Corrective Action Plans

Finding 387044 (2023-007)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

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

2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ...

2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board has developed a process to correctly allocate expenditures to the correct funding stream. At each month’s end, all employees complete an allocation spreadsheet. When all spreadsheets are completed, approved, and turned in, the Board determines the allocation of payroll and expenditures. Expenditures that occurred in March will be allocated using the allocation chart for February. Also, this procedure is backup for each cash request that is submitted for funding. And, this is reviewed for the reconciliation between the cash request and the Board’s accounting software.

View Audit 299385

Finding 387043 (2023-006)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Subrecipient Monitoring Eligibility Matching / Level of Effort / Earmarking § 200.303

2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities particip...

2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for the Youth program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth (Youth In or Youth Out) is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison. For the Adult Program, the Board has implemented internal controls to ensure each applicant completes the applications and to determine if they are eligible for the programs the Board offers. Our Business Services Manager reviews each application taken by the Board’s Career Services Coordinator and ensures they are in the correct program by the application.

View Audit 299385

Finding 387042 (2023-005)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Subrecipient Monitoring § 200.303 § 200.332

2023-005 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in comp...

2023-005 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Action Taken: With the assistance of Workforce WV, the Board met with a private company representative (via Zoom) who made recommendations to the Board for fiscal monitoring of the Board’s subrecipient. A plan is in the process of accomplishing this action for both 21-22 and 22-23 Fiscal Years. The Board is planning on submitting a monitoring report within the next week. This process will be developed, and a six-month monitoring period is being developed to enter into the Board’s policies and procedures as a normal course of action.

View Audit 299385

Finding 387041 (2023-004)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal cont...

2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.

View Audit 299385

Finding 387040 (2023-003)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

Matching / Level of Effort / Earmarking § 200.303

2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will c...

2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will create a spreadsheet that shows the earmarking percentage for each category. The Board will review various reports for each funding stream at month end and record the actual earmarking percentage for each month. With this information, the Board will discuss these percentages at the monthly manager’s meeting, budget meeting and Board of Directors meeting. If a plan of action is needed, a plan of action will be developed. Also, Workforce WV has a software system that takes the expenditures reported for each funding stream, for each month, called the MACC report in which each Region completes a report that will verify which percentages are not in compliance. The Board will be comparing this report to the analysis report from the State.

View Audit 299385

Finding 387039 (2023-002)

Material Weakness 2023

Workforce Development Board Work4wv Region 1, Inc.

WV

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

2023-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Ta...

2023-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board is taking adequate action to review and approve all charges to the federal programs. The Board’s steps have been reviewed with Workforce WV and has approved our procedures. Supporting documentation is kept both in physical and electronic forms. Each check the Board distributes has an approved Purchase Order attached, (if applicable), Invoice, or if it is a monthly recurring charge, statement or bill attached and once the bill is entered into our system and the bill is paid, the check has the Executive Director’s initials and date showing it is approved in our accounting system. Also, if the expenditures are questionable, we will receive approval before submission of the bill from our liaison in the Workforce WV office.

View Audit 299385

Finding 387003 (2023-004)

Significant Deficiency 2023

Lindenwood University

MO

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.

View Audit 299379

Finding 387001 (2023-003)

Significant Deficiency 2023

Lindenwood University

MO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 202...

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. During the go-live in Spring 2023, the University experienced critical system reporting issues which were addressed a quickly as possible. The new system has several built in features that are supplemented with internal controls to ensure enrollment reporting requirements are completed in a timely fashion. In Spring 2024, Anthology provided the University with a audit tool to review data before uploading to promote efficiency and accuracy.

View Audit 299379

Finding 386999 (2023-002)

Significant Deficiency 2023

Lindenwood University

MO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that changes in students enrollment status that trigger a return of title IV funds are completed within the required 45 day time period. During the transition of systems the report used to look at students who might need to be a withdrawal and have a R2T4 calculation performed needed to be rebuilt for the new system. During this process the report did not always work correctly. Those flaws have been fixed the report is being worked on a weekly basis.

