Corrective Action Plans

Finding 2398 (2023-004)

Significant Deficiency 2023

Independent School District No. 213 Osakis Public Schools

MN

School Nutrition Programs Internal Control / Segregation of Duties Special Tests & Provisions

2023-004 Verification Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555 and 10.559 Federal Award Identification Number and Year: 212MN061N1199- 2023 Pass-Through Agency: Minnesota Department of Education P...

2023-004 Verification Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555 and 10.559 Federal Award Identification Number and Year: 212MN061N1199- 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-213-000 Award Period: June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that District management and financial personnel have internal controls designed to ensure proper documentation of eligibility for Child Nutrition. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will continue to work at ensuring there is a second person to review applications. Name of the Contact Person Responsible for Corrective Action Plan: Justin Dahlheimer, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2024

View Audit 4115

Finding 2396 (2023-001)

Significant Deficiency 2023

Holy Rosary Senior Residence Inc.

NJ

HUD Housing Programs

Significant Deficiency - Failure to Provide Support For Cash Disbursement Corrective Action Plan: Management will ensure that all expenditures can be supported by approved invoices, bills or other supporting documentation. Anticipated Completion date: October 2, 2023 Responsible Person: John Wes...

Significant Deficiency - Failure to Provide Support For Cash Disbursement Corrective Action Plan: Management will ensure that all expenditures can be supported by approved invoices, bills or other supporting documentation. Anticipated Completion date: October 2, 2023 Responsible Person: John Westervelt, President

View Audit 4107

Finding 2395 (2023-002)

Significant Deficiency 2023

Amarillo Independent School District

TX

Reporting

Additional monitoring and comprehensive review of expenditure reporting will take place, with emphasis on matching accounting data presented in the District’s financial system.

View Audit 4100

Finding 2394 (2023-001)

Significant Deficiency 2023

Amarillo Independent School District

TX

Procurement, Suspension & Debarment Cash Management Subrecipient Monitoring § 200.305

The District will implement additional monitoring on cash advances with federal funds to ensure compliance with cash management procedures as referenced in 2 CFR 200.305.

View Audit 4100

Finding 2393 (2023-001)

None 2023

Rock Valley College

IL

Student Financial Aid Eligibility Internal Control / Segregation of Duties

2023-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty had was not disbursed the correct Pell Grant...

2023-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty had was not disbursed the correct Pell Grant award. Based on the student’s enrollment status and need, the College under awarded the student by $200. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: Run enhanced quality assurance (QA) checks with awarding analysis both prior to disbursement of funds and at the end of each semester. Execute 100% QA procedures to ensure accurate system awarding. Responsible Person for Corrective Action Plan: Mary Cobb, Program Manager Financial Aid, and Ana Mirnic, Program Manager Financial Aid, and Executive Director of Financial Aid (new hire in process) Implementation Date of Corrective Action Plan: September 1, 2023

View Audit 4094

Finding 2392 (2023-001)

Significant Deficiency 2023

Union County School District

SC

Questioned Costs Allowable Costs / Cost Principles

Client Response: The Finance Director has already met with many of the various program leaders within the District to ensure they understand and grasp the concept of indirect cost calculations. They have also shared with them the excluded expenditure listing again to re-emphasize the need to accur...

Client Response: The Finance Director has already met with many of the various program leaders within the District to ensure they understand and grasp the concept of indirect cost calculations. They have also shared with them the excluded expenditure listing again to re-emphasize the need to accurately budget for indirect cost. The District has also looked into the potential to reduce its reliance on indirect cost and increase its direct spending from grants. For the finding above, the Finance Director will serve as the primary contact person for district compliance effort. The District has an estimated completion date of November 2023 as the District has already corrected the finding and resolved any noncompliance, if any, moving forward related to the above listed finding.

View Audit 4087 Questioned Costs: $1

Finding 2391 (2023-001)

Significant Deficiency 2023

Titusville Senior Housing Corporation

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and ...

Views of Responsible Officials and Planned Corrective Actions: Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Department prior to submission.

View Audit 4086

Finding 2390 (2023-001)

Significant Deficiency 2023

Lutheran Housing Corporation of Oil City, Inc.

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Depa...

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Department prior to submission.

View Audit 4085

Finding 2389 (2023-001)

Significant Deficiency 2023

Girard Lutheran Housing Corporation

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Depa...

