Corrective Action Plans

Finding 41533 (2022-001)

Material Weakness 2022

VA

Questioned Costs Allowable Costs / Cost Principles

2022-001-Material Weakness and Compliance Qualification -Allowable Costs (Repeat Finding -See Finding 2021-001) Program: Education Stabilization Fund -Elementary and Secondary Schools Emergency Relief ("ESSER") Fund (ALN 84.4250 and 84.425U) -United States Department of Education -Virgin...

2022-001-Material Weakness and Compliance Qualification -Allowable Costs (Repeat Finding -See Finding 2021-001) Program: Education Stabilization Fund -Elementary and Secondary Schools Emergency Relief ("ESSER") Fund (ALN 84.4250 and 84.425U) -United States Department of Education -Virginia Department of Education; Grant Award Number: S4250200008; Federal Award Year: 2020) Responsible Officials: John Wack, Chief Financial Officer, Henrico County Public Schools Planned Corrective Action: The noted lack of time certifications was not consistent with policy, primarily occurring with substitute staff positions during School Year 2021-2022 and during the second year of the pandemic where classroom instructional roles were transitioning. The national health emergency is temporary and so are the accommodations to it that resulted in this deficiency. Payroll staff will reinforce the importance of timesheet approvals by temporary employees and their supervisors prior to semi-monthly processing, including through an organization-wide communication to principals and management staff. Expected Completion Date: January 31, 2023

View Audit 39118 Questioned Costs: $1

Finding 41532 (2022-003)

Significant Deficiency 2022

Isd #317 - Deer River

MN

Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District Office will ensure proper supporting documentation is obtained prior to all future disbursements. 3. Official Respon...

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District Office will ensure proper supporting documentation is obtained prior to all future disbursements. 3. Official Responsible for Ensuring CAP Pat Rendle, Superintendent, is the official responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2023. 5. Plan to Monitor Completion of CAP The Board of Directors will be monitoring this CAP.

View Audit 40700

Finding 41522 (2022-003)

Significant Deficiency 2022

Dodge County Housing Authority

WI

Subrecipient Monitoring Reporting

FINDING 2022-3 Preparation of Schedule of Federal Expenditures (design deficiency) Recommendation: The Housing Authority should assign an individual internally that is qualified to prepare the Schedule of Federal Expenditures. Action Taken: Effective immediately the Executive Director will continu...

FINDING 2022-3 Preparation of Schedule of Federal Expenditures (design deficiency) Recommendation: The Housing Authority should assign an individual internally that is qualified to prepare the Schedule of Federal Expenditures. Action Taken: Effective immediately the Executive Director will continue to work to assume this responsibility to ensure this is prepared accurately. Anticipated resolution with future submissions.

View Audit 39535

Finding 41515 (2022-002)

Significant Deficiency 2022

Dodge County Housing Authority

WI

Internal Control / Segregation of Duties

FINDING 2022-002 Segregation of Duties (design deficiency) Recommendation: We recommend that the Housing Authority's board and management be aware of the lack of segregation of duties of the accounting functions and, where possible, implement oversight procedures to ensure that the internal control...

FINDING 2022-002 Segregation of Duties (design deficiency) Recommendation: We recommend that the Housing Authority's board and management be aware of the lack of segregation of duties of the accounting functions and, where possible, implement oversight procedures to ensure that the internal control policies and procedures are being implemented by staff to the extent possible. Action Taken: Dodge County Housing has a system of internal controls that is reviewed and updated annually. Duties arc segregated within the staff members to ensure that no one individual handles a transaction from inception to completion. Board Commissioners are aware of the limitations and participate in reviewing purchases and payments in addition to monitoring budgets and monthly financials. We will continue to segregate duties whenever possible and implement procedures to incorporate the above recommendation throughout the year and monitor, update or change internal controls and procedures as necessary. This action is continually monitored with an annual review of internal controls in place as of the date of this letter. Duties were further segregated with additional staff hired September 2022.