View Audit 299379

Finding 386998 (2023-001)

Significant Deficiency 2023

Lindenwood University

MO

Student Financial Aid Subrecipient Monitoring Eligibility

Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure financial aid is awarded correctly. The system automatically awards the student at full-time, the awards are then confirmed through a review process before sending out the award notification, and again before payment. The system compares the full-time award status with the actual enrollment and if they do not match the student will fail for payment and we will revise the award.

View Audit 299379

Finding 386997 (2023-001)

Significant Deficiency 2023

City of Lathrop

CA

Reporting Internal Control / Segregation of Duties

The City will update policies and procedures over reporting, including additional independent reviews to ensure accurate completion.

View Audit 299368

Finding 386982 (2023-001)

Material Weakness 2023

Marshalltown Community School District

IA

Internal Control / Segregation of Duties

We will continue to review our procedures and implement additional controls where possible

View Audit 299360

Finding 386981 (2023-001)

Material Weakness 2023

Star City School District

AR

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

The District paid $219,500 for installation of an HVAC system from the Education Stabilization Fund without obtaining a written contract that included the prevailing wage rate clause. Additionally, weekly certified payrolls were not submitted to the District. ANSWER : The architect responsible for...

The District paid $219,500 for installation of an HVAC system from the Education Stabilization Fund without obtaining a written contract that included the prevailing wage rate clause. Additionally, weekly certified payrolls were not submitted to the District. ANSWER : The architect responsible for the project and supervision of subcontractors was contacted regarding the non-compliance issue. He obtained the required documentation from the sub-contractor which provided proof of compliance and is now on file in our offices. The Superintendent, Assistant Superintendent and CFO/Business Manager have all reviewed the prevailing wage requirements within Davis-Bacon. All corrective action has been completed as of March 15, 2024.

View Audit 299355

Finding 386980 (2023-001)

None 2023

New Milford Board of Education

NJ

Time and effort activity reports be available for all employees charged to the ARP ESSER grant program.

View Audit 299342

Finding 386976 (2023-001)

Material Weakness 2023

Boone-Apache Public Schools

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and en...

Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an affective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The updated policies and procedures will ensure that all items are posted at the work site to ensure compliance. The internal control policies and procedures will be completed on March 12, 2024.

View Audit 299333

Finding 386975 (2023-001)

None 2023

Harrington Park Board of Education

NJ

Board resolutions be prepared and approved identifying individuals and salary amounts to be charged to Federal grant programs.

View Audit 299322

Finding 386973 (2023-002)

Significant Deficiency 2023

Unified School District #107 Rock Hills

KS

Cash Management

The District will be reconciling and correcting the next quarterly report by reconcile the expenditures to date on the General Ledger.

View Audit 299315

Finding 386971 (2023-001)

Significant Deficiency 2023

City of Westland, Michigan

MI

Subrecipient Monitoring HUD Housing Programs Reporting

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for...

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for the program year ended June 30, 2023, we have taken immediate and strategic steps to address and prevent future occurrences. These include streamlining our data collection and reporting processes for greater efficiency, enhancing staff training on reporting responsibilities, and implementing robust internal monitoring to ensure adherence to reporting deadlines. These measures, designed to address both the immediate issue and bolster our overall reporting framework, demonstrate our commitment to transparency, accountability, and continuous improvement in our program operations. Contact person responsible for corrective action: Joanne Campbell Anticipated Completion Date: October 10, 2023

View Audit 299310

Finding 386970 (2023-001)

Significant Deficiency 2023

Ottawa University

KS

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328 § 200.329

Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided ...

Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided on the University’s website. Completion Date: March 25, 2024 Contact Person: Donna Ferguson, Controller, and Carrie Stevens, Associate Vice President of Compliance

View Audit 299309

Finding 386969 (2023-002)

Material Weakness 2023

Fountain Hills Unified School District No. 98

AZ

Allowable Costs / Cost Principles Material Weakness Reporting

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on ...

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on grant compliance. The District has also designated a District employee with specific responsibility of overseeing the District grant program to ensure timely grant submissions.

View Audit 299307

Finding 386968 (2023-001)

Material Weakness 2023

Fountain Hills Unified School District No. 98

AZ

Allowable Costs / Cost Principles

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on ...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Cain Jagodzinski, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Applicable District office staff have been trained on grant compliance. The District has also designated a District employee with specific responsibility of overseeing the District grant program to ensure timely grant submissions.

View Audit 299307

Finding 386962 (2023-006)

Significant Deficiency 2023

University of Central Missouri

MO

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address ...

The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the UCM community. UCM has commenced the process to create and publish the written information security program that addresses all required elements of the GLBA.

View Audit 299298

Finding 386961 (2023-001)

Significant Deficiency 2023

Medical University of South Carolina

SC

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

Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notific...

Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notification for disbursements within the required timeframe nor with the required information. Narrative Explanation: The general Financial Aid Award letter-directing the student to view their Loan Disbursement information was insufficient to meet the requirement. While the students have direct access to their student accounts that show disbursement activity and the institution has posted to their website the required terms of loan disbursements, the federal direct loan disbursement notification was not sent to the student or parent within the required 30 days before or 30 days after the disbursement was credited to the student's account and did not include the necessary information regarding the student's right or parent's right to cancel per 34 CFR section 668.165. Corrective action: The Student Financial Aid office reached out to our software vendor Ellucian Colleague and similar peer institutions to create a Loan Disbursement Notification notice. Effective immediately, all term disbursements will receive Loan Disbursement Notification notices. The Financial Aid Transmittal process (FATR) is run each week on Tuesday morning. The notices will be emailed weekly using a date range from the last financial aid transmittal date to the current date. Should more than one FATR be run in a week’s time, the notices would increase in frequency and intensity. The documents will be archived in batches within our current Document Imaging System by date. Additionally, a section on the Student Financial Aid website will be dedicated to the Disbursement Information, including Loan Notifications and Right to Cancel Loan procedures. MUSC is currently in the process of implementing a new Student Information System with a go live date scheduled for February 2025. During implementation we will configure the new SIS to automatically send the Loan Disbursement notifications to the students when their funds have been credited to the student’s accounts. You may direct questions to me at freelan@musc.edu or by telephone at 843-792-4364.

View Audit 299296

Finding 386959 (2023-001)

Material Weakness 2023

United Way of Greater Charlottesville

VA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Payroll Documentation: The Organization concurs with the finding. After thorough review of Uniform Guidance, the Organization has developed additional procedures for payroll allocations. These procedures were implemented for the year ending June 30, 2024.

View Audit 299293

Finding 386955 (2023-001)

Material Weakness 2023

Southeast Fountain School Corporation

IN

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

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: During the SBOA audit, our School Corporation did not have a policy nor the internal controls to review vendors to ensure they were not suspended or debarred. Our School Corporati...

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: During the SBOA audit, our School Corporation did not have a policy nor the internal controls to review vendors to ensure they were not suspended or debarred. Our School Corporation was unable to provide evidence or support to show that one contracted vendor tested was reviewed before we entered a covered transaction with the vendor. Contact Person Responsible for Corrective Action: Cynthia Alward, Treasurer Contact Phone Number and Email Address: (765)294-2254 alwardc@sefschools.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our School Corporation intends to verify the eligibility of vendors that will be paid more than $25,000.00 in federal funds with SAMS.gov. We will check that the vendor has not been debarred or suspended from participating in federal programs. Anticipated Completion Date: Immediately

View Audit 299292

Corrective Action Plans

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