Corrective Action Plans

Finding 390159 (2023-003)

Significant Deficiency 2023

City of Daly City

CA

Questioned Costs Cash Management § 200.305

Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Bloc...

Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 • Fiscal Year of Initial Finding: 2023 • Name(s) of the contact person: Traci Cho, Accountant • Corrective Action Plan: The City will review the retentions payable when preparing the IDIS drawdown to ensure that retentions are not included in the drawdown amount. • Anticipated Completion Date: 06/30/24

View Audit 301060 Questioned Costs: $1

Finding 390157 (2023-002)

Significant Deficiency 2023

City of Daly City

CA

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

Finding Reference Number: SA2023-002 Documenting Payroll Costs Charged to Grant Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Departm...

Finding Reference Number: SA2023-002 Documenting Payroll Costs Charged to Grant Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 • Fiscal Year of Initial Finding: 2023 • Name(s) of the contact person: Betsy ZoBell, Housing and Community Development Manager • Corrective Action Plan: ECD staff will perform periodic review of estimates to confirm that payroll allocations are supported by timesheet documentation of actual hours worked. • Anticipated Completion Date: 06/30/24

View Audit 301060

Finding 390155 (2023-001)

Significant Deficiency 2023

City of Daly City

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federa...

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2686 68-0281986 Name of Pass-Through Entity: California State Water Resources Control Board • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Cheresa Wang, Financial Services Manager • Corrective Action Plan: City staff will better comply with this rule going forward by either checking the exclusions list for suspensions or debarments for proposed contractors and subrecipients or by including suspension and debarment language in contracts. Finance staff communicated this new procedure to the appropriate project managers in April 2023. In addition, Finance staff developed a new Suspension and Debarment Policy, dated 12/4/23, to provide guidance to project managers on how to comply with this rule. • Anticipated Completion Date: 06/30/24

View Audit 301060

Finding 390151 (2023-002)

Significant Deficiency 2023

Vermont Adult Learning, Inc.

VT

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding # 2023 -002 Issue: During our audit procedures we identified instances where there was no documented rate approval or pay rate support within personnel files. Pay rates and pay rate changes should be reviewed and approved by department supervisors and human resource director at the time o...

Finding # 2023 -002 Issue: During our audit procedures we identified instances where there was no documented rate approval or pay rate support within personnel files. Pay rates and pay rate changes should be reviewed and approved by department supervisors and human resource director at the time of pay changes and documented in personnel files. Root Cause: The Organization is not properly following the internal controls in place over the documentation of such pay rate changes. Corrective Action Plan: ● The Organization has discussed internally how to more accurately and efficiently submit, sign and record pay rates and pay rate changes. The Human Resources department, as well as all supervisors are dedicated to retaining accurate and complete personnel records. The Organization will send each employee a letter when their raise comes up that documents their old rate and new rate. This letter will be signed by the employee, then the Supervisor, as well as the HR Director. Once all three signatures are obtained, HR will send a final, signed copy to the supervisor, and will keep a copy in a secure, central location that is accessible to the Supervisors and Directors. Timeline: This will be implemented as soon as possible Person Responsible for Corrective Action Plan: Joe Przyperhart, Program Director/Interim Executive Director, David Justice, Program Director/Interim Executive Director, Human Resources Director, Grant Managers and Regional Directors will oversee changes to ensure all payroll rate changes are reviewed, approved and appropriately filed in a secure location.

View Audit 301059

Finding 390147 (2023-001)

Significant Deficiency 2023

Vermont Adult Learning, Inc.

VT

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking

Finding # 2023-001 Issue: During our audit procedures we identified instances where there was no documented approval of invoices over expense transactions. Expenses should be reviewed and approved by someone other than the purchaser. Root Cause: The Organization is not properly following the in...

