Corrective Action Plans

Finding 11010 (2023-001)

Significant Deficiency 2023

IL

Questioned Costs Allowable Costs / Cost Principles

The Association has implemented monthly procedures to reconcile grant expenses to the general ledger before they are processed for reimbursement. Additionally, we are developing a formal policy for employee incentive pay and will have it approved by the Board if Directors.

View Audit 14899 Questioned Costs: $1

Finding 11005 (2023-001)

None 2023

Lafayette House Elderly Housing, Inc.

MI

Internal Control / Segregation of Duties

A. Comments on Finding and Recommendations Recommendation – Auditor recommends that the Entity fund the reserve immediately to make it current and create a better system of controls to ensure no future occurrences. Auditor notes deposit was made prior to issuance of the financial statements. No furt...

A. Comments on Finding and Recommendations Recommendation – Auditor recommends that the Entity fund the reserve immediately to make it current and create a better system of controls to ensure no future occurrences. Auditor notes deposit was made prior to issuance of the financial statements. No further action is required. B. Actions Taken or Planned Auditee agrees with the finding and has made an additional deposit of $6,000 to the security deposit bank account on July 24, 2023, in order to fully fund the account. The Entity has established a monthly review to prevent shortfalls in the future. The error occurred because a miscalculation by a new oversight employee.

View Audit 14875

Finding 11004 (2023-001)

Significant Deficiency 2023

Centre Volunteers in Medicine

PA

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management

Since the finding was identified during the audit, the Organization has initiated a plan to prepare and file the written policies/procedures required of the Uniform Guidance

View Audit 14867

Finding 11000 (2023-001)

Significant Deficiency 2023

Abc Unified School District

CA

Internal Control / Segregation of Duties

The district has established a checkout form, effective July 1, 2023, the student registrar at the school site will be responsible for reaching out to the parent/ guardian to get the check-out form completed upon the exit of a student. The site administrator (principal, assistant principal, or couns...

The district has established a checkout form, effective July 1, 2023, the student registrar at the school site will be responsible for reaching out to the parent/ guardian to get the check-out form completed upon the exit of a student. The site administrator (principal, assistant principal, or counselor) at the school site will be reviewing this form for accuracy and competition. The check-out form will be saved and stored at the school site as a permanent record.

View Audit 14843

Finding 10980 (2023-002)

Material Weakness 2023

Western Oregon University

OR

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Finding 2023-002 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Gramm-Leach-Bliley Act (GLBA) – Student ...

Finding 2023-002 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Gramm-Leach-Bliley Act (GLBA) – Student Information Security Type of Finding: Material Weakness in Internal Controls Finding Summary: During testing over GLBA compliance, it was noted that the University had not updated the information security program and was missing aspects of the required nine elements. Responsible Individuals: Kella Helyer, Director of Financial Aid (DFA) and Michael Ellis, Assistant Director of University Computing Solutions (AD UCS) Corrective Action Plan: Management agrees with this finding. See the GLBA Draft Corrective Action Plan table below. Anticipated Completion Date: See the attached GLBA Draft Corrective Action Plan table below: GLBA documentation 314.4 Reference What WOU will do Complete by Date Who will do it Completion Date Document full status of 314.4 4/1/24 AD UCS a Complete b Update our CIS18 controls - aka InfoSec Program 7/1/24 AD UCS b.2 Risk assessment for on-prem servers with FinAid* data 4/1/24 AD UCS, Lead Windows Admin, Warehouse Programmer c.1 Document current processes and access controls 4/1/24 AD UCS, DFA c.2 Document current information, including Business Office 12/20/23 Financial Aid Accountant 12/13/23 c.3 Encrypte NetApp volumes, and ensure encryption on DB links 8/1/24 AD UCS, Lead Windows Admin, Warehouse Programmer c.4 Assess warehouse & BannerRPT 7/1/24 AD UCS, Warehouse Programmer, Operating Systems/Security Analyst c.5 Complete c.6 Review PowerFAIDS electronic files for purging Review paper files for purging Have Business Office review files for purging 8/1/24 DFA c.7 Audit FinAid data access upon addition to Warehouse 8/1/24 Warehouse Programmer and/or Operating Systems/Security Analyst c.8 Add access logs to WOU central logging system 8/1/24 AD UCS, Web & Banner Programmer d.2.i Annual pentest by Campus Guard 2/29/24 AD UCS e Complete f Document all 3rd party providers who interact with FinAid data. Audit yearly 8/1/24 DFA, AD UCS g Complete h Complete i Verbal report given in 2023. Anticipated written report to Board on 7/1/24 7/1/24 AD UCS

View Audit 14816

Finding 10974 (2023-001)

Material Weakness 2023

Western Oregon University

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: M...