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Department prior to submission.

View Audit 4083

Finding 2388 (2023-001)

Significant Deficiency 2023

Chippewa Lutheran Housing Corporation

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Depa...

Managements acknowledges this finding and is taking steps to correct. Management has counseled HUD building management on the need for timely submissions of proposed budgets and contract completion. A master schedule has been set up and all budget submissions will now be reviewed by the Finance Department prior to submission.

View Audit 4082

Finding 2387 (2023-002)

Significant Deficiency 2023

Asbury University

KY

Student Financial Aid Eligibility Special Tests & Provisions

Asbury University's Financial Aid office has had a turnover in positions. Submitting a disbursement date adjustment file for TEACH Grant disbursements was missed in training Dawn Hopkins the new Financial Aid Specialist. Leslie Kurtz (Director of Financial Aid) has shown Ms. Hopkins how to create an...

Asbury University's Financial Aid office has had a turnover in positions. Submitting a disbursement date adjustment file for TEACH Grant disbursements was missed in training Dawn Hopkins the new Financial Aid Specialist. Leslie Kurtz (Director of Financial Aid) has shown Ms. Hopkins how to create and transmit a TEACH Grant adjustment file to COD. Ms. Hopkins sent a file to correct the 22-23 disbursement dates on July 14, 2023. Ms. Hopkins also updated her desk manual on July 14, 2023, adding the steps to create and submit a disbursement date adjustment file after each TEACH Grant is disbursed to a student's ledger. Leslie Kurtz and Dawn Hopkins have manually reviewed TEACH Grant recipients for the 22-23 at COD to ensure that our ledger and COD are in agreement. On July 14, 2023, Leslie Kurtz modified the receipt that is sent to students to indicate that they have the right to cancel the TEACH Grant by notifying our office.

View Audit 4081

Finding 2379 (2023-002)

Significant Deficiency 2023

East China School District

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval a...

Management will work with various departments to review current policies and procedures related to federal grant awards. We will focus on the related controls necessary to avoid transactions paid in advance that extend passed the expenditure period. Grant procedures will include review, approval and consideration during the grant planning process.

View Audit 4071

Finding 2375 (2023-002)

Material Weakness 2023

Special School District No. 6

MN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.405

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – 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 and Ma...

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – 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 and Material Noncompliance With Federal Allowable Costs Requirements Finding Summary 2 CFR § 200.405 specifies a cost is allocable to a particular federal award if the goods or services involved are chargeable or assignable to that federal award in accordance with relative benefits received. This standard is met if: the cost is incurred specifically for the award, the cost can be distributed in proportions that may be approximated using reasonable methods, and if the cost is necessary to the overall operation of the District and is assignable in part to the federal award in accordance with the principles in 2 CFR 200 Subpart E – Cost Principles. During our audit, we noted that the District did not have adequate internal controls in place to ensure all salary costs charged to the federal special education cluster program met the standard for an allowable or allocable cost as defined by the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allowable costs standards, which resulted in a reportable instance of noncompliance. Corrective Action Plan Actions Planned – The District’s Finance Director, along with special education staff, will review all salaries and benefits being charged to the special education cluster in fiscal 2024 to ensure that adequate time and effort documentation will be maintained for all salaries charged to the program so only allowable costs are being claimed for federal reimbursement. The District will also review its policies and procedures relating to allowable costs for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – Brady Hoffman, Finance Director. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Brady Hoffman, Finance Director, will monitor implementation of the corrective action plan to ensure compliance with the Uniform Guidance in the future.

View Audit 4067 Questioned Costs: $1

Finding 2361 (2023-001)

Significant Deficiency 2023

Gwinnett Christian Terrace LLC

GA

Questioned Costs HUD Housing Programs

Thesecurity deposit account was not fully funded until August of 2023. At June 30, 2023, the resident security deposit account did not equal or exceed the deposits collected from residents by $17725. (1) Comments on the Finding and Each Recommendation - The Company agrees with the finding and recomm...

Thesecurity deposit account was not fully funded until August of 2023. At June 30, 2023, the resident security deposit account did not equal or exceed the deposits collected from residents by $17725. (1) Comments on the Finding and Each Recommendation - The Company agrees with the finding and recommendation.; (2) Actions Taken on the Finding - The Company transferred $20000 to the security deposit account and will closely monitor the liability to ensure that the asset account is adequately funded. No further action required.