Finding # 2023-001 Issue: During our audit procedures we identified instances where there was no documented approval of invoices over expense transactions. Expenses should be reviewed and approved by someone other than the purchaser. Root Cause: The Organization is not properly following the internal controls in place over the approval of such expense transactions. Corrective Action Plan: We are committed to ensuring that we have approval of all expense transactions. To that end we have: ● VAL implemented procedures that all expenses must be accompanied by a purchase approval form for approval before the payment occurs. The purchase approval form is initiated by the purchaser, then signed by a manager or director and is submitted with the invoice or credit card receipt to Bill.com (A/P) or Dext (CC transactions) for payment and/or documentation retention. Multiple levels of additional approval are documented and retained in Bill.com (A/P). Purchases through vendor websites also include a level of approval (for example Staples and Amazon). In these cases, staff create an order and submit it for approval. The order is not processed until the Office Administrator approves every order. Invoices from these vendors still go through the regular approval process. There is just an extra layer of approval to ensure accuracy in reporting. ● Recurring expenses - The purchase approval process is also initiated for the initial payment of a recurring expense, noting that the expense will be a recurring charge. When expenses occur after the initial expense, any documentation related to the expense will be saved, but no approval form is required for future expenses as long as the amount or coding doesn’t change. This includes, but is not limited to, monthly lease payments, job search subscriptions, parking subscriptions, health/dental/vision/FSA expenses, etc. Timeline: This updated process has been implemented as of April 2023. Staff and management have been more diligent regarding including purchase approval forms to all expenses incurred. VAL has also verified that all expenses are reviewed for accuracy by managers, directors, and the outsourced accounting firm. Person Responsible for Corrective Action Plan: Joe Przyperhart, Program Director/Interim Executive Director, David Justice, Program Director/Interim Executive Director, Grant Managers and Regional Directors will oversee changes to ensure all expenses include the appropriate approval documentation.

View Audit 301059

Finding 390146 (2023-002)

Material Weakness 2023

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subreci...

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subrecipient disbursements. Moving forward, management will ensure that it properly allocate expenses in accordance with Uniform Guidance Regulations. In addition, management plans to work closely with the federal passthrough entity to ensure that overbilled amounts are returned during the fiscal year ending June 30, 2024

View Audit 301052 Questioned Costs: $1

Finding 390145 (2023-001)

Significant Deficiency 2023

Health Care for All, INC

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 301052

Finding 390143 (2023-001)

Significant Deficiency 2023

Nueva Esperanza, Inc.

PA

Reporting § 200.327

Management acknowledges the late filing of SF-425 for direct HUD grants. The delay is due to a delay from the sub awardees providing information timely to Housing Counseling for the fiscal year. Maria Iannarelli, Program Manager for Housing Counseling Assistance Program will continue to communicate ...

Management acknowledges the late filing of SF-425 for direct HUD grants. The delay is due to a delay from the sub awardees providing information timely to Housing Counseling for the fiscal year. Maria Iannarelli, Program Manager for Housing Counseling Assistance Program will continue to communicate with the sub-grantees to ensure reporting on a timely basis.

View Audit 301048

Finding 390139 (2023-001)

Significant Deficiency 2023

Reynolds School District

OR

Significant Deficiency

Reynolds School District respectfully submits the following corrective action plan in response to deficiencies reported in our audit of the fiscal year ended June 30, 2023. The audit completed by theindependent auditing firm December 28, 2023 reported the deficiency listed below. The plan ofaction w...

Reynolds School District respectfully submits the following corrective action plan in response to deficiencies reported in our audit of the fiscal year ended June 30, 2023. The audit completed by theindependent auditing firm December 28, 2023 reported the deficiency listed below. The plan ofaction was adopted by the governing body at their meeting on February 28, 2024, as indicated bysignatures below.Listed below is the deficiency as provided by the auditor followed by the district’s adopted Plan ofAction and implementation timeframe.1. Deficiency #1: SA-2023-001 a. Significant Deficiency—Compliance with Federal Award Program for Davis-Bacon Act • Condition: The District did not get certified payrolls for many contractors within the ESSER grant • Recommendations: We recommend that the District put in place a system where invoices for contracts are not paid until they receive certified payrolls, or some sort of system that ensures compliance. b. Plan of Action • The district will review its processes to ensure contracts include the Davis-Bacon Act provision when applicable and indicate the requirement to provide prevailing wages. • The district will include a requirement to receive documentation of certified payroll from the contractor when applicable as a condition of (and prior to) payment of invoices. c. Implementation Timeframe • The district implemented the review process immediately upon notification from the auditors of this deficiency. Contracts with payments from federal resources will include the Davis-Bacon Act provision to pay prevailing wages and provide documentation through certified payroll. Payment of invoices will not be completed without required documentation.

