Corrective Action Plans

Finding 7899 (2023-003)

Significant Deficiency 2023

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

Management will meet with the grant Program Manager(s) to review and ensure all of the City’s Federal Grants Management Policies are being adhered to.

View Audit 10301

Finding 7897 (2023-003)

Significant Deficiency 2023

Community Unit School District No. 3

IL

Subrecipient Monitoring Cash Management Reporting

Finding Synopsis: The District has inadequate controls over reviewing and approving quarterly "historical expenditure reports" filed with the Illinois State Board of Education. Action Steps: The District intends to fully implement the recommendation in FY2024, as corrective action was not taken unti...

Finding Synopsis: The District has inadequate controls over reviewing and approving quarterly "historical expenditure reports" filed with the Illinois State Board of Education. Action Steps: The District intends to fully implement the recommendation in FY2024, as corrective action was not taken until midway through FY2023.

View Audit 10289

Finding 7882 (2023-002)

Significant Deficiency 2023

West Shore Community College

MI

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

2023-002 – Gramm Leach Bliley Missing Compliance Requirements. Auditor Description of Condition and Effect. The most recent written security policy fails to address how the College will oversee its information system service providers and the evaluation and adjustment of its information security pro...

2023-002 – Gramm Leach Bliley Missing Compliance Requirements. Auditor Description of Condition and Effect. The most recent written security policy fails to address how the College will oversee its information system service providers and the evaluation and adjustment of its information security program for any changes in the College's operations or the results of risk assessments. Additionally, the College's policy does not include performing annual penetration tests or biannual vulnerability assessments, as required by the Gramm Leach Bliley Act. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley policies are met and confirmed by a second individual. Corrective Action. To address the missing element of Gramm Leach Bliley #6, procedures will be set in place to ensure oversight of our information service providers. A team will review and track who our providers are ensuring they meet our technical requirements in addition to the needs of our students and staff. To address the missing element of Gramm Leach Bliley #7, procedures will be set in place to ensure oversight of our information security protocols. A team will review our procedures at least annually, and make any necessary adjustments as changes to security protocols continue to evolve. Part of the procedures will include mandatory semi-annual information security training required by all staff, in addition to basic security information provided annually to students. Finally procedures to perform annual penetration testing will be established based on relevant identified risks. This could include any vulnerability assessments, in the form of systematic scans or review of information systems reasonably identified. These assessments should be completed at a minimum semi-annually, or whenever there may be material changes in operations that could be impacted. Responsible Party. Director of Information Technology and Student Services. Anticipated Completion Date. January 1, 2024.

View Audit 10258

Finding 7878 (2023-001)

Significant Deficiency 2023

West Shore Community College

MI

Student Financial Aid Allowable Costs / Cost Principles Eligibility

2023-001 – Pell Grant Calculation. Auditor Description of Condition and Effect. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule pr...

2023-001 – Pell Grant Calculation. Auditor Description of Condition and Effect. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full-time in a term-based program. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. In the spring of each year, the College Financial Aid Department will establish the Cost of Attendance (COA) necessary for Pell student eligibility, in addition to the Educational Financial Contribution (EFC) for the following fiscal year. Once these are calculated and established, the head of the Business Office will review the calculations, discuss, and approve. Once they have been approved, the appropriate information will be entered into the Financial Aid software system. Responsible Party. Director of Financial Aid and Head of the Business Office. Anticipated Completion Date. June 30, 2024.

View Audit 10258

Finding 7858 (2023-003)

Material Weakness 2023

Prattsburgh Central School

NY

Internal Control / Segregation of Duties

Adjusting Journal Entries and Required Disclosures to the Financial Statements Year ended June 30, 2023 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and in the future, under the new pronouncement, the District should continue to review and accept both ...

