Corrective Action Plans

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Management agrees with the finding. Management has already corrected by reducing the most recent drawdown from HRSA by the amount in question ($6,405). Management will also implement additional review procedures to prevent similar errors in the future.
Management agrees with the finding. Management has already corrected by reducing the most recent drawdown from HRSA by the amount in question ($6,405). Management will also implement additional review procedures to prevent similar errors in the future.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedur...
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedures governing the administration of proportionate share funds for non-public schools to ensure compliance with federal grant requirements. (see IDEA Procurement Plan Earmarking for Non Pub CEIS Funds hyperlinked above) • Strengthening Internal Controls o Additional internal controls will be implemented requiring review and approval by the Director of Special Education, Bookkeeper, and Rensselaer Central Treasurer prior to any reimbursement related to non-public school expenditures funded through the Special Education grant. • Reimbursement Process Changes o Non-public schools will no longer receive reimbursements directly from Cooperative School Services. Cooperative School Services will receive approval and verification from the Non-Public School LEA. o All reimbursement requests must include detailed documentation demonstrating that the expenditure directly benefits eligible non-public school students receiving special education services. • Allowable Cost Verification o Rensselaer Central and Cooperative School Services will implement a verification process to ensure all expenditures comply with federal allowable cost requirements and that funds are used solely for the benefit of eligible non-public school students. • Staff Training o Rensselaer Central and Cooperative School Services personnel responsible for federal grant oversight will receive training on federal grant compliance requirements, including allowable and unallowable expenditures (e.g., gift cards and similar incentives). • Monitoring and Oversight o Rensselaer Central will conduct periodic monitoring of expenditures made on its behalf by Cooperative School Services and maintain documentation demonstrating compliance with oversight responsibilities. • Implementation Timeline o These corrective actions and revised procedures have already been implemented and will apply to all future federal Special Education grant expenditures. • Ongoing Compliance Monitoring o Rensselaer Central and Cooperative School Services will conduct annual reviews of federal grant expenditures and internal controls to ensure continued compliance with IDOE and federal grant requirements. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management ...
Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management will also communicate via our Financial Administrative Bulletin to the grants administration community our internal controls around 2 CFR 200. Management will conduct 2 CFR 200 training with the impacted departmental grant administration by March 5, 2026 Completion Date: March 31, 2026 Contact Person: Paul Gasior 443-997-8141
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beth Quinn Contact Phone Number and Email Address: 260-728-3306 quinnb@nadams.k12.in.us Contact Person Responsible for Corrective Action: Abi West, Director of Special Ed...
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beth Quinn Contact Phone Number and Email Address: 260-728-3306 quinnb@nadams.k12.in.us Contact Person Responsible for Corrective Action: Abi West, Director of Special Education Contact Phone Number and Email Address: 260-824-5880 awest@awssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Cooperative maintains a tracking spreadsheet to monitor hours worked by staff providing services to non-public students. Staff member will record K-12 and preschool hours separately on their Time and Effort Log. The Cooperative will then document these hours, distinguishing between Part B funds and Preschool funds. For kindergarten-aged students, the Speech-Language Pathologist will collaborate with the Student Record Administrative Assistant to identify students eligible under Section 5a (619 funding). Specifically, these are kindergarten students who are not yet six years old as of December 1. Such students are funded through both the 611 and 619 grants. Time and effort for preschool students, including 5a students, will be prioritized to the 619 grant until its allocated funds are fully expended. Once the 619 funds are exhausted, effort will be shifted to the 611 grant accordingly. Proportionate share reports will be based on actual expenditures within the six-month period, as reflected in our tracking spreadsheet. This process will be corrected for FY 2023 (611 and 610) and FY 2024 (611 and 910) to ensure compliance and prevent recurrence of similar findings in the next audit cycle. Anticipated Completion Date: September 1, 2025
Information on the federal program : Subject: Child Nutrition Cluster (CNC) 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): FY2...