View Audit 301042

Finding 390138 (2023-002)

Material Weakness 2023

Barnes-Kasson County Hospital

PA

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

Finding 2023-002 Condition The Hospital did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Hospital erroneously entered information into the lost revenue calculation, resulting in lost revenues being understated $1,020,0...

Finding 2023-002 Condition The Hospital did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Hospital erroneously entered information into the lost revenue calculation, resulting in lost revenues being understated $1,020,030. The Hospital reported lost revenues amounting to $999,172 on distributions totaling $1,177,041. The Hospital had excess lost revenues from previous periods available to be used through June 30, 2023 amounting to $5,406,884. The Hospital also reported expenses of $907,051. Corrective Action Plan Corrective Action Planned: The Hospital will undertake a review of its internal control policies and procedures surrounding the reporting on federal grant activities and add additional layers of review where necessary to ensure future reporting is accurate. Name of Contact Person Responsible for Corrective Action: Kelli Kane, Chief Financial Officer Anticipated Completion Date: April 15, 2024

View Audit 301031

Finding 390137 (2023-001)

Material Weakness 2023

Second Harvest Foodbank of Southern Wisconsin, Inc.

WI

Procurement, Suspension & Debarment

Corrective Action Plan For the Year Ended June 30, 2023 Finding 2023‐001 Second Harvest has a procurement policy that applies to federal funds. Purchases that are above the simplified acquisition threshold ($10,000) must have quotes obtained from an adequate number of sources. The quote process incl...

Corrective Action Plan For the Year Ended June 30, 2023 Finding 2023‐001 Second Harvest has a procurement policy that applies to federal funds. Purchases that are above the simplified acquisition threshold ($10,000) must have quotes obtained from an adequate number of sources. The quote process includes review of multiple quotes to ensure procurement compliance requirements are met. The review of quotes or attempts to obtain quotes was informal and in certain cases inadequate documentation of the review was available to provide as part of the single audit. Second Harvest was in compliance with procurement compliance requirements and followed our procurement policy for the year. Status: In progress Anticipated Completion Date: June 30, 2023 Corrective Action: 1. We will continue to review our procurement policy at least annually to ensure alignment with acquisition thresholds. 2. The VP of Finance (VPF) will include any necessary clarification on the process, including explicit requirement for final approval by VPF of any purchases that meet the threshold for multiple quotes. 3. When the threshold applies, the VPF will ensure that adequate quotes were obtained, with proper documentation, before approving the purchases. Management agrees with the finding and will perform that corrective action as outlined above. Responsible individual for corrective action: Michelle Orge Title: President and CEO Contact information: michelle.orge@secondharvestsw.org Date: March 22, 2024

View Audit 301028

Finding 390136 (2023-001)

Significant Deficiency 2023

Northeast Colorado Board of Cooperative Educational Services

CO

Cash Management Subrecipient Monitoring Material Weakness § 200.305

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the gran...

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the grant manager determines the amount to be requested and this will be subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. A review of the internal control procedures with all grant management and finance staff will assure that this is not a reoccurring issue.

View Audit 301027

Finding 390135 (2023-101)

Material Weakness 2023

Gila County

AZ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Assistance Listings number and program name: 21.027 COVID-19 Corona Virus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2024 Corrective Action Plan: The County will develop, implement, and maintain procedures requiring both the performance & doc...

Assistance Listings number and program name: 21.027 COVID-19 Corona Virus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2024 Corrective Action Plan: The County will develop, implement, and maintain procedures requiring both the performance & documentation of independent review and approval of all federal program reports prior to submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. Program expenditures will be reconciled to the County’s accounting records. The County’s previous corrective action plan stated “Errors identified will be reported to the federal agency in adjusted or resubmitted reports” however the Federal Reporting interface lacks capacity for resubmitted reports. The adjusted reports resulted in the understatement and overstatement amounts noted in Federal Award Finding 2023-101. Departmental training will be provided for staff responsible for preparing and reviewing reports for both data management, compliance with Uniform Guidance, 2 Code of Federal Regulations (CFR) §200.510, and adherence to County’s policies and procedures.