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: Material Weakness in Internal Controls Finding Summary: During the testing of compliance for Enrollment Reporting, there were instances where the National Student Loan Data System (NLSDS) did not reflect accurate or timely reporting of a student’s change in enrollment status. While records were submitted accurately and timely to the National Student Clearinghouse, those records were not reflected in NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: Management agrees with this finding. The initial response to this request for data did not include the active and inactive enrollment levels for the requested sample students. Initially it appeared that there was a systems issue between the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS); however, upon further investigation and in conversation with NSLDS, the required information was found and subsequently provided to Eide Bailly on December 1, 2023. The resolution of this request for data was resolved but after the final audit report was submitted. Anticipated Completion Date: Completed December 1, 2023

View Audit 14816

Finding 10967 (2023-001)

Material Weakness 2023

Center for Advocacy for the Rights and Interests of the Elderly

PA

Reporting Material Weakness

Center for Advocacy for the Rights and Interests of the Elderly (CARIE) respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: Year ending June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding...

Center for Advocacy for the Rights and Interests of the Elderly (CARIE) respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: Year ending June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—SINGLE AUDIT MATERIAL WEAKNESS 2023‐001 Internal Control over Compliance and Compliance (Reporting) Recommendation: We recommend management evaluate their internal controls surrounding the major federal programs to ensure compliance with the reporting requirements of their grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will create a reporting calendar with due dates to be reviewed monthly. The Finance Manager will prepare the reports and the Executive Director will review the reports prior to submission. Names of contact responsible for corrective action: Whitney Lingle, Executive Director. Planned completion date for corrective action plan: June 30, 2024. If the Department of Health and Human Services has questions regarding this plan, please call Whitney Lingle at (267) 546‐3434.

View Audit 14811

Finding 10962 (2023-001)

Significant Deficiency 2023

Tensas Community Health Center

LA

The Center agrees with the finding. While additional training and corrections to the practice management system were completed in the prior fiscal year, turnover and additional system issues still plague the process. The Center has developed an improved front desk audit tool in response to this find...

The Center agrees with the finding. While additional training and corrections to the practice management system were completed in the prior fiscal year, turnover and additional system issues still plague the process. The Center has developed an improved front desk audit tool in response to this finding which includes verifying certain sliding fee components with an updated methodology increasing the number in the sample per month. The new front desk audit tool will be tested by February 28, 2024 and continue monthly with changes suggested during the test as needed throughout the next 12 months.

View Audit 14809

Finding 10957 (2023-001)

Significant Deficiency 2023

Independent School District No. 280

MN

Procurement, Suspension & Debarment

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.553, AND 10.582 2023-001 Internal Control Over Compliance With Federal Suspension and Debarment Requireme...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.553, AND 10.582 2023-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires Independent School District No. 280 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including applicable suspension and debarment requirements. The District did not have sufficient controls in place within the child nutrition cluster federal programs 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 policies and procedures relating to suspension and debarment for child nutrition cluster 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 Finance, James Gilligan. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Chief Administrative Officer, Craig Holje, will monitor the implementation of these corrective actions as determined by the Director of Finance to 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 14792

Finding 10955 (2023-001)

Significant Deficiency 2023

Linn County

OR

Reporting Special Tests & Provisions Significant Deficiency

1. Deficiency #1 a. Significant Deficiency: SA 2023 - 001 - SIGNIFICANT DEFICIENCY FEDERAL PROGRAM: 21.027 - Coronavirus State and Local Fiscal Recovery Funds SPECIFIC REOUREMENT: Expenditures being reported under the major program were made in accordance within grant compliance. CONDITION: During o...

1. Deficiency #1 a. Significant Deficiency: SA 2023 - 001 - SIGNIFICANT DEFICIENCY FEDERAL PROGRAM: 21.027 - Coronavirus State and Local Fiscal Recovery Funds SPECIFIC REOUREMENT: Expenditures being reported under the major program were made in accordance within grant compliance. CONDITION: During our testing of Quarterly Project and Expenditure Reporting forms, we noted that there was inaccurate reporting of expenditures, where monies expended in fiscal year 2022 were reported as 2023 expenditures. Forms submitted prior to fiscal year 2023 start, had a clerical error where the second quarter of fiscal year 2022 was improperly identified as the third quarter of 2022. QUESTIONED COST: None noted. CONTEXT: This finding is limited to this major program and the context noted in the condition. The minimum noted in questioned cost, is the amount where no documentation was maintained and maximum is the amount reimbursed under this program related to the condition noted. EFFECT: Without adequate controls or procedures in place to review reporting documents, the possibility exists that expenditures may be improperly charged to inaccurate fiscal years under a federal grant program. CAUSE: The County did not have adequate review processes in place to ensure accuracy ofreporting forms. RECOMMENDATION: We recommend the County implement review policies and procedures for federal awards to ensure proper usage and ensure compliance with federal award provisions.b. Linn County, Oregon - PLAN OF ACTION: LINN COUNTY management agrees with the finding. The County has implemented a grant reporting process where grant reports are reviewed by a second person before the reports are filed with the corresponding agency. c. Timeframe: Linn County management implemented the changes discussed in b. above on May 15, 2023.