View Audit 39535

Finding 41514 (2022-001)

Significant Deficiency 2022

Dodge County Housing Authority

WI

Reporting Internal Control / Segregation of Duties

FINDING 2022-001 Weakness regarding preparing financial statements (design deficiency) Recommendation: It is not cost effective for the Housing Authority to employ additional personnel solely for financial reporting purposes. Therefore, the Housing Authority should use its current knowledge obtaine...

FINDING 2022-001 Weakness regarding preparing financial statements (design deficiency) Recommendation: It is not cost effective for the Housing Authority to employ additional personnel solely for financial reporting purposes. Therefore, the Housing Authority should use its current knowledge obtained from training seminars and trade associations to mitigate the situation. Action Taken: We continue to implement procedures to incorporate the above recommendation throughout the year to take advantage of training and information as available. The Executive Director has taken more responsibility to reduce the reliance on the audit firm. Discussion and review of any auditor entries are reviewed prior to the audit submission. The Board of Commissioners will continue to monitor this situation and may attempt to fill future board positions with a member who has expertise to contribute to the review of financials or consider contracting an accounting firm to assist in preparation.

View Audit 39535

Finding 41512 (2022-001)

Material Weakness 2022

Western Indiana Community Action Agency, Inc.

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

Corrective Action Plan for Current Year Findings Finding 2022-001: Timely Processing of Participant Applications: Department of Health and Human Services - AL #93.568 Low Income Home Energy Assistance Program #Ll-023-024, #Ll-022-024 Corrective Action: WICAA has developed a streamlined approach...

Corrective Action Plan for Current Year Findings Finding 2022-001: Timely Processing of Participant Applications: Department of Health and Human Services - AL #93.568 Low Income Home Energy Assistance Program #Ll-023-024, #Ll-022-024 Corrective Action: WICAA has developed a streamlined approach for assessing incoming applications, differentiating between complete and incomplete applications at the beginning of the processing cycle. This will ensure that complete applications can be promptly processed. Additionally, if a substantial number of unprocessed applications are nearing 10 days of the deadline for processing, our staff will be notified that there is a need for overtime. Overtime requirements will be assessed weekly. These modifications are anticipated to result in applications being processed within the allowable number of days. Person Responsible: The Energy Assistance Director has primary responsibility with oversight by the Executive Director. Timing for Implementation: Immediately; Carole Barr, Executive Director; Debbie Kearschner, Finance Director

View Audit 39954

Finding 41511 (2022-003)

Significant Deficiency 2022

Mahnomen County

MN

Procurement, Suspension & Debarment § 200.318 § 200.326

2022-003 FINDING Contact Person ? CJ Holl, County Administrator Corrective Action Plan ? The County will implement procedures to ensure that federal procurement standards are followed for federal grant purchases. Completion Date ? Ongoing

View Audit 38524

Finding 41510 (2022-002)

Significant Deficiency 2022

Mahnomen County

MN

Reporting

2022-002 FINDING Contact Person ? CJ Holl, County Administrator Corrective Action Plan ? The County will implement procedures to ensure that reports are completed accurately, including ensuring reports match the supporting accounting records. Completion Date ? 9/30/2023

View Audit 38524

Finding 41508 (2022-003)

Material Weakness 2022

Community School of Excellence

MN

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment

2022-003 Material Weakness in Internal Control over Compliance Recommendation: We recommend that the School properly list the source of funding, the percentage of federal participation on the cost, and the cost in equipment inventory listings. Explanation of disagreement with audit finding: There is...

2022-003 Material Weakness in Internal Control over Compliance Recommendation: We recommend that the School properly list the source of funding, the percentage of federal participation on the cost, and the cost in equipment inventory listings. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSE will segregate federally funded equipment and document its cost. Names of the contact persons responsible for corrective action: CSE School Leadership Planned Completion date for corrective action plan: 6/30/2023

View Audit 38656 Questioned Costs: $1

Finding 41507 (2022-002)

Significant Deficiency 2022

Klamath Watershed Partnership

OR

Reporting § 200.328

Management will perform a review with supporting information in future filings. Also, management will amend the identified reports.

