Corrective Action Plans

Finding 370229 (2023-001)

None 2023

NJ

School Nutrition Programs Subrecipient Monitoring Cash Management

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board...

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

View Audit 291821

Finding 370217 (2023-002)

Significant Deficiency 2023

Woodbury University

CA

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

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Def...

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency In Internal Control Over Compliance. Corrective Action: The University has updated the status of all students in our latest batch send. That includes and is not limited to all students selected In the Single Audit. Steps/Policies Implemented to avert problem: The process for reporting information to NSLDS through the Clearinghouse works efficiently. The problem in this case, is that the University has always had two individuals with access to the upload data into the Clearinghouse. When one of the individuals responsible for uploading's position was eliminated, authorization was not given to anyone else as a backup. So, when the then Registrar resigned, no one on-site was authorized to upload the already prepared "send". That issue has been resolved and there will always be, once again, two individuals with access to upload. Although the process to resolve this Issue was extremely timely, permission to access the Clearinghouse site was eventually provided. Contact Person: The Registrar, Verletta Jackson is the responsible person. Her contact information is, Verletta Jackson, email Verletta.Jackson@woodbury.edu, phone 818 252 5277. Anticipated Completion Date: Completed as of 10.15.2023

View Audit 291795

Finding 370216 (2023-002)

Significant Deficiency 2023

Lewis-Clark State College

ID

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit find...

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370210 (2023-001)

Material Weakness 2023

Lewis-Clark State College

ID

Student Financial Aid Reporting Material Weakness

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Te...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with its third-party servicer and implement procedures to ensure that enrollment data, changes in status, and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office has temporarily taken over the administration of this process due to personnel changes in the Registrar’s Office. Enrollment reports are scheduled to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. An internal audit will be conducted using the third-party Audit Guide and will be documented. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370200 (2023-002)

Significant Deficiency 2023

Independent School District No.15

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance With Federal Suspension and...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Summary of Finding Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the special education cluster. Condition – The District did not have sufficient controls or documentation in place within its special education cluster to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – The District’s Director of Business Services, Ron Meyer. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – There is no disagreement with the finding. Plan to Monitor – The District’s Director of Business Services, Ron Meyer, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 291778

Finding 370198 (2023-001)

Significant Deficiency 2023

Multicultural Learning Center

CA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.514

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported ful...

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported full allocations per fund, in error during 2023 by the Center’s back-office service providers without review from Center’s management. Upon the Center’s communication with the CDE, the CDE has notified that “according to the U.S. Department of Education for ESSER Annual Reporting, there will be an opportunity to correct the Year 3 report that was submitted in March of 2023. The U.S. Department of Education requires that we submit Year 4 data to them first. This data will be collected in March of 2024. At that time, the LEA should report to the best of their ability, based on the previously reported expenditures. Depending on the previous amount reported, this may mean the LEA is not yet able to fully report applicable expenditures. This will be corrected later. Following the initial Year 4 submission, the U.S. Department of Education will allow for a Year 3 correction period. At this time, the LEA will be able to correct the Year 3 report. Finally, there will be a Year 4 correction period. This correction period will be based on any changes reported during the Year 3 correction period, to allow for a final true up of Year 4 reporting based on actual expenditures.” Therefore, the correction will be made in March of 2024. In the future, the Center’s back-office service providers will be utilizing a stricter rule for cross-checking reports, and will send reports (quarterly and annual) to the Center for a third review before submitting. The Center will also make the correction in March of 2024 per the CDE’s and U.S. Department of Education direction.

View Audit 291776

Finding 370196 (2023-001)

Significant Deficiency 2023

District IV Human Resources Development Council

MT

Reporting Matching / Level of Effort / Earmarking § 200.502

CORRECTIVE ACTION PLAN - FY 2023 AUDIT FINDING 2023 - 001 BASIS FOR DETERMINING FEDERAL AWARDS EXPENDED - SEFA EXPENDITURES Finding: Department of Agriculture - Rural Development Loan was not recorded correctly on the SEFA Expenditures Report. District 4 Human Resources Development Council Respon...

CORRECTIVE ACTION PLAN - FY 2023 AUDIT FINDING 2023 - 001 BASIS FOR DETERMINING FEDERAL AWARDS EXPENDED - SEFA EXPENDITURES Finding: Department of Agriculture - Rural Development Loan was not recorded correctly on the SEFA Expenditures Report. District 4 Human Resources Development Council Response: The Council concurs with the finding and understands the importance of appropriately including and measuring loans and loan guarantees in accordance with 2 CFR § 200.502(b) and (c) of the Uniform Guidance. The oversite has been corrected and the loans have been accounted for correctly on the current SEFA. The Council will ensure the loans are correctly reported on the SEFA in the future.