View Audit 14787

Finding 10952 (2023-001)

None 2023

Harvard University

MA

Student Financial Aid Eligibility Reporting

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistanc...

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The enrollment reporting exceptions identified by PwC were isolated to one Harvard school and did not impact the loan repayment status for any student. The exceptions were the result of system reporting and management has completed corrective actions. Program level enrollment effective date was addressed by correcting the enrollment reporting logic within the Harvard school’s reporting system, Ellucian Banner. This updated logic now provides accurate program status effective dates in the National Student Clearinghouse (NSC) reporting file. Harvard successfully transmitted its first file with the updated logic to NSC in November 2023. As program level enrollment data is not used to initiate loan repayment or other loan status changes; these students were not negatively impacted. Withdrawn versus graduation status issue was isolated to off-cycle graduation events in November and March. Although the final status was reported as withdrawn instead of graduated for these selections, there was no impact on the student’s loan repayment or eligibility as we appropriately reported the initial separation event. Harvard implemented a “Graduates Only” NSC reporting file to correctly transmit the graduation status for these off-cycle graduates which will ensure compliance going forward. Sincerely, Amanda McDonnell University Controller 617-495-8032

View Audit 14779

Finding 10949 (2023-001)

Material Weakness 2023

Lake County Community College District

OH

Cash Management Subrecipient Monitoring Material Weakness § 200.305

Condition: The College drew down an estimated amount of cash prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: There is not anymore HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future, the C...

Condition: The College drew down an estimated amount of cash prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: There is not anymore HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future, the College will follow the three-day drawdown rules for cash disbursements. Contact person responsible for corrective action: Tom Reynolds College Treasurer Anticipated Completion Date: 12/14/2023 as soon as possible moving forward

View Audit 14778

Finding 10948 (2023-001)

Material Weakness 2023

South Redford School District

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Special Tests & Provisions

Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovatio...

Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2023 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovation, or construction contracts that are over $2,000 and use laborers and mechanics, must meet Davis-Bacon prevailing wage requirements. The School District expended ESSER funds that related to repairs and renovations; however, the prevailing wage requirement was not included in any of the related contracts' language, nor did the School District receive or review the certified payroll reports from any of the contractors. Planned Corrective Action: As it pertains to the use of ANY Federal funds for construction projects in the South Redford School District (SRSD), when said funds will be used to compensate for labor for any construction project: We must stipulate in all RFP’s, Davis-Bacon requirements for prevailing wages as it relates to the use of laborers and mechanics, for all projects over $2,000. All responses to RFP’s must: 1. Acknowledge the Davis Bacon prevailing wage requirement; 2. All bid pricing must reflect prevailing wage requirements; 3. Bid recipients must have a process in place for reporting their compliance to the prevailing wage requirement and submit documentation along with all invoices, be it directly to SRSD or to the construction management firm, who will then include said documentation with their backup and invoices to SRSD. Contact person responsible for corrective action: Linda Earl, Finance Director Anticipated Completion Date: November 1, 2023

View Audit 14775

Finding 10938 (2023-009)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Material Weakness Reporting

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and is committed to establishing and enforcing internal control procedures for compliance with performance reporting requirements. We will work to improve our oversight and compliance in this regard. o A compliance team wil...

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and is committed to establishing and enforcing internal control procedures for compliance with performance reporting requirements. We will work to improve our oversight and compliance in this regard. o A compliance team will be appointed to ensure that the agency adheres to all compliance requirements. o The compliance team will work closely with the PM to coordinate and delegate tasks to collect the data needed to complete the report. o The compliance team will assist in creating a process for maintaining documentation to support what is reported. o The compliance team will document the level of compliance in which internal controls are followed and report results to program and agency leadership along with recommendations for improvement. Internal audits will be conducted in preparation for external audits. • Anticipated Completion Date: The process will be implemented on January 3, 2024, and will continuously be reviewed and updated to align with best practices.