Adjusting Journal Entries and Required Disclosures to the Financial Statements Year ended June 30, 2023 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and in the future, under the new pronouncement, the District should continue to review and accept both proposed adjusting journal entries and footnote disclosures, along with the draft financial statements. School District’s Response: The District has received, reviewed and approved all journal entries, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Further, the District believes it has a thorough understanding of these financial statements and the ability to make informed judgments based on these financial statements. Mr. Kory Bay (Superintendent) will continue to review and approve the proposed adjusting journal entries, footnote disclosures and draft financial statements for the year ending June 30, 2024.

View Audit 10237

Finding 7856 (2023-001)

Significant Deficiency 2023

Cross Anchor Utility District

TN

Recommendation: Year-end closing entries should be made, if possible, by District personnel. We understand that that the financial information is accurately reported on the general ledger on a cash basis. However, material entries were required as a result of audit procedures to accurately present t...

Recommendation: Year-end closing entries should be made, if possible, by District personnel. We understand that that the financial information is accurately reported on the general ledger on a cash basis. However, material entries were required as a result of audit procedures to accurately present the financial statements on a basis consistent with U.S. GAAP. Should limited staffing be a concern, we recommend that the District outsource the year end closing entries to an accounting firm so that financial statements are properly stated before they are audited. Action Taken: The District will consider this recommendation and explore the above as well as alternative options for implementation.

View Audit 10227

Finding 7851 (2023-001)

None 2023

Winslow Township Board of Education

NJ

School Nutrition Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Method of Implementation - School District personnel will continue to work closely with the Food Service Director to determine the needs of the District in an effort to reduce year end net cash resources. Person Responsible - Director of Food Servcies; Assistant Business Administrator; and Bu...

Method of Implementation - School District personnel will continue to work closely with the Food Service Director to determine the needs of the District in an effort to reduce year end net cash resources. Person Responsible - Director of Food Servcies; Assistant Business Administrator; and Business Administrator/Board Secretary. Implementation Dates - June 30, 2024

View Audit 10213

Finding 7850 (2023-001)

Significant Deficiency 2023

Aha Westhaven, LLC

AL

HUD Housing Programs Eligibility Reporting

ALN 14.195 – Section 8 Housing Assistance Payments Program – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs by making the required monthly deposits to the Reserve for Replacement account. Person...

ALN 14.195 – Section 8 Housing Assistance Payments Program – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs by making the required monthly deposits to the Reserve for Replacement account. Person Responsible for Correction of Finding: Bobby Johns, Secretary-Treasurer Projected Completion Date: June 30, 2024

View Audit 10211

Finding 7849 (2023-001)

Significant Deficiency 2023

San Diego Blood Bank

CA

Questioned Costs Cash Management § 200.68

The Blood Bank added review and approval processes to ensure only allowable charged are included in the MTDC subject to the indirect cost rate.

View Audit 10207 Questioned Costs: $1

Finding 7848 (2023-001)

None 2023

The Cleveland Institute of Art and Subsidaries

OH

Student Financial Aid Internal Control / Segregation of Duties

Management acknowledges that there was an error in the amount of Pell awarded to the student. Cleveland Institute of Art is in the process of calculating the number of students affected by the issue and reconciling any differences. The College is also reconfiguring the systems to ensure that this is...

Management acknowledges that there was an error in the amount of Pell awarded to the student. Cleveland Institute of Art is in the process of calculating the number of students affected by the issue and reconciling any differences. The College is also reconfiguring the systems to ensure that this issue does not continue. The financial aid office will import on a regular basis the credit hour update/create student update into Powerfaids using the data integration from J1 table to load credit hours onto the student record until the Pell recalculation/census date. The financial aid office will continue to share with the Registrar’s office the Financial Aid credit hours update report that shows hours not contributing to the program so they can correct the coding on specific coursework into the appropriate “trees.” Powerfaids only imports hours contributing to the program. At the beginning of the semester, and prior to disbursing aid, the financial aid office will look for enrollment discrepancies and reconcile hours in their system with a registration report from the Registrar’s office. On the census date, which is defined as day 15 of the term, the financial aid office will lock down the enrollment hours on the student record after reconciling the hours on the student record with the hours on the Registrar’s census report.

