Corrective Action Plans

Finding 394239 (2023-002)

Material Weakness 2023

TX

Material Weakness Internal Control / Segregation of Duties

Margaret Riojas, Office Manager and Ronald Daniels, General manager, concur with the finding. The District is in the process of interviewing potential new consultants that will assist in the monthly and annual closing of accounting records

View Audit 304235

Finding 394238 (2023-001)

Material Weakness 2023

Harris County Wcid #21

TX

Material Weakness Internal Control / Segregation of Duties

Margaret Riojas, Office Manager and Ronald Daniels, General Manager, concur with the finding. The District is in the process of interviewing potential new consultants that will assist in the preparation of Financial Statements

View Audit 304235

Finding 394237 (2023-001)

None 2023

Puerto Rico Fiscal Agency & Financial Advisory Authority

PR

Reporting Internal Control / Segregation of Duties § 200.512

Management response: Finding accepted Management has in place all the internal controls needed to issue the Uniform Guidance report for the fiscal year ending on June 30, 2024, and subsequent years on time. Currently, management is working with the 2024 fiscal year financial statement audit and uni...

Management response: Finding accepted Management has in place all the internal controls needed to issue the Uniform Guidance report for the fiscal year ending on June 30, 2024, and subsequent years on time. Currently, management is working with the 2024 fiscal year financial statement audit and uniform guidance audit plan which take into consideration to issue those reports on or before March 31, 2025. Corrective action plan: The submission of the 2023 data collection form and reporting package will be performed on or before April 30, 2024. Contact Person: Jessica Ortiz Rivera – Title: Comptroller

View Audit 304216

Finding 394236 (2023-001)

Significant Deficiency 2023

Laurentian Hall Associates, Inc. Dba Laurentian Hall 033-35197

PA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Name of auditee: Laurentian Hall Associates, Inc. HUD auditee identification number: 033-35197 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2023 CAP prepared by Name: Dana Wall Position: Director of Accounting Telephone number: 412-578-7872 C...

Name of auditee: Laurentian Hall Associates, Inc. HUD auditee identification number: 033-35197 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2023 CAP prepared by Name: Dana Wall Position: Director of Accounting Telephone number: 412-578-7872 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2023-001: As of December 31, 2023, the Corporation has not made the required payment of 50% of available surplus cash from the prior fiscal period. Comments on the Finding and Each Recommendation: The delinquent payment should be made to HUD and future required payments should be made within the time period defined in the Use Agreement and Mortgage Restructuring Agreement. Action(s) taken or planned on the finding: Agree. Management agrees with the recommendation and made the delinquent mortgage payment of $18,268 on February 14, 2024.

View Audit 304215 Questioned Costs: $1

Finding 394232 (2023-005)

Material Weakness 2023

City of Forest Park, Georgia

GA

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

Name of the Contact Person Responsible for the Corrective Action Plan: John Wiggins, Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps to ensure that the reporting requirement of the CSLFRF grant will be submitted on time to prevent noncompliance with the ...

Name of the Contact Person Responsible for the Corrective Action Plan: John Wiggins, Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps to ensure that the reporting requirement of the CSLFRF grant will be submitted on time to prevent noncompliance with the terms of the CSLFRF grant. Anticipated Completion Date: April 30, 2024

View Audit 304202

Finding 394231 (2023-004)

Material Weakness 2023

City of Forest Park, Georgia

GA

Subrecipient Monitoring § 200.331 § 200.332

Name of the Contact Person Responsible for the Corrective Action Plan: John Wiggins, Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps in the future to ensure that our subrecipient agreements include all of the required federal compliance language and we w...

Name of the Contact Person Responsible for the Corrective Action Plan: John Wiggins, Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps in the future to ensure that our subrecipient agreements include all of the required federal compliance language and we will ensure that risk assessments are performed for future subrecipients. Anticipated Completion Date: April 30, 2024

View Audit 304202

Finding 394227 (2023-003)

Significant Deficiency 2023

Lyford Consolidated Independent School District

TX

HUD Housing Programs Internal Control / Segregation of Duties § 200.303

The District will review the current procedures for maintaining documentation for when students are removed from the adjusted cohort and ensure written documentation is maintained. ...

