Corrective Action Plans

Finding 517409 (2024-005)

Material Weakness 2024

Eastern Carver County Schools Independent School District No. 112

MN

Procurement, Suspension & Debarment § 200.303

Material Weakness in Internal Control Over Compliance and Other Matters Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with fede...

Material Weakness in Internal Control Over Compliance and Other Matters Recommendation: We recommend that the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. Also, the District should ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will revise its procurement and suspension/debarment procedures to fully align with the Uniform Guidance requirements. The District will implement a process to verify vendors for suspension and debarment prior to entering into any covered transactions. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025

View Audit 335365

Finding 517401 (2024-006)

Material Weakness 2024

Eastern Carver County Schools Independent School District No. 112

MN

Procurement, Suspension & Debarment § 200.303 § 200.318

Material Weakness in Internal Control Over Compliance Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. Explanation of...

Material Weakness in Internal Control Over Compliance Recommendation: We recommend the District ensures it retains all documentation for procurement methods used such as retaining all quotes/bids received, as well as formally documenting rationale for all procurement decisions made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its policies and procedures to ensure that all required documentation, including quotes, bids, and the formal rationale for procurement decisions, is retained in compliance with best practices and applicable regulations. These updates will include clear guidelines for procurement methods, documentation requirements, and accountability measures to ensure compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025

View Audit 335365

Finding 517397 (2024-004)

Material Weakness 2024

Eastern Carver County Schools Independent School District No. 112

MN

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303

Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transact...

Material Weakness in Internal Control Over Compliance Recommendation: We recommend that the District review its procurement policies and controls to ensure there is a formally documented control to ensure all vendors are checked for suspension and debarment prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures and policies over procurement and suspension and debarment to ensure that the District performs the proper suspension and debarment procedures prior to entering into a covered transaction, either through a sam.gov check or by including self-certification language in the contract. Name(s) of the contact person(s) responsible for corrective action: David Brecht, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2025

View Audit 335365

Finding 517334 (2024-001)

Material Weakness 2024

Sacramento Metropolitan Air Quality Management District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarm...

Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Finding Summary: As a result of our test work, we noted three (3) out of three (3) instances where there was no evidence that the District verified the subrecipient entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Repeat Finding from Prior Years: No Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District will develop procedures outlining the requirement to 1) access the System for Award Management (SAM) exclusion list, 2) collect a certificate from the subrecipient, or 3) add a clause or condition to the subrecipient agreement to verify that an entity that may submit invoices for federal grant-funded activities has not been debarred or suspended prior entering into the agreement with the subrecipient. Name of Responsible Person: Patricia Kepner, Controller Projected Implementation Date: March 31, 2025

View Audit 335337

Finding 517153 (2024-001)

Material Weakness 2024

Academie Lafayette

MO

Questioned Costs School Nutrition Programs Subrecipient Monitoring § 200.303

A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Con...

A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Controls 1. Eligibility Review: o DeAnn Gould, Federal Programs & Grants Coordinator, and Howard Carpenter, Director of Operations, will oversee eligibility determinations using the updated software and Attachment A for reference. o Conduct a second review of all applications to verify accuracy and compliance with eligibility criteria. 2. Regular Edit Checks: o Implement weekly edit checks in the Point of Service (POS) system to confirm correct benefits distribution. C. Staff Training 1. Regular Food and Nutrition Services (FNS) Training: o Conduct quarterly training sessions on eligibility criteria, compliance requirements, and internal control processes. o Include hands-on training for using the new software and reviewing Attachment A criteria. 2. Compliance Assessments: o Assess staff understanding post-training to identify additional support needs. D. Monitoring and Evaluation 1. Audit Schedule: o Conduct monthly internal audits to evaluate compliance and report findings to leadership. 2. Performance Metrics: o Track error rates in eligibility determinations and aim for a significant reduction by June 30, 2025. E. Addressing Questioned Costs 1. Reconciliation Plan: The Missouri Department of Elementary and Secondary Education (DESE) has informed the School that the questioned costs of $20,578.74 will be withheld from future Food Service payment requests. The School will work with DESE to ensure proper adjustments and compliance with this reconciliation plan. 2. Process Transparency: Documentation of the withholdings and their impact on future payments will be maintained and reviewed to confirm accurate reconciliation of the overclaimed amount.