View Audit 14751

Finding 10937 (2023-008)

Significant Deficiency 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Reporting Significant Deficiency

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and agree to implement procedures for reviewing financial reports and ensuring that the CFAO signs off on the review before submission to the granting agency. We are committed to improving the accuracy and compliance of fina...

• Corrective Action Plan: Caritas Family Solutions acknowledges the finding and agree to implement procedures for reviewing financial reports and ensuring that the CFAO signs off on the review before submission to the granting agency. We are committed to improving the accuracy and compliance of financial reports. • Anticipated Completion Date: In July 2023, management implemented formal review, performed by the CFAO, of all SA1 and SA2 reports.

View Audit 14751

Finding 10936 (2023-007)

None 2023

Caritas Family Solutions and Affiliates

IL

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

• Corrective Action Plan: The monthly reports are submitted through the CWI portal and since the former Project Manager left the agency, no one else has been granted access to the portal. Several requests have been made to CWI and promises from CWI to grant access to the current Project Manager, but...

• Corrective Action Plan: The monthly reports are submitted through the CWI portal and since the former Project Manager left the agency, no one else has been granted access to the portal. Several requests have been made to CWI and promises from CWI to grant access to the current Project Manager, but access remains elusive. Without access to the portal, - Caritas Family Solutions does not have the template for the report and do not know what data are reported. Moving forward, a hardcopy of the report will be kept on file in the SCSEP office for future reference and audit purposes. The reports are submitted via the funder’s portal and with the departure of the previous program manager, no one at Caritas has access to the poral. Several requests were made to the funder to grant the new program manager access, but those requests have not been honored. • Anticipated Completion Date: The process will be ongoing once management receives access to the portal.

View Audit 14751

Finding 10935 (2023-006)

None 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification appl...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification application and gather the necessary documentation.

View Audit 14751

Finding 10934 (2023-005)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification appli...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o A SCSEP Employment Specialist will meet with participants to complete the recertification application and gather the necessary documentation. o The recertification application and documentation will be forwarded to the PM for review and approval. o The PM will review the form, sign, and date it after confirming that all information is accurate and complete. o If there are inaccuracies and/or missing information, the form will be returned to the ES who will follow up with the host site to obtain the missing information or correct the inaccuracy. o Steps 1 and 2 will be repeated. o The QI department will conduct quarterly file reviews to determine if processes are being followed. Re-certification was modified during the pandemic out of an abundance of caution for the participants in the program. Those who had access to the internet were asked to email their documentation, and those who didn’t were asked to mail theirs. A drive through recertification process was implemented when COVID restrictions eased, and participants were asked to remain in their vehicles while SCSEP employment specialists obtained their recertification documentation. Many participants do not have transportation and were not able to participate in the drive through. The most recent, pre-pandemic certification information for participants was used for those who were not able to attend the drive through or virtual recertification processes. CWI did not end COVID protocols until Q4 of PY2022 (April 1, 2023). Alternative recertification methods were used to comply with the protocols. With the end of the COVID protocols and restrictions, we have reinstituted the in-person/face-to-face recertification process required by the funder. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded.

View Audit 14751

Finding 10933 (2023-004)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing whi...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded. o A SCSEP Employment Specialist will meet with participants to complete the recertification application and gather the necessary documentation. o The recertification application and documentation will be forwarded to the PM for review and approval. o The PM will review the form, sign, and date it after confirming that all information is accurate and complete. o If there are inaccuracies and/or missing information, the form will be returned to the ES who will follow up with the host site to obtain the missing information or correct the inaccuracy. o Steps 1 and 2 will be repeated. o The QI department verify eligibility and recertification documents are within the file during their quarterly reviews to determine if processes are being followed.

View Audit 14751

Finding 10932 (2023-003)

Significant Deficiency 2023

Caritas Family Solutions and Affiliates

IL

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

• Corrective Action Plan: Caritas Family Solutions acknowledge the finding and are committed to establishing and enforcing internal control procedures for earmarking compliance requirements. We will work to improve our oversight and compliance in this regard. o A compliance team from the QI Departm...

• Corrective Action Plan: Caritas Family Solutions acknowledge the finding and are committed to establishing and enforcing internal control procedures for earmarking compliance requirements. We will work to improve our oversight and compliance in this regard. o A compliance team from the QI Department will be appointed to ensure that the program adheres to all compliance requirements. o The compliance team will work closely with the PM to coordinate and delegate tasks to determine how and what data will be collected. o The compliance team will work closely with the PM to determine who has responsibility for data entry, compilation, and processing. o The compliance team will assist the program in creating a process for maintaining, storing, and securing data for the required period. o The compliance team will review compliance throughout the life of the grant and adjust, as necessary. • Anticipated Completion Date: The process will be implemented on January 3, 2024, and will be continually updated to align with best practices.