View Audit 291757

Finding 370195 (2023-005)

Significant Deficiency 2023

Phoenix Elementary School District No. 1

AZ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

The District will review its internal control procedures over federal programs to ensure purchase orders and maintained to support the authorization of purchases before the goods or services are purchased.

View Audit 291755

Finding 370194 (2023-001)

None 2023

City of Bellflower

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Management will develop written procedures outlining the requirement to use the SAM.gov database to verify that any vendors who may be awarded a contract or submit invoices for grant-funded activities have not been debarred or suspended. Although a verification process was in place at the time of th...

Management will develop written procedures outlining the requirement to use the SAM.gov database to verify that any vendors who may be awarded a contract or submit invoices for grant-funded activities have not been debarred or suspended. Although a verification process was in place at the time of the finding for contractors, the process was not followed to verify consultants. The development of written procedures will include a new form to be approved and signed by appropriate Public Works management staff memorializing the verification of any vendors.

View Audit 291753

Finding 370188 (2023-004)

Material Weakness 2023

Lake Region Special Education

ND

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.318 § 200.326

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals:...

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals: Rhandi Knutson, Director Corrective action plan: A procurement policy in compliance with Uniform Guidance will be approved and implemented. Anticapted Completion Date: June 30, 2024.

View Audit 291744

Finding 370187 (2023-002)

Significant Deficiency 2023

Housing and Redevelopment Authority of Austin

MN

Internal Control / Segregation of Duties HUD Housing Programs

Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance, Other Matters Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the submission of these forms. Explanation of Disagreement with Audit Finding: There ...

Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance, Other Matters Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the submission of these forms. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all policies and procedures are followed to ensure that the proper submission is completed for all tenants. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2024 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the above reviews have been completed through discussions with the Finance Director.

View Audit 291732

Finding 370186 (2023-006)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

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

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lo...

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lost revenue was based on average credit hours per semester prior to COVID-19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID-19 resulting in an understated amount of lost revenue from the intended methodology. Responsible Individuals: Tami Lansing, Controller Corrective Action Plan: The calculation underwent a review, yet the error eluded detection during the review. In any future COVID-19 lost revenue calculations, we will exercise more detailed scrutiny. The University was constrained by a predetermined threshold for lost revenue, and we had already surpassed that limit. The miscalculation, had it not been overlooked, would have only inflated that amount. It is important to note that the University intentionally approached lost revenue calculations with a conservative basis. Anticipated Completion Date: August 10, 2023

View Audit 291731

Finding 370183 (2023-005)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Finding Summary: One instance was noted where the enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar, Registrar’s Office Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and the Financial Aid office will conduct quality sampling once a semester. Anticipated Completion Date: Commenced December 1, 2023

View Audit 291731

Finding 370180 (2023-004)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Special Tests & Provisions Student Financial Aid Significant Deficiency

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Finding Summary: Four instances were identified where there was no documented control over student verification. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained on these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370177 (2023-003)

Material Weakness 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370175 (2023-002)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1-23 columns e & f. Responsible Individuals: Robert Hoover, Director of Financial Aid and Deb Theill, Student Accounts Loan Coordinator Corrective Action Plan: The Financial Aid and Loan offices will obtain review from a non preparer of the FISAP report before submittal. Anticipated Completion Date: Tami Lansing did an initial review on 10/16/2023, another review will also be performed before May 1, 2024.

View Audit 291731

Finding 370174 (2023-002)

None 2023

Town of Blacksburg, Virginia

VA

Reporting

CORRECTIVE ACTION PLAN January 17, 2024 Town of Blacksburg, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit pe...

CORRECTIVE ACTION PLAN January 17, 2024 Town of Blacksburg, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2023-002: CDBG - Community Development Block Grants/Entitlement Grants - ALN #14.218, Reporting Condition: Housing and Community Connections did not timely file Cash on Hand Quarterly Reports in two instances of testing. Criteria: Under the requirements in the Uniform Guidance, reports are to be filed within 30 days after the end of the reporting period. Cause: Housing and Community Connections typically files all reports timely, however, two quarterly reports during the same quarter were filed late. Effect: Failure to file timely reports could result in improper reporting of the use of Federal funds. Perspective Information: Two Cash on Hand Quarterly Reports of four tested were not filed within 30 days after the end of the reporting period. Recommendation: Management should implement a procedure to ensure that reports are filed within reporting periods. Views of Responsible Officials and Planned Corrective Action: Housing and Community Connections will put into place a procedure to ensure that reports are filed timely. If the Federal Audit Clearinghouse has questions regarding this plan, please call Susan H. Kaiser, Director of Finance at 540-443-1051. Sincerely yours, Susan H. Kaiser Director of Finance

View Audit 291722

Finding 370164 (2023-002)

Significant Deficiency 2023

University of Louisville

KY

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

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Education 2023-002 Student Financial Assistance Cluster: Assistance Listing No. 84.007, 84.063, 84.268, 84.379, 84.033 UNIVERSITY OF LOUISVILLE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Recommendation: We recommen...