View Audit 335092 Questioned Costs: $1

Finding 516973 (2024-004)

Material Weakness 2024

State of New York

NY

Eligibility Period of Performance Reporting § 200.303

New York State Education Department’s Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCES-VR) will update RSA 911 Reporting Data Validation policies and procedures. This updated policy and procedure will address the input of information provided through supporting documen...

New York State Education Department’s Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCES-VR) will update RSA 911 Reporting Data Validation policies and procedures. This updated policy and procedure will address the input of information provided through supporting documentation, the storing of supporting documents and review protocols of the RSA 911 data elements.

View Audit 334898

Finding 516972 (2024-003)

Material Weakness 2024

State of New York

NY

Questioned Costs Period of Performance Matching / Level of Effort / Earmarking § 200.1 § 200.211 § 200.303

New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR gra...

New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR grant. Additional controls will be explored to ensure that the accounting details on the payment form are accurate and entered correctly into the Statewide Financial System.

View Audit 334898 Questioned Costs: $1

Finding 516971 (2024-002)

Significant Deficiency 2024

State of New York

NY

Reporting Internal Control / Segregation of Duties § 200.303 § 200.502 § 200.510

Internal controls will be reviewed and modified as needed to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. DED will increase future communication with the Office of the State Comptroller when reporting expenditures of the SSBCI program to ins...

Internal controls will be reviewed and modified as needed to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. DED will increase future communication with the Office of the State Comptroller when reporting expenditures of the SSBCI program to insure proper categorization of technical assistance expenditures.

View Audit 334898

Finding 516971 (2024-002)

Significant Deficiency 2024

State of New York

NY

Reporting Internal Control / Segregation of Duties § 200.303 § 200.502 § 200.510

Office of the State Comptroller will review the instructions provided to State Agencies with the Sub-Schedules and consider changes to make them clearer that State Agencies should review and include all Federal expenditures for their Agency. OSC will also review the process used for determining if a...

Office of the State Comptroller will review the instructions provided to State Agencies with the Sub-Schedules and consider changes to make them clearer that State Agencies should review and include all Federal expenditures for their Agency. OSC will also review the process used for determining if any additional programs should be included on State Agency Sub-schedules.

View Audit 334898

Finding 516688 (2024-001)

Significant Deficiency 2024

Lawndale Christian Health Center and Affiliates

IL

Cash Management Matching / Level of Effort / Earmarking § 200.303 § 200.305

Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and tr...

Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and transfer of accounting roles/responsibilities like the review and approval of grant drawdown request. Name(s) of the contact person(s) responsible for corrective action: Jeff Nelson, Accounting and Financial Analysis Director Planned completion date for corrective action plan: 9/30/2024

View Audit 334674

Finding 516555 (2024-006)

Significant Deficiency 2024

United Way of the Battle Creek and Kalamazoo Region

MI

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

Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on journal entries related to their federal grant program. Without a review process, there is an increased risk of inaccurate financial reporting and potential noncompliance. A...

Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on journal entries related to their federal grant program. Without a review process, there is an increased risk of inaccurate financial reporting and potential noncompliance. Auditor Recommendation. We recommend that the Organization implement a formal review and approval process for all journal entries related to federal grant programs. Corrective Action. Management will implement an independent monthly review of all journal entries, including those related to the federal grant programs. The designated reviewer will be a senior accounting team member or equivalent who does not have the ability to create or approve journal entries in the general ledger system. The designated reviewer will compare the entries to ensure proper documentation, accurate amounts, correct coding, and compliance with the applicable federal grant regulations. Any discrepancies or issues identified during the review will be documented, and corrective actions will be taken immediately. The reviewer will sign off on the entries, confirming that all journal entries meet required standards. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. March 31, 2025

View Audit 334487

Finding 516521 (2024-001)

Significant Deficiency 2024

Husson University

ME

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

Finding 2024-001 Return to Title IV Condition While testing R2T4, the University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. RESPONSE: Husson University agrees with this finding. The financial aid office had staff turn-over that lead to new s...