View Audit 14751

Finding 10931 (2023-002)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Material Weakness

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o After the PM has verified that timesheets are accurate and complete, they will be scanned and s...

• Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o After the PM has verified that timesheets are accurate and complete, they will be scanned and sent to Payroll for processing. o Payroll will maintain a copy of the email providing the documents and will comply with federal guidelines of storing records for a period after the close of the grant. o The PM will file a hard copy of the timesheets in the SCSEP office. o The files will be kept in the office until completion of quarterly reviews for the fiscal year by the QI department, and then they will be transferred to the agency’s long-term storage facility for files. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded

View Audit 14751

Finding 10930 (2023-001)

Material Weakness 2023

Caritas Family Solutions and Affiliates

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding 2023-001: Lack of Internal Control Review for Allowable Costs • Responsible Party: Gary Huelsmann, Chief Executive Officer • Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure t...

Finding 2023-001: Lack of Internal Control Review for Allowable Costs • Responsible Party: Gary Huelsmann, Chief Executive Officer • Corrective Action Plan: This deficiency was also discovered during our internal investigation, and Caritas Family Solutions has implemented a new process to ensure that internal controls are in place. o Program participants will only be paid for verified hours of service. An annual meeting (either one-on-one or in a group) will be held with site supervisors to discuss processes and procedures and program expectations. During this meeting, supervisors will be shown how to complete the timesheet and given details on how to submit them for processing. o Individual and group meetings will be held with program participants to explain the process to them and remind them that payments will not be made until timesheets are accurate and complete. Timesheets are due on Friday prior to pay dates. o The ES will review submitted timesheets for accuracy and completeness and will forward them to the PM for review and final approval before they are submitted to Payroll for processing. o The PM will review the form, sign, and date it after confirming that all information is accurate and complete. o If there are inaccuracies and/or missing information, the form will be returned to the ES who will follow up with the host site to obtain the missing information or correct the inaccuracy. o Steps 1 and 2 will be repeated. o The QI department will conduct quarterly file reviews to determine if processes are being followed. • Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while the program is funded.

View Audit 14751

Finding 10920 (2023-001)

Significant Deficiency 2023

University of New Mexico

NM

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid § 200.303

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent ...

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent upon packaging which includes type of loan offered, amount, and semester. The loan offer also includes instructions on how to accept the loan and links to resources such as loan interest rates, promissory notes, entrance counseling and how to access loan history via NSLDS. If students choose to accept the loan(s), a loan acceptance notification is sent. This notification includes type of loan, amount, and semester. It also includes right to cancel information, cancellation procedures and instructions on accessing loan history. Loan acceptance notifications are sent nightly upon acceptance. The timing of the loan offer and acceptance notifications is based on when the student completes their financial aid file and is packaged, and when they accept their loan(s) but does not correspond with the actual loan disbursement. UNM has been relying on the loan offer and acceptance notifications and COD disbursement notifications to convey the loan disbursement notification information as required per 34 CFR 668.165. Effective immediately, UNM will establish an internal process to send loan disbursement notifications within 30 days of the actual loan disbursement. The internal process will duplicate our current offer and acceptance notifications. UNM will continue to opt in to COD disbursement notifications as a secondary method of communication. Contact Person: Elizabeth Jacquez-Amador Anticipated Completion Date: October 31, 2023

View Audit 14747

Finding 10918 (2023-003)

Significant Deficiency 2023

Fletcher Public Schools

OK

Questioned Costs Procurement, Suspension & Debarment

The school will make sure no purchase is initiated without first obtaining an approved purchase order and adequate documentation.

View Audit 14729 Questioned Costs: $1

Finding 10914 (2023-002)

Material Weakness 2023

Three Rivers Community Schools

MI

Matching / Level of Effort / Earmarking

Condition: The School District tracked employee activities through the use of schedules and semi-annual certifications but did not have adequate controls in place to ensure these personnel activity reports/certifications were reviewed timely and accurately. During payroll expenditure testing of s...

Condition: The School District tracked employee activities through the use of schedules and semi-annual certifications but did not have adequate controls in place to ensure these personnel activity reports/certifications were reviewed timely and accurately. During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Planned Corrective Action: Three Rivers Community Schools agrees with the above recommendation. While the proper controls were not in place throughout the year, the School District changed their procedures and controls near year-end to allow for a review and reconciliation process to support that the amount charged to Title I based on actual time expended on Title I activities. Contact person responsible for corrective action: Angie Tesman, Director of Business Operations Anticipated Completion Date: 11/7/2023

View Audit 14719

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