View Audit 38520

Finding 41506 (2022-001)

Significant Deficiency 2022

Klamath Watershed Partnership

OR

Procurement, Suspension & Debarment § 200.318 § 200.327

Management has updated their procurement policy to align with the requirements of 2 CFR 200.318

View Audit 38520

Finding 41505 (2022-001)

Significant Deficiency 2022

Infectious Diseases Society of America

VA

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

Department of Health and Human Services 2022-001 Protecting and Improving Health Globally ? Assistance Listing No. 93.318 Recommendation: We recommend IDSA implement procedures to ensuring costs are allowable and time is allocated properly to the grant. Explanation of disagreement with audit findin...

Department of Health and Human Services 2022-001 Protecting and Improving Health Globally ? Assistance Listing No. 93.318 Recommendation: We recommend IDSA implement procedures to ensuring costs are allowable and time is allocated properly to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Out of approximately 30 employees billing to the CDC grant, the audit review uncovered two errors in our calculation of billable payroll. ? An employee received a pay increase outside of our normal annual raise process, due to a promotion. We did not pick up the higher pay rate, and therefore, undercharged the grant for the final six months of the grant that ended on September 29, 2022. The salary was corrected for the calculations of the new grant year that began on September 30, 2022. ? An employee received vacation pay as part of her final paycheck, when she left IDSA. We incorrectly billed CDC for the pro-rated portion of the vacation pay. The net of these two errors was an undercharge to the CDC grant billing of $549. Planned completion date for corrective action plan: N/A - we believe that our policies and review are adequate to insure accurate billings to the grant. Name of the contact person responsible for corrective action: Barton Groh, Vice President of Finance & Administration If the Department of Health and Human Services has questions regarding this plan, please call Barton Groh, Vice President of Finance & Administration at 703-299-0108.

View Audit 38593

Finding 41499 (2022-001)

Material Weakness 2022

Central Greene School District

PA

Questioned Costs Procurement, Suspension & Debarment

We were under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program (COSTAR) satisfied compliance of quote/bid requirements of federal purchases. We will follow our policy for federal purchases subject to quotation/bid requirements moving f...

We were under the false notion that purchases made through the Commonwealth of Pennsylvania?s cooperative purchasing program (COSTAR) satisfied compliance of quote/bid requirements of federal purchases. We will follow our policy for federal purchases subject to quotation/bid requirements moving forward. When federal money is used to purchase through a cooperative purchasing programs, we will obtain advertisement, and document quote/bid information relating to the purchase. We will document the ?reason? and ?cost analysis? of purchases that meet sole source criteria.

View Audit 38430 Questioned Costs: $1

Finding 41498 (2022-002)

Material Weakness 2022

Lighthouse Social Service Centers

CA

Subrecipient Monitoring Cash Management Material Weakness § 200.1 § 200.303

Finding 2022-002 The Corrective Action Plan (CAP) is designed to address audit recommendations related to revenue recognition, timely grant claims submission, and monthly expenditure reconciliation. To enhance revenue recognition, the Finance Department will review and update existing accounting pro...

Finding 2022-002 The Corrective Action Plan (CAP) is designed to address audit recommendations related to revenue recognition, timely grant claims submission, and monthly expenditure reconciliation. To enhance revenue recognition, the Finance Department will review and update existing accounting procedures, provide clearer guidelines, and conduct staff training. The timely submission of grant claims will be ensured through a monitoring mechanism, reporting structure, and an escalation process. Monthly reconciliation of revenue to expenditures will be established, with management reviewing and taking corrective actions as needed. Progress will be closely monitored and reported, with the goal of implementing these improvements immediately, involving the Finance Department, Grants Management Team, and relevant management personnel.

View Audit 38289

Finding 41497 (2022-003)

Significant Deficiency 2022

Columbia College Dba Columbia College Hollywood

CA

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

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent ...