Finding 2024-001 Return to Title IV Condition While testing R2T4, the University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. RESPONSE: Husson University agrees with this finding. The financial aid office had staff turn-over that lead to new staff taking over this function. As part of the training, the staff who performed these calculations were under the impression that no secondary review was required for students who earned 100% of the awarded financial aid based on withdrawal after the 60% point of the payment period. CORRECTIVE ACTION: Husson reviewed all calculations completed after 60% point of the term for 2023-2024 to ensure they were accurate. Moving forward all R2T4 calculations are reviewed by a second individual. A staff training was completed to ensure that the financial aid staff understand that a second review is required for all R2T4 calculations completed to ensure the calculation is accurate regardless of the % of term completed. RESPONSIBLE PARTY: Sherry Watson, Director of Financial Aid COMPLETION DATE: July 2024

View Audit 334430

Finding 516466 (2024-002)

Material Weakness 2024

Community Foundation of Northwest Indiana, Inc.

IN

Procurement, Suspension & Debarment § 200.303 § 200.318

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 2...

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 29, 2026 A material weakness was issued related to internal control over suppliers under the UG audit. CFNI recognizes the need to comply with the procurement standards outlined in 2 CFR §§ 200.318-326, which require written policies addressing competition, conflicts of interest, procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurement), oversight, efforts to engage small and disadvantaged businesses, and procurement of recovered materials, among others. To address this deficiency, CFNI is committed to enhancing its documented procurement policies for procure-to-pay processes involving federal funds. The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists—periodic PeopleSoft program checks and an annual review by a third-party vendor—no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors. CFNI will develop and implement a robust supplier management policy, incorporating requirements for procurement, suspension, and debarment reviews. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

View Audit 334378

Finding 516386 (2024-006)

Significant Deficiency 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no...

Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no longer using a Tier One processor for our financial aid refunds. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented July 2024 when we changed from Bank Mobile to TouchNet.

View Audit 334325

Finding 516382 (2024-005)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are wo...

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working on an updated WISP and plan to have it approved by college administration prior to the end of the academic year. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: 6/30/2025

View Audit 334325

Finding 516378 (2024-004)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and a...

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025

View Audit 334325

Finding 516374 (2024-003)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024

View Audit 334325

Finding 516372 (2024-002)

Significant Deficiency 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation...

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have updated our procedure to reconcile Pell and Loans twice monthly to be able to catch any reporting errors within the 15-day reporting window. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516371 (2024-001)

Significant Deficiency 2024

Clatsop Community College

OR

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

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516370 (2024-002)

Significant Deficiency 2024

National Trust for Historic Preservation in the United States

DC

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

2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing...

2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing monitoring of federal awards. The current internal control policies and procedures will be strengthened and enforced to ensure employees are preparing and certifying, and supervisors and/or program managers are approving hours charged to all federal projects monthly. Individual(s) Responsible for Corrective Action Plan: John Chomiak Chief Financial & Administration Officer, NMSC 312-610-5615 Anticipated Completion Date: June 30, 2025

View Audit 334317

Finding 516273 (2024-002)

Significant Deficiency 2024

Anne Arundel County Board of Education

MD

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-...

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the Board continue with established policies and procedures implemented in November 2023 to ensure that documentation supporting the Board’s review and approval of the monthly FSR reimbursement requests are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Reporting and Grants Management will ensure that the Board’s review and approval of monthly FSR reimbursement requests and documented and retained. Name(s) of the contact person(s) responsible for corrective action: Ruth Grasty Director of Financial Reporting and Grants Management Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 334095

Finding 516272 (2024-001)

Significant Deficiency 2024

Anne Arundel County Board of Education

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-...