View Audit 10206

Finding 7847 (2023-002)

Material Weakness 2023

Garfield County School District

UT

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.326

Auditee Response: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to when applicable. Corrective Action Plan: (1) Any contracts over $2,000 will include th...

Auditee Response: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to when applicable. Corrective Action Plan: (1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Lane Mecham, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract – November 2023 Certified weekly payroll reports obtained from contractor – November 2023

View Audit 10202

Finding 7846 (2023-005)

Significant Deficiency 2023

City of Henderson

NV

Reporting Significant Deficiency

Finding 2023-005 Finding Summary: The City did not have adequate internal controls to ensure Project and Expenditures Reports were prepared in accordance with governing requirements as estimates obligations, rather than actual, were reported. The OMB Compliance Supplement requires that reports submi...

Finding 2023-005 Finding Summary: The City did not have adequate internal controls to ensure Project and Expenditures Reports were prepared in accordance with governing requirements as estimates obligations, rather than actual, were reported. The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. The City of Henderson (the City) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Certain critical information includes: • Obligations and Expenditures • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure Responsible Individuals: Rebecca Gillis, Accounting Manager Corrective Action Plan: City management and staff has reviewed the reporting requirements. The City has contacted the Treasury Department to assist in updating the obligated amounts reported in their reporting system. This is currently a system limitation that the City is unable to correct. Anticipated Completion Date: Ongoing pending response from the Treasury Department

View Audit 10194

Finding 7838 (2023-002)

Significant Deficiency 2023

Rio Rancho Public School District No. 94

NM

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.303 § 200.306 § 200.308 § 200.403

Executive Director of Finance: Management agrees with this finding. The school district converted to a new financial ERP system as of July 1, 2023. The new ERP system flags any duplicate invoice numbers that maybe entered. The Accounts Payable (A/P) staff will verify if payment has already been made...

Executive Director of Finance: Management agrees with this finding. The school district converted to a new financial ERP system as of July 1, 2023. The new ERP system flags any duplicate invoice numbers that maybe entered. The Accounts Payable (A/P) staff will verify if payment has already been made. On occasion, payment requests do not have an invoice number. To prevent duplicate payments, the Accounts Payable staff require original invoices and uses a system generated invoice number, or a will use a manual entry numbering convention to prevent duplicate invoice numbers. The invoice data is entered by an Accounts Payable specialist and reviewed by the Accounts Payable Manager. On occasion, A/P must request corrected invoices from vendors who try and reuse invoice numbers. The A/P Manager reviews invoice numbers during the check run for accuracy. Purchasing and A/P will also periodically review the vendor database for duplicate vendors. For construction projects that list a pay application number instead of an invoice number, A/P will implement a consistent invoice numbering convention to avoid duplicate payments. The A/P specialists will also review the PO payment history prior to processing. Responsible party(ies) for corrective action(s): Accounts Payable Manager Corrective action(s) timeline: December 1, 2023

View Audit 10190 Questioned Costs: $1

Finding 7836 (2023-001)

Material Weakness 2023

City of Madison Heights, Michigan

MI

Procurement, Suspension & Debarment § 200.214

Finding Number: 2023-001 Condition: The City had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Planned Corrective Action: City Manager office staff has searched the State Procurement office webpage to check if any vendor f...

Finding Number: 2023-001 Condition: The City had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Planned Corrective Action: City Manager office staff has searched the State Procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future as part of Federal Grant Funding implementation staff will check vendors to make sure they are not debarred or suspended from federal funding awards. Contact person responsible for corrective action: Melissa Marsh, City Manager Anticipated Completion Date: 10/10/2023

View Audit 10187

Finding 7832 (2023-001)

Material Weakness 2023

Selinsgrove Area School District

PA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment School Nutrition Programs

The Selinsgrove Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the Single Audit Report Year Ended June 30, 2023 included in the schedule of findings and questioned costs are discussed below. Finding 2023-0001: Activi...