The District will review the current procedures for maintaining documentation for when students are removed from the adjusted cohort and ensure written documentation is maintained. Contact Person: Reynaldo Robles, CFO Implementation Time Frame: August 31, 2024

View Audit 304193

Finding 394226 (2023-001)

None 2023

Silver Lake Housing, Inc.

TX

Cash Management HUD Housing Programs Reporting

Condition: The tenant security deposit cash account was insufficient to cover the tenant security deposit liability. Response: The Project is experiencing escalation of operating costs and management is going to request a Budget Based Rent increase for the property. Management believes that it wi...

Condition: The tenant security deposit cash account was insufficient to cover the tenant security deposit liability. Response: The Project is experiencing escalation of operating costs and management is going to request a Budget Based Rent increase for the property. Management believes that it will then be able to fund the shortfall in the security deposit cash account.

View Audit 304188

Finding 394064 (2023-002)

Significant Deficiency 2023

Th, INC

WI

Internal Control / Segregation of Duties

Recommendation: Management and Board of Directors should remain aware of this situation and continue to monitor the various functions of the office staff and review detail reports to improve reliance on information prepared. Management Response: TH, Inc’s Administrator and Board will continue to mo...

Recommendation: Management and Board of Directors should remain aware of this situation and continue to monitor the various functions of the office staff and review detail reports to improve reliance on information prepared. Management Response: TH, Inc’s Administrator and Board will continue to monitor the accounting process. The following procedures have become written policy: all checks received are recorded in the appropriate deposit book by the Administrative Assistant; all deposits are reviewed by the Administrator; the Administrator makes the deposit at the bank; the Bookkeeper reviews and compares deposit totals with the online bank activity; the Administrator and Bookkeeper review monthly paper bank statements together; the Board reviews the financial reports, which includes monthly check register activity.

View Audit 304173

Finding 394063 (2023-001)

Significant Deficiency 2023

Th, INC

WI

Internal Control / Segregation of Duties

Recommendation: We recommend the Organization adopt policies and procedures to ensure the accounting records are in compliance with generally accepted accounting principles. Additionally, procedures should remain for requiring the Organization’s management to review the drafted financial statements...

Recommendation: We recommend the Organization adopt policies and procedures to ensure the accounting records are in compliance with generally accepted accounting principles. Additionally, procedures should remain for requiring the Organization’s management to review the drafted financial statements with the accounting firm and take responsibility for the finalized financial statements. Management Response: TH, Inc’s Administrator and Boad recognize their responsibility for the financial statements. The following procedures have become written policy: The Administrator reviews and approves invoices and statements as they come in; the Bookkeeper processes invoices and statements weekly, processing checks every other week; a Board member and Administrator review and approve the checks and direct payments every other week; electronic payments are reviewed and approved monthly by a Board member and Administrator; all financial reports are reviewed and approved by the Board at the monthly Board meetings.

View Audit 304173

Finding 394034 (2023-003)

Material Weakness 2023

Workforce Development Board of Southeast Missouri

MO

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Refer to finding 2023-001 for the views of responsible officials and planned corrective actions.

View Audit 304161

Finding 394034 (2023-003)

Material Weakness 2023

Workforce Development Board of Southeast Missouri

MO

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. As was noted in the prior year audit, which due to the timing had a carryover impact to the current year, unfortunate circumstances existed prior to the departure of two key employees within th...

Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. As was noted in the prior year audit, which due to the timing had a carryover impact to the current year, unfortunate circumstances existed prior to the departure of two key employees within the Organization that significantly impacted the daily financial reporting and processing capabilities of the Organization. The Organization however, made a concerted effort to ensure that it met Federal program reporting compliance standards. Effective October 1, 2022, the Organization became a 100% pass thru agent of all Federal programs, thereby significantly reducing the financial reporting and processing requirements. The Organization has accordingly changed their financial reporting and processing procedures that has improved the overall internal control over financial reporting and compliance. Federal programs for the year ended June 30, 2023 were subjected to monitoring procedures and subrecipient auditing procedures resulting in unqualified reports and no identification of disallowable costs.