Information on the federal program : Subject: Child Nutrition Cluster (CNC) 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): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed and Unallowed, Allowable Costs Audit Findings: Material Weakness, Other Matters Condition : The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context : During our testing of the School Corporation’s compliance with the allowable cost requirements for the Child Nutrition Cluster (CNC), we tested 40 vendor disbursement transactions and 40 payroll disbursement transactions and identified the following exceptions: 1. For one vendor disbursement, the School Corporation incorrectly recorded the disbursement for $820 to Fund 800 (School Lunch Fund) that should have been recorded to Fund 300 (Operations Fund), resulting in an unallowable cost being charged to the food service fund. 2. For one payroll disbursement, the School Corporation inaccurately entered the number of hours worked by a cafeteria employee for one pay period, resulting in an overpayment to the employee by $5,568. The employee notified the School Corporation of the overpayment and remitted the overpayment back to the School Corporation. These errors were attributable to deficiencies in the internal controls over the review and approval of vendor and payroll expenditures. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : Management will enhance controls and review processes surrounding vendor and payroll expenditures charged to the Child Nutrition. The Food Service Director will be receiving periodic reports to review expenditures charged to the CNC to monitor charged costs. The payroll exceptions report is now checked by the Executive Assistant and Payroll. Responsible Party and Timeline for Completion : Immediately corrected
Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hour...
Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request.
Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers...
Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-ARP, 24611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Context: During fiscal year 2023-2024, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of separate transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures, which is not allowable under the grant award. The audit team reviewed the expenditure population in entirety and identified a total of 5 expenditures, totaling $17,857, that were made from Special Education funds directly to non-public schools by the cooperative during the audit period. The lack of controls and noncompliance was an isolated to the 22611-047-PN01, 22611-047-ARP, 22619-047-ARP and 24611-047-PN01 grant awards. This issue was isolated to fiscal year 2024. No direct payments to non-public schools were identified during fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding. During the required consultation meeting involving the Local Educational Agency (LEA), representatives from private schools, and the parents or legal guardians of nonpublic students with disabilities, the agenda will cover both allowable and un-allowed costs. The meeting agenda will clearly outline that all purchased items are the responsibility of the LEA, that gift cards are prohibited, and that all acquisitions must provide direct benefit to students with disabilities. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.
Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specif...
Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specific Corrective Action: To prevent recurrence, the College is implementing the following measures: 1. Enhanced Funding Source Review Procedures: The College will develop and enforce a standardized review process requiring staff to verify and document the original funding source for any expenditure prior to charging it to a federal award. This process will include mandatory cross-checking between project accounting records, bond expenditures logs, and grant reimbursement requests. 2. Strengthened Internal Controls Over Capital Project Accounting: The College will implement additional controls within the accounting system to ensure expenditures tied to capital projects are flagged and reviews for potential dual funding before being charged to any federal program. 3. Training and Guidance for Staff: All personnel involved in grant management, accounting, and capital project administration will receive updated training on Cost Principles under 2 CFR 200.400-200.406, with emphasis on allocability, reasonableness, and the proper handling of applicable credits. 4. Ongoing Monitoring and Review: Quarterly internal compliance reviews will be conducted to confirm adherence to the new procedures, and corrective measures will be taken immediately if discrepancies are identified. The College is committed to ensuring full compliance with federal regulations and strengthening internal controls to safeguard all funding sources. We appreciate the opportunity to improve our processes and will implement the recommended procedures to ensure the integrity of future federal program expenditures. Anticipated Completion Date: June 30, 2026
Insufficient Supporting Documentation of Disbursements Auditor Description of Condition and Effect. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. As a resul...
Insufficient Supporting Documentation of Disbursements Auditor Description of Condition and Effect. During our testing of disbursements, we noted 1 of 26 disbursements tested where the University did not have adequate documentation to support why the disbursement was charged to the grant. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Corrective Action. The University will establish formal procedures to ensure all expenses charged to grants have adequate support and reviewed and approved by management. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026
Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no dis...
Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability Corrective Action Plan: DHHS will work with Federal Partners on reviewing allowability of methodology used. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability Corrective Action Plan: DHHS will work with Federal Partners on reviewing allowability of methodology used. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026
Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.090 – Guardianship Assistance; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Desi...
Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.090 – Guardianship Assistance; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Grants to States for Medicaid – Allowable Cost/Cost Principles Corrective Action Plan: A new Business Unit mapping process has been implemented that will ensure that all Business Units are correctly accounted for. In addition, procedures were updated and sent to applicable staff to ensure payroll is correctly recorded. Contact: Patrick Werner Anticipated Completion Date: Complete
Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575...
Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Grants to States for Medicaid – Allowable Cost/Cost Principles Corrective Action Plan: DHHS has begun strengthening processes and procedures to ensure entries are complete and accurate and in compliance with Federal regulations. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026
The Organization has transitioned from QuickBooks to Sage Intacct accounting software, which now requires digital attachments for all transactions to ensure proper documentation. The Organization continues to review and improve processes and procedures as we grow as an organization. We will reinforc...
The Organization has transitioned from QuickBooks to Sage Intacct accounting software, which now requires digital attachments for all transactions to ensure proper documentation. The Organization continues to review and improve processes and procedures as we grow as an organization. We will reinforce adherence to the Organization's policies.
2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SP...
2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SPRMCO23CA0361- FY24 MRA Capacity Development Funds 2. SPRMCO24CA0356- FY2023-25 Year 3 Reception and Placement Program - Affiliate MRA DA+Admin 3. SPRMCO24CA0357- FY2023-25 Year 3 Reception and Placement Program - Affiliate ERMA DA+Admin Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: IRC’s management has taken several steps to stop fraudulent activities, prevent new fraud and improve IRC’s ability to detect future fraud. a. Upon identifying potentially unauthorized and fraudulent fund requests, all program office access to the USIO bank portal was immediately suspended. USIO debit card loads were centralized, and this process remains in place. b. Nine staff potentially involved in those activities were placed on leave during the investigation; five were eventually terminated. Following investigations, the IRC has made significant changes in leadership in structure in Northern California. By the end of June 2026, new Finance, Operations, and Program Delivery leadership will be in place, and the office will be broken down into two smaller offices, each with its own Executive Director. c. Working visits and in-person training on fraud prevention have been and will continue to be delivered to reinforce IRC’s compliance standards in all offices engaged in direct client payments. Additionally, network wide training are being provided focused on on compliance, CFR and fraud prevention for all staff. New policies on pre-paid cards and gift cards have also been issued. d. A Financial Analyst position was created under the RAI Head of Finance to focus on compliance. The analyst performs quarterly sample-based spot checks across all U.S. network offices, randomly selecting transactions for end-to-end review, including USIO payments. An automated tool also flags potential non-compliance issues such as irregular p-card payments and gift card purchases – vulnerabilities that could be exploited in NorCal-like situations. The RAI Head of Finance then compiles quarterly compliance reports for office leadership, highlighting areas for improvement. Anticipated Completion Date: June 30, 2026
FINDING 2025-001 Finding Subject: Twenty-First Century Community Learning Centers – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: April Boone and Levi Yowell Contact Phone Number and Email Address: 765-249-2515; april.boone@clinton...
FINDING 2025-001 Finding Subject: Twenty-First Century Community Learning Centers – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: April Boone and Levi Yowell Contact Phone Number and Email Address: 765-249-2515; april.boone@clinton.k12.in.us; levi.yowell@clinton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Per written directive from our Superintendent, Mr. Yowell on November 14, 2025, the following steps are being implemented to provide better oversight over the Twenty-First Century Program. 1. Multiple signatures are now required on all payroll, including the CCE Principal, Site Coordinator, CCSC Treasurer, and Superintendent 2. Immediately discontinuing the unallowable expenses as shared by the SBOA auditors 3. Required approval for all purchases from Site Coordinator, CCE Principal, CCSC Treasurer, and Superintendent. On December 15, 2025, the School Board will be reviewing and considering the approval of a District Financial Authority Oversight Resolution. This resolution will better define who has financial oversight and authority for all spending within the corporation. Anticipated Completion Date: November 14, 2025 and December 15, 2025 (Note: Provide the projected date of completion of major tasks for the planned corrective actions described above.)
FINDING 2025-003 Finding subject: COVID-19 Educational Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131 millerje@maconaquah.k12.in.us Views of Responsible O...
FINDING 2025-003 Finding subject: COVID-19 Educational Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131 millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the finding According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This action will need to be voted on by the School Board. Anticipated Completion Date: August 2026
FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We c...
FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the findings Response Comments: According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This will need to voted on by the School Board before we can put into practice. Anticipated Completion Date: August 2026
FINDING 2025-004 Finding Subject: Special Education - Earmarking Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-205-3332 x 77218 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Correc...
FINDING 2025-004 Finding Subject: Special Education - Earmarking Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-205-3332 x 77218 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Business Services will work with the Special Education team and IDOE to ensure that waivers are filed in a timely manner for any proportionate share funding not spent by nonpublic schools. Anticipated Completion Date: June 30, 2026 INDIANA STATE
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and s...
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021- ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person(s) Responsible for Corrective Action/Contact Phone Number and Email Address: Lissa Stranahan Michelle Cronk Phone: 765-771-6013 Phone: 765-746-1602 Email: lstranahan@lsc.k12.in.us Email: cronkm@wl.k12.in.us View of Responsible Officials: West Lafayette Community School Corporation concurs with the audit finding for Earmarking. The GLASS Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.
Finding 2025-003 Duplicate expenditures charged to same grant Recommendation: We recommend the District establish and maintain proper review procedures for expenditures charged to grants prior to submission for reimbursement. Management’s View: The District will strengthen internal controls over pay...
Finding 2025-003 Duplicate expenditures charged to same grant Recommendation: We recommend the District establish and maintain proper review procedures for expenditures charged to grants prior to submission for reimbursement. Management’s View: The District will strengthen internal controls over payroll expenditures charged to federal grants by implementing a standard operating procedure that will be conducted by the Payroll Specialist of verifying payroll distribution reports, funding codes, and supporting documentation prior to submission for payment. Before each payroll is finalized, the payroll specialist will run a payroll report that will be generated and sorted by employee to verify that no duplicate charges have been applied to the same grant within the same payroll period. This review will ensure that all costs charged to federal grants during the pay period are accurate, allowable, properly coded, and not duplicated. No payroll adjustments will be keyed until timesheets have been verified against previously submitted timesheets and that they are reviewed to confirm that prior entries have not already been charged to the same grant. Additionally, a secondary review by the accountant will be conducted prior to finalizing grant-related payrolls. Effective March 1, 2026, the Payroll Accountant and Chief Financial Officer will review grant-related payroll transactions to ensure accuracy, proper funding allocation, and compliance with applicable federal requirements. Effective Date: March 1, 2026 Contact Person: Sylvia Garza, Chief Financial Officer, Edcouch-Elsa Independent School District
Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Explanation of disagreeme...
Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Explanation of disagreement with audit finding: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.403(f). Action planned in response to finding: Corrective action will be taken. The Department revised the policies and procedures for cash disbursements within the Administrative Services Division. Effective immediately, upon running the monthly query of federal expenditures for the cash reimbursement for federal grants, the Federal Financial Analyst will submit the query to the Budget Director and the Accountant/Auditor. A reconciliation to the General Ledger will be completed by them prior to the Federal Financial Analyst requesting the cash reimbursement. Name(s) of the contact person(s) responsible for corrective action: Paul Varela, CFO Planned completion date for corrective action plan: July 31, 2026
Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all fut...
Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance and under ARPA guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026
Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: DARS’ Finance Division will develop agency-specific payroll policies and procedures governing all critical payroll processes, including payroll reconciliations and payroll certifications. Additionally, the Fi...
Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: DARS’ Finance Division will develop agency-specific payroll policies and procedures governing all critical payroll processes, including payroll reconciliations and payroll certifications. Additionally, the Finance Division will ensure that payroll reconciliations are completed each pay period so that payroll transactions are accurate, complete, and properly reviewed. Estimated Completion Date: 5/31/2026
U.S. DEPARTMENT OF EDUCATION 2025-002 Special Education Cluster Grants – ALN’s 84.027 & 84.173 Recommendation: We recommend procedures be implemented to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Explanation of disagreement wit...
U.S. DEPARTMENT OF EDUCATION 2025-002 Special Education Cluster Grants – ALN’s 84.027 & 84.173 Recommendation: We recommend procedures be implemented to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed the finding and have since implemented controls to ensure that expenditures are charged to a grant only after final approval has been issued in the grant portal. Name(s) of the contact person(s) responsible for corrective action: Aisha Oppong, Executive Director of Business and Support Services Planned completion date for corrective action plan: January 12, 2026.
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