View Audit 301026

Finding 390133 (2023-001)

Significant Deficiency 2023

Sunnyside Unified School District No. 12

AZ

Allowable Costs / Cost Principles § 200.230 § 200.430

Finding Number: 2023‐001 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U, 84.425W Contact Person: Andrea Leon Foster, Director of Federal Programs Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Although th...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U, 84.425W Contact Person: Andrea Leon Foster, Director of Federal Programs Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Although the Federal Programs Department has a process for periodic certification, compression was not included in the percentage breakdown for each classified staff salary. Reporting adjustments have been made to include ESSER funded positions with additional oversight on percentage breakdowns for positions funded with multiple cost objectives. These breakdowns are reflected in the electronic version of FORMS B and D in addition to the hard copies. The Federal Programs Director will work with district leadership to ensure all employees in each department (Curriculum and Instruction, Professional Development, etc.) on the process of maintaining Time and Effort logs and signing the bi‐annual FORM B and FORM D.

View Audit 301015

Finding 390126 (2023-003)

Material Weakness 2023

San Francisco Community College District

CA

Allowable Costs / Cost Principles Student Financial Aid Subrecipient Monitoring § 200.430

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and c...

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and charged to the appropriate programs and services. This should be completed by June 30, 2024.

View Audit 301013

Finding 390122 (2023-001)

Significant Deficiency 2023

New Trier Township High School District 203

IL

See Corrective Action Plan

View Audit 301010

Finding 390121 (2023-003)

Significant Deficiency 2023

Integrated Living, Inc.

KS

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings ...

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2023‐001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Directors and management should review the impact of the current year adjustments on the financial reporting process. Once this review is complete, the Organization should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with U.S. GAAP. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2023‐002 Review and Approval of Project Expenditures (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should obtain proper approval of all project expenditures and that evidence of that approval is documented and maintained.. Action Taken (Unaudited): Management is in the process of updating its control procedures to ensure proper approval of all project expenditures. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. 2023‐003 Written Procedures of Internal Control over Compliance (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. If HUD has questions regarding this plan, please call Patrick Gardner at 785-242-5035. Sincerely yours, Patrick Gardner CEO, COF Training Services, Inc. (Management Agent of Integrated Living, Inc.)

View Audit 301005

Finding 390120 (2023-002)

Significant Deficiency 2023

Integrated Living, Inc.

KS

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings ...

March 26, 2024 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2023‐001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Directors and management should review the impact of the current year adjustments on the financial reporting process. Once this review is complete, the Organization should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with U.S. GAAP. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2023‐002 Review and Approval of Project Expenditures (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should obtain proper approval of all project expenditures and that evidence of that approval is documented and maintained.. Action Taken (Unaudited): Management is in the process of updating its control procedures to ensure proper approval of all project expenditures. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. 2023‐003 Written Procedures of Internal Control over Compliance (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2024. If HUD has questions regarding this plan, please call Patrick Gardner at 785-242-5035. Sincerely yours, Patrick Gardner CEO, COF Training Services, Inc. (Management Agent of Integrated Living, Inc.)

View Audit 301005

Finding 390112 (2023-001)

Significant Deficiency 2023

Omaha - Council Bluffs Metropolitan Area Planning Agency

NE

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Federal Agency Name: U.S. Department of Transportation, Federal Highway Administration Pass‐Through Entity: Nebraska Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Finding Summary MAPA is the pass-through entity for several subrecipient...

Federal Agency Name: U.S. Department of Transportation, Federal Highway Administration Pass‐Through Entity: Nebraska Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Finding Summary MAPA is the pass-through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Corrective Action Plan MAPA will establish written internal procedures and complete a compliance risk determination for every federal subaward to evaluate subrecipient risk of noncompliance in accordance with the guidance provided in 2 CFR 200.332: Requirements for pass-through entities. In particular with regard to this finding, MAPA will verify whether every subrecipient is audited as required by the conditions cited in 2 CFR 200.332(f), and MAPA will evaluate such audits for compliance risk as part of its internal procedures. Responsible Individual Matthew Eash, Director of Finance Anticipated Completion Date June 30, 2024

View Audit 301004

Finding 390111 (2023-004)

None 2023

Union College

KY

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b...

