ensure documentation of review and approval of required match amounts and allowability to be charged to the federal award. Action Taken: Boys & Girls Clubs of Dane County is establishing a forma...

Recommendation: Procedures should be designed, implemented, and documented for matching requirements to ensure documentation of review and approval of required match amounts and allowability to be charged to the federal award. Action Taken: Boys & Girls Clubs of Dane County is establishing a formal policy around grant matching in accordance with 2 CFR 200.303. Grants Compliance will work with Finance to review the matched costs submitted by departments. This reconciliation/review will be performed monthly. The individuals responsible are: Sr. Director of Grants & Compliance, Controller, Finance Operations Administrator, PI/Program Managers over respective grants. The anticipated completion date is March 31, 2025.

View Audit 342825

Finding 523504 (2024-002)

Material Weakness 2024

School Town of Munster

IN

Equipment & Real Property Management § 200.303 § 200.313

FINDING 2024-002 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation failed to add improvements paid for out of ESSER monies to the capital asset listing and complete physical inventories were not completed. Contact Person...

FINDING 2024-002 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation failed to add improvements paid for out of ESSER monies to the capital asset listing and complete physical inventories were not completed. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and Email Address: (219)836-9111 jbespinoza@munster.us Views of Responsible Officials: We concur with the finding. The School Corporation plans to complete a physical inventory of assets this year and every two years, thereafter. Description of Corrective Action Plan: The Director of Operations will share inventory listings with each building. An STM employee will conduct the inventory and it will be reviewed by a supervisor and signed off on. The sources of funding will also be added to the School Corporation’s inventory listing to easily identify equipment paid for out of Federal dollars. Anticipated Completion Date: Fall 2025

View Audit 342775

Finding 523500 (2024-001)

Material Weakness 2024

School Town of Munster

IN

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

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not verify that a vendor was neither suspended nor debarred. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and...

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not verify that a vendor was neither suspended nor debarred. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and Email Address: (219)836-9111 jbespinoza@munster.us Views of Responsible Officials: We concur with the finding. All vendors have been verified for suspension and debarment, thereafter. This was the only vendor that was missed. All employees have been trained to check for vendor suspension or debarment. Description of Corrective Action Plan: The School Corporation will ensure that the vendor is either listed in SAM.gov or states in their contract that they are neither suspended nor debarred. Anticipated Completion Date: March 2025

View Audit 342775

Finding 523499 (2024-001)

Significant Deficiency 2024

The United Methodist Children's Home of the North Georgia Conference, Inc.

GA

Reporting § 200.303

Grantee Response and Corrective Action Plan: Management agrees with the findings. The Organization has hired a Senior Accountant who is responsible for grant reporting including quarterly Federal Financial Reporting (FFR). Additionally, to ensure the quarterly FFR’s are timely and properly document,...

Grantee Response and Corrective Action Plan: Management agrees with the findings. The Organization has hired a Senior Accountant who is responsible for grant reporting including quarterly Federal Financial Reporting (FFR). Additionally, to ensure the quarterly FFR’s are timely and properly document, current policies and procedure have been updated to include the following: • Senior Accounting will prepare the SF-425 by the 5th of the month after the end of the quarter and email the report to the Controller. • The Controller will review the SF-425 for accuracy and forward report to the Chief Operating Officer for approval. • The Controller will forward the approved SF-425 to the Senior Accountant for release to the awarding agency. • The Senior Accountant will email the report to the account liaison of the awarding agency no later than the 15th of the reporting period and copy the Controller on the submission. • The Senior Accountant and Controller will maintain a digital record of the SF-425 and of the submission communication to the awarding agency.

View Audit 342768

Finding 523460 (2024-007)

Material Weakness 2024

Crawfordsville Community School Corporation

IN

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

Information on the federal program: Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, 84.425W Federal Award Numbe...

Information on the federal program: Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, 84.425W Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Other Matters Context: For 1 selection, 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 another federal grant; however, the School Corporation did not have support for the allocation of the time charged to the Education Stabilization Fund grant. Contact Person Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Contact Phone Number: 765-362-2342 x6 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Activities Allowed or Unallowed and allowable Costs/Cost Principles for the Education Stabilization Fund. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. The School Corporation will also implement procedures to determine proper splits for employees who are not paid from one singular Federal Grant and completion of appropriate Time and Effort Reporting. Anticipated Completion Date: We expect this Corrective Action to be implemented as of the current date due to this grant being completed and the School Corporation is not expected to have these grant funds in the future.

View Audit 342716 Questioned Costs: $1

Finding 523458 (2024-006)

Significant Deficiency 2024

Crawfordsville Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Reporting § 200.303

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers: S425D210013, S425U210013 Pass-Through Enti...

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers: S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Significant Deficiency Context: For the three projects sampled for Davis-Bacon requirements, the contracts with the companies did not include the clauses for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $1,367,798. The School Corporation did obtain the weekly payroll reports certifications from the companies that performed renovations. Contact Person Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Contact Phone Number: 765-362-2342 x6 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Special Tests and Provisions – Wage Rate Requirements for the Education Stabilization Fund. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented as of the current date due to this grant being completed and the School Corporation is not expected to have these grant funds in the future.

View Audit 342716

Finding 523453 (2024-004)

Material Weakness 2024

Crawfordsville Community School Corporation

IN

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

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Feder...

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Other Matters Context: For 5 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 another federal grant, however, the School Corporation did not have support for the allocation of the time charged to the Title I grant. Additionally, for three selections, the School Corporation charged a higher percentage to the Title I grant than what the time and effort log percentage showed. Contact Person Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Contact Phone Number: 765-362-2342 x6 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Activities Allowed or Unallowed and allowable Costs/Cost Principles for the Title I Program. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. The School Corporation will also implement procedures to determine proper splits for employees who are not paid from one singular Federal Grant and completion of appropriate Time and Effort Reporting. Anticipated Completion Date: We expect this Corrective Action to be implemented by the end of the current 6-month period in June 2025.

View Audit 342716 Questioned Costs: $1

Finding 523447 (2024-003)

Significant Deficiency 2024

Crawfordsville Community School Corporation

IN

Procurement, Suspension & Debarment School Nutrition Programs § 200.303 § 200.318 § 200.320

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, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listing...

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, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation did not obtain quotes from an adequate number of qualified sources. Additionally, the School Corporation did not perform a suspension and debarment check on the vendors. The sample items were for $76,200 and $31,639 worth of repair supplies in FY2023 and FY2024, respectively. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Procurement and Suspension and Debarment for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by the end of March 2025.

View Audit 342716

Corrective Action Plans

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