The Selinsgrove Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the Single Audit Report Year Ended June 30, 2023 included in the schedule of findings and questioned costs are discussed below. Finding 2023-0001: Activities Allowed. Contact Person: Jeff Hummel, Business Manager. Recommendation: The District should follow its established internal control procedures over activities allowed requirements. Action: The District will continue to review its internal control procedures over disbursements and increase its usage of the financial accounting system to aid in the management of the approval process prior to disbursements. Date for Completion: June 30, 2024.

View Audit 10167

Finding 7831 (2023-004)

Significant Deficiency 2023

Cherry County Hospital

NE

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Condition: The Hospital reported amounts in the reporting portal for information technology expenditures for Quarter 3 2022 in excess of amounts that are supported by audit evidence. Planned Corrective Action: Management will continue to refine processes to more diligently review the calculation of...

Condition: The Hospital reported amounts in the reporting portal for information technology expenditures for Quarter 3 2022 in excess of amounts that are supported by audit evidence. Planned Corrective Action: Management will continue to refine processes to more diligently review the calculation of allowable expenses and amounts entered into the provider relief fund reporting portal. Contact Person: Stephanie Jacobsen, Interim Chief Financial Officer Anticipated Completion Date: March 31, 2024

View Audit 10165

Finding 7829 (2023-001)

Significant Deficiency 2023

Child & Family Resources, Inc.

AZ

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

Management’s Response – Corrective Action Plan: When using federal funds to compensate employees, Child & Family Resources (CFR) acknowledges that the internal controls need to reasonably assure that the charges are accurate, allowable and properly allocated. The records should support the distribut...

Management’s Response – Corrective Action Plan: When using federal funds to compensate employees, Child & Family Resources (CFR) acknowledges that the internal controls need to reasonably assure that the charges are accurate, allowable and properly allocated. The records should support the distribution of the employee’s salary or wages among the specific activities charged. CFR uses a third party payroll company (Paycom) for payroll and time and attendance reporting. The payroll allocations are tracked based on percentages approved by the funding source or by employee entries on their timesheet reflecting the grant they are working on. For direct service employees that are allocated to various federal grants, CFR will include the following information on the budget narrative that will outline the specific employee, their time allocation and need. The Federal Program will be able to review and approve the amount of time these employees will spend under their specific grant rendering the allocation as an allowable expense. The language to be included within the budget narrative outlining this allocation is as follows: Labor Costs (Special Considerations): Compensation to members of the non-profit institution, trustees, directors, associates, officers and immediate family thereof: (Name of employee with breakdown of time to be spent on contract) Explanation of why this cost is necessary for the (Program’s) Operations: What is the total cost to the agency? Is the cost a less-than-arms-length transaction? Contact Person: The Grants & Contracts Coordinator (Scott Fauland) will complete the budget narratives for the federal funding agencies and include the above language within them in order to receive approval from the contracting agency. Completion Date CFR will submit the Special Considerations request to the current federal contracts awarded for Fiscal Year 2024 by December 2023 for approval. On new federal contracts, this language will be included on the budget narratives submitted from the original submission. This will be implemented for new contracts starting December 1, 2023.

View Audit 10163 Questioned Costs: $1

Finding 7827 (2023-001)

None 2023

Johnsburg Community Unit School District No. 12

IL

Questioned Costs School Nutrition Programs

Condition: The District submitted claims for meal reimbursements that were higher than the meals actually served. Plan: Management will review and implement procedures to ensure the reports used for daily counts match the reports used for submitting the claim to ISBE. Anticipated Date of Completion:...

Condition: The District submitted claims for meal reimbursements that were higher than the meals actually served. Plan: Management will review and implement procedures to ensure the reports used for daily counts match the reports used for submitting the claim to ISBE. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Annie Mulvaney, Assistant Superintendent Management Response: N/A

View Audit 10160 Questioned Costs: $1

Finding 7822 (2023-001)

Significant Deficiency 2023

Higher Ground Academy

MN

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Cash Management § 200.302

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The Academy will adopt the referenced policies to achieve compliance with Uniform Guidance. 3. Official Responsible Samuel Yigzaw, Executive Director, is the of...