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Education 2023-002 Student Financial Assistance Cluster: Assistance Listing No. 84.007, 84.063, 84.268, 84.379, 84.033 UNIVERSITY OF LOUISVILLE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The original guidance for missing or incorrect social security number from the Clearinghouse was to reach out to the student and obtain proof of the social security number or enter the student into the system without a social security number. The student was entered without using a social security number and this issue was not resolved. The University’s Registrar’s Office has inquired about this issue and have since been provided updated guidance on how to rectify the occurrence of such. The new guidance provided has already been implemented by the Registrar’s Office. The new guidance from the National Student Clearinghouse allows for a student’s information to be entered with the social security number supplied when registering and add enrollment information. Going forward, this missing information will not preclude a student from being reported. Name(s) of the contact person(s) responsible for corrective action: Chris Goodman Planned completion date for corrective action plan: Implemented 09/28/2023 If the U.S. Department of Education has questions regarding this plan, please call Beverly Santamouris at (502) 852-6272.

View Audit 291699

Finding 370163 (2023-001)

Material Weakness 2023

Community Mental Health Affilates, Inc.

CT

Cash Management Internal Control / Segregation of Duties

CMHA has revised its Selection and Hiring Policy to include certain mandatory alerts and action items whenever an OIG exclusion inquiry shows an individual has been excluded. In addition, the policy has been updated to explicitly referenceOIG exclusion inquiries as part of the screening process and ...

CMHA has revised its Selection and Hiring Policy to include certain mandatory alerts and action items whenever an OIG exclusion inquiry shows an individual has been excluded. In addition, the policy has been updated to explicitly referenceOIG exclusion inquiries as part of the screening process and requires regular inquires to be performed on the entire staff of active employees, interns, vendors, and independent contractors every 60 days. CMHA is also in the process of contracting with a vendor to perform these regular OIG exclusion inquiries. CMHA maintains the good faith belief that the corrective actions described above will mitigate the risk of hiring or retaining an individual who has been excluded from participating in Medicare, Medicaid, or any other Federal health care program going forward.

View Audit 291697

Finding 370161 (2023-003)

Significant Deficiency 2023

Culver-Stockton College

MO

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

The College implemented the following policies effective September 2023. The responsible college officer is Tina Wiseman, Director of Financial Aid. • Students that graduate will automatically be sent exit counseling within 30 days of their last date of at least part-time attendance. • Students that...

The College implemented the following policies effective September 2023. The responsible college officer is Tina Wiseman, Director of Financial Aid. • Students that graduate will automatically be sent exit counseling within 30 days of their last date of at least part-time attendance. • Students that identify to the college that they are not returning for the next term of enrollment will be sent exit counseling within 30 days of that notification. • Students that enroll for the next term, but then drop their enrollment before the start of the next term, will have exit counseling sent within 30 days of the drop date. If that date falls more than 30 days outside of their last date of at least part-time attendance, the financial aid office will document their file of that notification. • Students that do not enroll for the next term but have identified to the college they plan to enroll (example, they have a balance due they need to pay, are waiting to hear on placement within a program, waiting on class schedule confirmation, etc.), will receive exit counseling within 30 days of census date of the next term. If a student identifies at any time before census they are not returning, exit counseling will be sent within 30 days of learning they are not returning. • Students that do not enroll for the next term and have not had any communication with the college on their plans to enroll will receive exit counseling within 30 days of census date of the next term.

View Audit 291681

Finding 370156 (2023-002)

Significant Deficiency 2023

Culver-Stockton College

MO

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. T...

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. The paperwork is returned to the first staff member to make the changes in PowerFAIDS. The responsible college official is Tina Wiseman, Director of Financial Aid.

View Audit 291681

Finding 370133 (2023-001)

Significant Deficiency 2023

West Babylon Union Free School District

NY

Allowable Costs / Cost Principles Cash Management Significant Deficiency § 200.430

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) A...