View Audit 4061 Questioned Costs: $1

Finding 2347 (2023-001)

Material Weakness 2023

Independent School District No. 12

MN

Procurement, Suspension & Debarment § 200.318

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – 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 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THRO...

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – 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 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Finding Summary 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the special education cluster and coronavirus state and local fiscal recovery funds federal programs. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds federal programs to ensure compliance with federal procurement requirements related to methods of procurement and 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 is in the process of reviewing and updating its policies and procedures relating to procurement, suspension, and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to methods of procurement and maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Patrick Chaffey. Planned Completion Date – December 31, 2023. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Patrick Chaffey, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, suspension, and debarment requirements.

View Audit 4027

Finding 2342 (2023-001)

Significant Deficiency 2023

Catholic Charities

NM

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Corrective action plan: Catholic Charities will begin completing a standard checklist to ensure all client files have been completed by case managers. These checklists will then be reviewed by the Center's Lead Case Managers and Director prior to submission of any check requests. This review include...

Corrective action plan: Catholic Charities will begin completing a standard checklist to ensure all client files have been completed by case managers. These checklists will then be reviewed by the Center's Lead Case Managers and Director prior to submission of any check requests. This review includes a review of the client leases as well as rent reasonableness documentation. Personnel responsible for corrective action: Linda Zamora (Director of the Center for Self Sufficiency and Housing Assistance), Andy Najar (Associate Director), Annabelle Perez (Case Manager II/Landlord Engagement Specialist), Santana Leyba (Case Manager II), and Barney Sanchez, Carla Bustillos, Jessica Montoya, Rudolfo Carrillo (Case Managers). Estimated corrective action completion date: September 8, 2023

View Audit 4022 Questioned Costs: $1

Finding 2341 (2023-001)

Significant Deficiency 2023

Claremont Lincoln University

CA

Student Financial Aid Reporting Significant Deficiency

Management’s Corrective Action Plan Finding 2023-001 Special Tests and Provisions- Enrollment Reporting- Significant Deficiency in Internal Control over Compliance. Responsible Office and Individuals The Associate Vice President of Student Financial Services, Jazmin Martin and the Executive Vice Pre...

Management’s Corrective Action Plan Finding 2023-001 Special Tests and Provisions- Enrollment Reporting- Significant Deficiency in Internal Control over Compliance. Responsible Office and Individuals The Associate Vice President of Student Financial Services, Jazmin Martin and the Executive Vice President/Chief Operations Officer, Mark Mendoza are responsible for the development of the processes, and implementation of the corrective actions described in the Corrective Action Plan. The corrective actions will result in timely and accurate reporting to NSLDS. Corrective Action Plan Management accepts responsibility for this significant deficiency in internal control over compliance and has implemented a new financial aid management system (Campus Ivy) and process to ensure that students’ statuses are reported timely. To maintain accuracy and compliance with the Title IV regulations, Campus Ivy will perform weekly, monthly, and bi-monthly National Student Loan Data System (NSLDS) enrollment reporting. Enrollment reporting is a process by which a student’s enrollment status and program of study is reported to NSLDS on a timely basis to meet the U.S. Department of Education’s 30-day and 60-day reporting requirements. The Student Financial Services Department will provide accurate and timely information to Campus Ivy and Campus Ivy will report that information timely and accurately to NSLDS. Campus Ivy’s Core system receives the NSLDS Enrollment Roster as scheduled on the 5th of the month every 60-days. The Core system will automatically load the roster and update all relevant enrollment data based on the information sent from CLU through the secure data import on an ongoing basis. These updates are then batched by the system to be transmitted to NSLDS. The Student Financial Services Department, through the student information system (Maestro), will provide student information updates. The Student Financial Services Department will sync updates to the Campus Ivy Core Financial Aid Management System (Core) with all students’ academic and demographic information from Maestro, by imports through Campus Ivy’s secure encrypted portal or through direct integration. The Student Financial Services Department will be responsible for timely and accurate updates of the Core system. The Student Financial Services Department will ensure daily updates from Maestro to clear any failed validations. The student data import process has built in validations to assist CLU with maintaining accurate data. These validations are on both the student’s demographic and academic information. In addition to the bi-monthly roster process, Campus Ivy also sends bi-weekly updates to NSLDS to record enrollment updates on an ongoing basis, well within the 30-day timeframe set by the Department of Education. The NSLDS module within Campus Ivy stores all roster batches processed by the system. CLU will have access to view our Roster Batches at any time and can request changes through our 24/7 Support Site. Anticipated Completion Date The anticipated completion date of the corrective action plan is November 30, 2023

View Audit 4011

Finding 2340 (2023-003)

Significant Deficiency 2023

Antelope County

NE

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

Antelope County will complete the annual expenditure report as required by ARPA Funding.