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The Academy will adopt the referenced policies to achieve compliance with Uniform Guidance. 3. Official Responsible Samuel Yigzaw, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2024 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Plan.

View Audit 10150

Finding 7819 (2023-002)

Significant Deficiency 2023

Higher Ground Academy

MN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. Current practices will be...

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. Current practices will be revised to ensure proper documentation is retained supporting all future reports submitted to the State. 3. Official Responsible Samuel Yigzaw, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2024 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Action Plan.

View Audit 10150

Finding 7818 (2023-001)

Material Weakness 2023

Village Apartments of Cherry Hill, Inc.

NJ

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

The HUD Form 9839 has been prepared and sent for signature of the Project Owner. Once it is received back it will be signed by the Management Agent and forwarded to our HUD Asset Manager.

View Audit 10143 Questioned Costs: $1

Finding 7815 (2023-001)

None 2023

Marengo-Union Elementary Consolidated School District No. 165

IL

Condition: Data submitted on the LEA Data Collection Form showed some key line-item expenditures categorized differently from previously filed expenditure reports. Plan: Management will implement procedures including reconciling amounts between underlying data, quarterly expenditure reports, and ann...

Condition: Data submitted on the LEA Data Collection Form showed some key line-item expenditures categorized differently from previously filed expenditure reports. Plan: Management will implement procedures including reconciling amounts between underlying data, quarterly expenditure reports, and annual data collection reports. Additionally, reports and supporting documentation will be reviewed by a second person. Anticipated Date of Completion: 6/30/24 Name of Contact Person: Lea Damisch

View Audit 10142

Finding 7805 (2023-004)

Significant Deficiency 2023

Town of Westport, Conencticut

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

United States Department of the Education 2023-004 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE policies be updated to include that vendors will be reviewed to ensure they are not suspended and debarred. Explanation of disagreement with audit finding...

United States Department of the Education 2023-004 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE policies be updated to include that vendors will be reviewed to ensure they are not suspended and debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management further notes that a policy will be put in place to review all vendors through the Sam website to verify that the vendor has not been debarred or ineligible from receiving Federal Government funds. The of the contact person responsible for corrective action: Elio Longo Planned completion date for corrective action plan: June 30, 2024.

View Audit 10136

Finding 7804 (2023-002)

Significant Deficiency 2023

Town of Westport, Conencticut

CT

Procurement, Suspension & Debarment Reporting Significant Deficiency § 200.318 § 200.326

United States Department of the Education 2023-002 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation...

United States Department of the Education 2023-002 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management will update their purchasing policy to ensure compliance with Uniform Guidance. The of the contact person responsible for corrective action: Elio Longo

View Audit 10136

Finding 7802 (2023-003)

Significant Deficiency 2023

Town of Westport, Conencticut

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

United States Department of the Treasury 2023-003 COVID-19 American Rescue Plan Act Local Fiscal Recovery – AL No. 21.027 United States Department of Transportation 2023-003 Highway Planning and Construction – AL No. 21.205 Recommendation: We recommend that the policies be updated to include t...

United States Department of the Treasury 2023-003 COVID-19 American Rescue Plan Act Local Fiscal Recovery – AL No. 21.027 United States Department of Transportation 2023-003 Highway Planning and Construction – AL No. 21.205 Recommendation: We recommend that the policies be updated to include that vendors will be reviewed to ensure they are not suspended and debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management further notes that a policy was put in place in March 2023 to review all vendors through the Sam website to verify that the vendor has not been debarred or ineligible from receiving Federal Government funds. Name of the contact person responsible for corrective action: Sheila Carey

View Audit 10136

Corrective Action Plans

Filters