2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not accurately complete refund calculations in the Spring. In review of the Spring 2023 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in Spring 2023 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 1 out of the population of 4 (25%) total withdrawal calculations. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Views of Responsible Officials: After years of completing a manual calculation we had switched to a full automated process. Going forward we will be completing a manual calculation to compare to the automated response to ensure the correct number of days are used. Responsible Person: Andra Butler, Vice President of Financial Aid Implementation Date: October 2023

View Audit 301000 Questioned Costs: $1

Finding 390110 (2023-003)

None 2023

Union College

KY

Questioned Costs Student Financial Aid Eligibility

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b...

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.” Condition: The College did not properly disburse direct loans for 1 out of 40 students (2.5%). Views of Responsible Officials: The financial aid office staff will complete the packaging aid and loans learning tracks on the Federal Student Aid Training Center. The staff will complete this training annually to ensure compliance of all regulations. Responsible Person: Andra Butler, Assistant Vice President of Financial Aid Implementation Date: October 2023

View Audit 301000 Questioned Costs: $1

Finding 390109 (2023-001)

Significant Deficiency 2023

City of San Diego

CA

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

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All not...

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All notification receipts and various forms of verification will be saved in house, on the City of San Diego’s network. This corrective action was set in place as of March 28, 2023, based on findings from the water arrearages program audit. The sewer arrearages program was also completed prior to the original corrective action plan date of March 28, 2023. This was the same finding for both the water and sewer arrearage program audits. Moving forward with this action on a continual basis, once email notifications are sent to customers using an external service provider, notification confirmations will be immediately archived at the City of San Diego. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. This affords the City full control and oversight of the verification process for all future noticing. All available notification verifications from the third-party vendor will be downloaded and saved to the City network for future inquiries. Furthermore, internal controls will be enhanced to ensure notification verification compliance. Upon notification to customers, the Billing and Financial Analytics Program Coordinator will oversee the immediate archiving of all confirmations of emails sent to customers using an external service provider. Once complete, the Billing and Financial Analytics Program Coordinator will notify the Program Manager, who will in turn, perform a secondary review of all notifications against the verification documentation to ensure accuracy. At this point, a third level of approval will be added, as the Public Utilities Customer Support Deputy Director will provide a final level review. Once complete, these documents will be saved for a minimum of five years, per the City of San Diego’s retention policy. Implementation Date: 03/28/2023 Contact: Tracy Morales Interim Deputy Director

View Audit 300999

Finding 390106 (2023-002)

Significant Deficiency 2023

Invisible Children, Inc.

DC

Procurement, Suspension & Debarment § 200.318 § 200.320

Views of Responsible Officials and Planned Corrective Actions: The Organization will review procurement policies and procedures to address the recommendation noted. The Organization will also ensure that all documentation for procurement is saved in a central location digitally to ensure documentati...

Views of Responsible Officials and Planned Corrective Actions: The Organization will review procurement policies and procedures to address the recommendation noted. The Organization will also ensure that all documentation for procurement is saved in a central location digitally to ensure documentation is complete in the Organization’s records for all procurement decisions made.

View Audit 300993

Finding 390105 (2023-001)

Significant Deficiency 2023

Invisible Children, Inc.

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials and Planned Corrective Actions: The Organization made every effort to register subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. However, due to the change from DUNS to UEI by the federal government a...

Views of Responsible Officials and Planned Corrective Actions: The Organization made every effort to register subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. However, due to the change from DUNS to UEI by the federal government and the requirement to use an organization’s UEI to find sub-awardees in FSRS.gov, the Organization was not able to register the subawards meeting the requirements. The Organization is still working with our sub-awardees to establish and collect UEI’s for each so this reporting can be completed this year.

View Audit 300993

Finding 390100 (2023-001)

Significant Deficiency 2023

Saint Michael's College

VT

Subrecipient Monitoring

The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going...

The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going forward the Information Technology department will periodically review the inventory of customer data and update as necessary.

View Audit 300992

Corrective Action Plans

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