View Audit 4002

Finding 2339 (2023-002)

Significant Deficiency 2023

Antelope County

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

It will be the practice of Antelope County to check vendor status with the SAMS/DUNS before any payments are made utilizing Federal funds. To further insure the funds are safely being utilized and spent, regular checks on the vendor status will be completed.

View Audit 4002

Finding 2326 (2023-002)

Significant Deficiency 2023

Marquette Area Public Schools

MI

Allowable Costs / Cost Principles Reporting § 200.430

The School District recognizes the issue identified during the audit and has made all necessary adjustments to ensure compliance with spending down the remaining ESSER III funding.

View Audit 3993

Finding 2325 (2023-003)

Significant Deficiency 2023

Holt County

NE

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

Holt County will create a spreadsheet that will track expenditures and obligations.

View Audit 3982

Finding 2324 (2023-002)

Significant Deficiency 2023

Holt County

NE

Procurement, Suspension & Debarment § 200.214 § 200.303

Holt County's first choice will be to obtain a certificate or an agreement with each entity stating they are in good standing.

View Audit 3982

Finding 2319 (2023-002)

Material Weakness 2023

Harrison County Community Hospital District

MO

Questioned Costs Material Weakness Reporting

Identification: 93.498 United States Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution; Noncompliance Finding/Material Weakness; Activities Allowed Compliance Requirement. Corrective Action Plan: The Hospital District will make improvements to ...

Identification: 93.498 United States Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution; Noncompliance Finding/Material Weakness; Activities Allowed Compliance Requirement. Corrective Action Plan: The Hospital District will make improvements to its procedures over federal grant reporting to ensure that future reporting submissions do not contain duplicated expenditures. Anticipated completion date: The Hospital District will implement improvements to its procedures over federal grant reporting beginning in FY 2024.

View Audit 3969 Questioned Costs: $1

Finding 2311 (2023-002)

Significant Deficiency 2023

Crete Public Schools No 2

NE

Internal Control / Segregation of Duties

The Crete Public Schools Board of Education and Superintendent continually evaluate the distribution of duties to employees and closely monitor finances. The Chief Financial Officer will work to separate duties to the best of the ability with the staff on hand. The addition of a Director of Federa...

The Crete Public Schools Board of Education and Superintendent continually evaluate the distribution of duties to employees and closely monitor finances. The Chief Financial Officer will work to separate duties to the best of the ability with the staff on hand. The addition of a Director of Federal Programs who will be responsible for compliance and monitoring will allow further segregation of duties. The Director of Federal Programs will regularly run reports to ensure the accuracy of transactions and that the expenses comply with grant funding. The Superintendent and the Chief Financial Officer will work together to determine the staffing needs in the business office. There will be consideration for additional staffing as the budget allows for it.

View Audit 3960

Finding 2310 (2023-001)

Material Weakness 2023

The Towers LLC

MN

Questioned Costs HUD Housing Programs

2023-001 - Management Fees Name of contact person - Vicky Dwyer, CFO, Great Lakes Management Company Corrective action - Management began the process of requesting these changes from HUD prior to when the changes went into effect, working through the mortgage company. However, due to turnover at t...

2023-001 - Management Fees Name of contact person - Vicky Dwyer, CFO, Great Lakes Management Company Corrective action - Management began the process of requesting these changes from HUD prior to when the changes went into effect, working through the mortgage company. However, due to turnover at the mortgage company, the request for approval by HUD was never sent to HUD. As a result, management is now currently in the process of working with HUD and the mortgage company to obtain all necessary approvals. Proposed completion date - Management has put in the necessary requests with HUD and the mortgage company to receive the necessary approvals, and the finding will be corrected once HUD has issued its approval or other response to management.

View Audit 3955 Questioned Costs: $1

Corrective Action Plans

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