2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Purchasing Office had processes in place to ensure debarment status was checked before contract award. Both the contract checklist (attached) and the Qualifications Affidavit in the solicitation template contained debarment status language to ensure the necessary checks took place. Despite these processes, a contract for curriculum materials was not checked for debarment status before contract award. The cause of that oversight seems to be the different procurement processes used in instructional materials procurements. The contract was not competitively awarded, so they did not require a qualifications affidavit, which would have ensured the debarment status was checked. In this instance, a checklist was not included in the contract file as required, which would have also triggered a debarment check. In response, the Purchasing Office is adding a third layer of oversight - requiring that a revised contract affidavit (sample attached) is completed for every contract award. Language was added to the current contract affidavit that contains an affirmation by the contractor that they are not suspended or debarred by any government entity – local, state, and federal. The relevant section is highlighted in the attachment. To summarize, the Purchasing Office will engage the three processes listed below to ensure timely debarment checks are conducted on every contract, regardless of funding source. 1) Contract Checklist 2) Qualifications Affidavit 3) Contract Affidavit Name(s) of the contact person(s) responsible for corrective action: Mary Jo Childs Director of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 334095

Finding 515828 (2024-001)

Significant Deficiency 2024

Catholic Charities of the Diocese of Tulsa, Inc.

OK

Questioned Costs Allowable Costs / Cost Principles § 200.303

Audit Finding Reference: 2024-001 Department's Response: We concur. Views of Responsible Officials and Corrective Action: There were not sufficient controls to ensure accurate payroll expenditures were submitted for reimbursement. Payroll in excess of $31,565 was charged to the grant. CCEOK has i...

Audit Finding Reference: 2024-001 Department's Response: We concur. Views of Responsible Officials and Corrective Action: There were not sufficient controls to ensure accurate payroll expenditures were submitted for reimbursement. Payroll in excess of $31,565 was charged to the grant. CCEOK has implemented a more robust review process that includes all payroll expenditures billed to the grant are traced back to supporting details. CCEOK will reimburse the overbilled amounts to the funder. Name of Contact Person: Lisa Wheeler, CPA Director of Finance Lwheeler@CCEOK.org 918-508-7118 Date of Implementation: October 2024

View Audit 333690 Questioned Costs: $1

Finding 515730 (2024-001)

Significant Deficiency 2024

School District No. 1 in the City & County of Denver & State of CO

CO

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Finding: The District did not have signed acknowledgement forms for two of the schools selected to detail their understanding of the District's assessment system security policies for the 2023-2024 school year. Cause: The District did not have a tracking system in place to ensure that signed acknowl...

Finding: The District did not have signed acknowledgement forms for two of the schools selected to detail their understanding of the District's assessment system security policies for the 2023-2024 school year. Cause: The District did not have a tracking system in place to ensure that signed acknowledgement forms for all District schools were received. Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a tracking tool to help ensure that all schools within the District return the required acknowledgement form on an annual basis. Corrective Action: Moving forward, the school Accountability Leader(SAL) will be required to sign the Security Plan and return it to the Assessment team. The school SAL will also be required to complete a Google form to confirm the completion of the Security plan. Prior to the start of testing for the school, the Assessment Team will audit the Google form responses and follow up with each school that has not completed the form. Escalation Plan: Assessment Team will remind the school SAL via email one time prior to testing; 2nd email notification will include the school leader; 3rd email notification will include the Collaborative Director. Person Responsible for Implementing: Mackenzie Lane - Director, Assessment Implementation Date: 10/30/2024 Status: In Progress

View Audit 333583

Finding 514375 (2024-004)

Significant Deficiency 2024

Danville Area Community College

IL

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties § 200.303

Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the College work to update the written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreeme...

Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the College work to update the written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act. Name of the contact person responsible for corrective action: Carl Lewis, Assistant Vice President and Chief Information Officer Planned completion date for corrective action plan: June 30, 2025

View Audit 332657

Corrective Action Plans

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