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing No. 84.425U Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries, wages and other forms of compensation must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs), timesheets, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District inadvertently charged resource officers payroll costs to a federal grant, however, it was determined that these payroll costs were not budgeted in the federal grant and should not have been charged to the federal grant. Planned Corrective Action: The District implemented a new summer program utilizing federal grant funds approved by the NYSED. The District charged resource officers payroll costs that occurred during the scheduled approved summer program, however it was determined that these payroll costs were not budgeted in the federal grant, per the FS-10. Since the grant funding period of this grant is still open, the District contacted NYSED to determine the necessary course of action to rectify this matter. It was determined that the District will prepare and submit an FS-10A amending the original FS-10, to include the resource officer’s payroll costs in the grant as it relates to the approved summer program. In addition, the District will review its internal review procedures to ensure that payroll costs charged to federal grants are supported by the proper documentation for each employee and are allowable per the approved budget of the federal grant. The FS-10A will be prepared and filed prior to the June 30, 2024 by the Assistant Superintendent for Curriculum. Responsible Contact Person: Denise Gillis Assistant Superintendent for Finance & Operations West Babylon Union Free School District 200 Old Farmingdale Road West Babylon, NY 11704 Anticipated Completion Date: June 30, 2024

View Audit 291652

Finding 370125 (2023-001)

Material Weakness 2023

Western Boone County Community School Corporation

IN

Procurement, Suspension & Debarment § 200.303

Information on the federal program: Subject: Special Education Cluster (IDEA) – Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federa...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (Or Other Identifying Number): 21611-095-PN01, 22611-095-PN01, 22611-095-ARP, 23611-095-PN01, 22619-095-PN01, 23619-095-PN01, 22619-095-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreements and Procurement and Suspension and Debarment compliance requirements. Context: During the audit period, the School Corporation had purchases over $25,000 from one vendor charged to the Special Education Cluster grants which requires suspension and debarment procedures. For the vendor selected for testing, there was no evidence provided to verify that the vendor was checked for suspension and debarment prior to entering into the transaction. The total amount disbursed to the vendor during the audit period was $113,921. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Management will establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This will include adding a clause to all future contracts of $25,000 or more and paid for with federal funds. We will notify our leadership team of this control to ensure compliance. Responsible Party and Timeline for Completion: Kyle Whitelely, Director of Business and Technology, will oversee this corrective action plan. It will be implemented immediately, and the leadership team will be notified of this control measure at the next leadership meeting scheduled for March 21, 2024.

View Audit 291647

Finding 370123 (2023-001)

Significant Deficiency 2023

Reading Area Community College

PA

Student Financial Aid

Federal Program Federal Pell Grant Program ALN 84.063, Contract #P063P223333 Criteria According to the Code of Federal Regulations (CFR) Title 34, Section 668.22(c), the withdrawal date for a student who ceases attendance at an institution that is not required to take attendance is the date, as de...

Federal Program Federal Pell Grant Program ALN 84.063, Contract #P063P223333 Criteria According to the Code of Federal Regulations (CFR) Title 34, Section 668.22(c), the withdrawal date for a student who ceases attendance at an institution that is not required to take attendance is the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution or the date, as determined by the institution, that the student otherwise provided official notification to the institution. Condition/Cause Out of a sample of 25 students who withdrew or did not maintain attendance during a semester within the audit period, there was one instance where an incorrect withdrawal date was used. Effect An R2T4 calculation was performed using an incorrect withdrawal date of October 3, 2022 which required the student to return $453 of Pell funds. The correct withdrawal date is September 28, 2022. Using September 28, 2022 as the withdrawal date, the student would have been required to return $487 of Pell funds. Recommendation We recommend that a process be put in place at the College to strengthen its controls to ensure that it performs accurate return of Title IV calculations. Management Response The College agrees with the deviation noted in the testing. The financial aid office continues to refine its processes and controls over the return of Title IV calculations to ensure the calculations remain accurate, including a review of calculations being made. Sincerely, Kenneth Dearstyne, Senior Vice President of Finance and Administrative Services

View Audit 291639

Finding 370120 (2023-001)

Significant Deficiency 2023

Arcadia University

PA

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2023-001 – Error in Return of Title IV Aid – Significant Deficiency ALN Number: 84.007, 84.063, 84.268 Federal Award Identification Number: P007A223541, P063P222079, P268K232079 Recommendation: It is recommended that University personnel review the Return of Title IV calculations and agree f...

Finding 2023-001 – Error in Return of Title IV Aid – Significant Deficiency ALN Number: 84.007, 84.063, 84.268 Federal Award Identification Number: P007A223541, P063P222079, P268K232079 Recommendation: It is recommended that University personnel review the Return of Title IV calculations and agree final amounts for refund to the refunds made to the Department of Education. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify the accuracy of the calculations and the amounts refunded. Action Taken: The University has returned the funds for the student tested. In addition, the University reviewed every Return of Title IV Aid calculation performed and the amounts refunded for the award year ended May 31, 2023 and has corrected any additional errors discovered. The University has provided additional training on this topic to financial aid staff, has increased the number of staff members who will monitor the accuracy of the work and has modified its procedures by developing a tracking system to add another level of review and accountability. This will enable the team to be sure the refund calculations are performed correctly for all students and consistently applied. Name of Contact Person Responsible for Corrective Action: Holly Kirkpatrick, Ed.D., Assistant Vice President for Financial Aid

View Audit 291636 Questioned Costs: $1

Corrective Action Plans

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