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent to the prior employee, who by that time was no longer with the college. The new individual did not see the notice and was not aware that a refund calculation was required. There was a brief window when all notifications were switched to the new staff member, and this particular status change was processed during that transition. The refund has now been processed and all unearned aid for the term has been returned. We have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

View Audit 38278

Finding 41496 (2022-002)

Significant Deficiency 2022

Columbia College Dba Columbia College Hollywood

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

The institution does not dispute the finding. This was an isolated incident and no further instances of this nature occurred. There was a delay in processing the refund as the R2T4 was completed just before our holiday break. The staff member that handles the return in COD would have completed it up...

The institution does not dispute the finding. This was an isolated incident and no further instances of this nature occurred. There was a delay in processing the refund as the R2T4 was completed just before our holiday break. The staff member that handles the return in COD would have completed it upon return to the office in early January but then she was out of the office for longer than anticipated due to symptoms resulting from a positive diagnosis of Covid. Upon her return, she completed the refund and it posted to the ledger 19 days late. Each position within the department has now been cross trained so that any one staff member's extended absence does not impact the operation and our ability to maintain regulatory compliance. This finding as reviewed with all staff members in the department to ensure compliance moving forward.

View Audit 38278

Finding 41495 (2022-001)

Significant Deficiency 2022

Columbia College Dba Columbia College Hollywood

CA

Questioned Costs Student Financial Aid Eligibility

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent...

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

View Audit 38278 Questioned Costs: $1

Finding 41494 (2022-002)

None 2022

Ryder Assisted Care Iii, Inc.

PR

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

2022-2 Residual Receipt The budget of managing agent is limited so the recommendation of more employees cannot be assumed at this time, however management will be evaluating functions performed by the accountant Person in charge will be the Project Administrator and Mr. Jose Feliciano Executive Dire...

2022-2 Residual Receipt The budget of managing agent is limited so the recommendation of more employees cannot be assumed at this time, however management will be evaluating functions performed by the accountant Person in charge will be the Project Administrator and Mr. Jose Feliciano Executive Director of the Management Agent.

View Audit 38265

Finding 41493 (2022-001)

None 2022

Ryder Assisted Care Iii, Inc.

PR

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 day...

Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 days of the invoice was received.

View Audit 38265

Finding 41491 (2022-001)

Significant Deficiency 2022

St. Timothy Manor, Inc.

OH

Questioned Costs Internal Control / Segregation of Duties Reporting

CORRECTIVE ACTION PLAN September 29, 2022 U.S. Department of Housing and Urban Development St. Timothy Manor, Inc. respectively submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: HW&Co. 23240 Chagrin Blvd, Suite ...

CORRECTIVE ACTION PLAN September 29, 2022 U.S. Department of Housing and Urban Development St. Timothy Manor, Inc. respectively submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: HW&Co. 23240 Chagrin Blvd, Suite 700 Cleveland, OH 44122-5450 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT AND FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Supportive Housing for the Elderly ? CFDA #14.157 Recommendation: St. Timothy Manor, Inc. should deposit underfunded amount into the replacement reserve account. Action Taken: St. Timothy Manor, Inc. agrees with the recommendation. Management has corrected all items and completed the deposit into the replacement reserve account on September 29, 2022. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Fred Berry at 330-384-1555

View Audit 37662 Questioned Costs: $1

Finding 41479 (2022-005)

Material Weakness 2022

Safe and Sound

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

2022-005 ? Reporting Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Due to staff transition from those who managed the federal grant, the documented controls and timely reporting were missed. Safe & Sound?s Finance team implemented policies and proce...

2022-005 ? Reporting Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Due to staff transition from those who managed the federal grant, the documented controls and timely reporting were missed. Safe & Sound?s Finance team implemented policies and procedures to ensure the timely preparation, review, and approval of FFATA reporting. Date Completed: 8/31/2023

View Audit 37696

Finding 41478 (2022-004)

Significant Deficiency 2022

Safe and Sound

CA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.1 § 200.303 § 200.403 § 200.414

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified t...