View Audit 304161

Finding 394032 (2023-005)

Significant Deficiency 2023

East Central Regional Water District

ND

Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.327

Contact Person Neil Breidenbach Planned Corrective Action The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Planned Completion Date December 31, 2024.

View Audit 304157

Finding 393960 (2023-005)

Significant Deficiency 2023

School District of Fort Atkinson

WI

Plan: The District will have a dual review process so this mistake does not happen again.

View Audit 304135

Finding 393959 (2023-004)

Significant Deficiency 2023

School District of Fort Atkinson

WI

Questioned Costs Cash Management

Plan: The District will have a dual review process so this mistake does not happen again.

View Audit 304135 Questioned Costs: $1

Finding 393958 (2023-003)

Significant Deficiency 2023

School District of Fort Atkinson

WI

Plan: The business manager will review numbers entered by other staff members. The assistant to the business manager will review the information entered by the business manager.

View Audit 304135

Finding 393957 (2023-002)

Significant Deficiency 2023

School District of Fort Atkinson

WI

Cash Management

Plan: The District receives notices from our Medicaid consultants reminding us multiple times before the deadline comes. If the district has not submitted by the second notice, we will schedule a meeting to dedicate time to submitting on time.

View Audit 304135

Finding 393952 (2023-001)

Significant Deficiency 2023

School District of Fort Atkinson

WI

Questioned Costs Cash Management Reporting

Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies.

View Audit 304135 Questioned Costs: $1

Finding 393950 (2023-002)

Significant Deficiency 2023

Columbia Gorge Community College

OR

Allowable Costs / Cost Principles Eligibility Significant Deficiency

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) S...

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion Finding Summary: The College did not have consistent controls in place to formerly approve a plan for distribution of funds that was documented and circulated to the College. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the audit process. Three independent outreach efforts were implemented to contact, support, and release funding to students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect execution. Documentation was provided for all sample disbursements with a few instances of missing documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF funding was distributed to students that met eligibility requirements withing the June 30, 2023, disbursement deadline. Ongoing efforts include the following:  The college will continue to archive and document all disbursement records.  Continued implementation of processes and procedures for all aid disbursement to prevent future instances. Anticipated Completion Date: Completed June 30, 2023

View Audit 304126

Finding 393949 (2023-003)

Significant Deficiency 2023

Columbia Gorge Community College

OR

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.328 § 200.329

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Re...

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Finding Summary: A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual reports. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer 105 Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024

View Audit 304126

Finding 393941 (2023-008)

Material Weakness 2023

Columbia Gorge Community College

OR

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Fede...

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Finding Summary: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. The auditors were not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Corrective Action: The College will review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College will review all processes and procedures related to eligibility to ensure controls are well documented and to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

View Audit 304126 Questioned Costs: $1

Finding 393940 (2023-007)

Material Weakness 2023

Columbia Gorge Community College

OR

Student Financial Aid Material Weakness Reporting

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have ad...

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted in a timely way and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes. 108  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

View Audit 304126

Finding 393939 (2023-006)

Material Weakness 2023

Columbia Gorge Community College

OR

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Student Financial Aid

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Prog...

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program 107 Finding Summary: Staffing shortages have contributed to the delay in the implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

View Audit 304126

Finding 393938 (2023-005)

Material Weakness 2023

Columbia Gorge Community College

OR

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place...

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, the auditors were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

View Audit 304126 Questioned Costs: $1

Finding 393937 (2023-004)

Material Weakness 2023

Columbia Gorge Community College

OR

Student Financial Aid Material Weakness Reporting

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensu...

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding – Yes, 2022-003 Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting. 106  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

View Audit 304126

Corrective Action Plans

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