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023

View Audit 37696

Finding 41477 (2022-003)

Material Weakness 2022

Safe and Sound

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403 § 200.430 § 200.431 § 200.447

2022-003 ? Allowable Costs/Activities Allowed or Unallowed: Fringe Benefits and Shared Costs Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer Corrective Action: During the initial year of receiving our first direct federal grant, Safe & Sound calculated fringe benefits bas...

2022-003 ? Allowable Costs/Activities Allowed or Unallowed: Fringe Benefits and Shared Costs Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer Corrective Action: During the initial year of receiving our first direct federal grant, Safe & Sound calculated fringe benefits based on a percentage of the salaries allocated to the grant. Salaries were calculated based on time and effort. Safe & Sound has reviewed the current practices related to allocating fringe benefits and shared costs. Safe & Sound?s Finance team reviewed and verified that we have the adequate fringe benefit and shared costs to meet the costs allocated to this grant. To ensure we have the proper supporting documentation to meet the Uniform Guidance requirements in 2 CFR Sections 200.303 and 200.403, we will implement time and effort documentation for benefit and shared cost allocations on a monthly basis and will review for any necessary budget to actual adjustments. Date Completed: 8/31/2023

View Audit 37696 Questioned Costs: $1

Finding 41476 (2022-001)

Significant Deficiency 2022

Centenary College of Louisiana

LA

Questioned Costs Procurement, Suspension & Debarment § 200.320

To: Sara E. Grenier, CPA Subject: Audit Finding 2022-001 COVID-19 - Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 The purpose of this memo is to respond to the FY22 Audit finding referenced in the subject matter. The auditors found th...

To: Sara E. Grenier, CPA Subject: Audit Finding 2022-001 COVID-19 - Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 The purpose of this memo is to respond to the FY22 Audit finding referenced in the subject matter. The auditors found that "The College did not follow their procurement policy for expenses charged to federal awards" and recommended "Management should review contracts being charged to the federal grants to ensure they have followed their procurement policy." The College concurs with the finding and recommendation and will review contracts supported by federal grants to ensure they meet institutional and Federal Guidelines. The College will also review our current procurement policies and make any adjustments that may be necessary. The estimated completion date to review contracts of this nature let between July 2022-October 2022 is no later than December 31, 2022. The action officer for this review is Robert S. Blue, Vice President for Finance and Administration & CFO.

View Audit 37735 Questioned Costs: $1

Finding 41467 (2022-003)

Material Weakness 2022

Tri-Creek School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity:...

Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Context: The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, and Earmarking compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The lack of internal controls and noncompliance was isolated to the 19611-045-PN01 and 20611-045-PNO1 grant awards. The Non-Public Proportionate Share expenditures for the 19611-045-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools ona percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirement for the 19611-045-PNO1 grant award was $6,228. The Non-Public Proportionate Share expenditures for the 20611-045-PN01 and 21611-045-PNO1 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required.Views of Responsible Officials and Planned Corrective Actions: The district agrees with the finding and notes as a member of the Northwest Indiana Special Education Cooperative (NISEC), Tri-Creek School Corporation reported their proportionate share based on a percentage of expenditures and had successful audits in doing so. When the Tri-Creek School Corporation was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included a detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee's detailed time and effort report is then provided to the NISEC finance department for a second review and signature before being provided to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B grant in the payroll system bi-weekly based on the time and effort report pertinent to just Tri-Creek Non-Public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Tri Creek?s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Tri-Creek?s proportionate share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is submitted to the Department of Education. Responsible party and timeline for completion: Responsible parties: Lisa Rosinko, Northwest Indiana Special Education Cooperative Chief Financial Officer Anticipated Completion Date: The Northwest Indiana Special Education Cooperative discontinued reporting nonpublic proportionate share expenditures by percentage as of the 2022-2023 school year. An internal control procedure to report nonpublic proportionate share expenditures by detailed time and effort work and expenditures was implemented as of the 2022-2023 school year.

View Audit 37708

Corrective Action Plans

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