Corrective Action Plans

Finding 38196 (2022-001)

Material Weakness 2022

The Harry and Jeanette Weinberg Terrace, Inc.

MD

Eligibility HUD Housing Programs Subrecipient Monitoring

Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well ...

Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. We have implanted new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.

View Audit 32236

Finding 38195 (2022-002)

Material Weakness 2022

The Harry and Jeanette Weinberg Terrace, Inc.

MD

HUD Housing Programs Cash Management Internal Control / Segregation of Duties

Finding 2022-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding The Residual Receipts deposit was not made timely due to a turnover in staff. Management has trained all accounting staff on this process and the Contr...

Finding 2022-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding The Residual Receipts deposit was not made timely due to a turnover in staff. Management has trained all accounting staff on this process and the Controller has implemented tracking procedures to insure timely deposits.

View Audit 32236

Finding 38193 (2022-001)

Significant Deficiency 2022

Logan County School District

KY

Questioned Costs Allowable Costs / Cost Principles § 200.303

IN REGARDS TO COVID-19 EDUCATION STABILIZATION FUND -- ASSISTANCE LISTING NO. 84.425; GRANT PERIOD -- YEAR ENDED JUNE 30, 2022 THE DISTRICT WILL PUT MEASURES IN PLACE TO ENSURE THAT ALLOWABLE COSTS ARE CHARGED TO THE GRANT. THE ANTICIPATED COMPLETION DATE OF THESE ACTIONS IS NOVEMBER 14, 2022 WITH K...

IN REGARDS TO COVID-19 EDUCATION STABILIZATION FUND -- ASSISTANCE LISTING NO. 84.425; GRANT PERIOD -- YEAR ENDED JUNE 30, 2022 THE DISTRICT WILL PUT MEASURES IN PLACE TO ENSURE THAT ALLOWABLE COSTS ARE CHARGED TO THE GRANT. THE ANTICIPATED COMPLETION DATE OF THESE ACTIONS IS NOVEMBER 14, 2022 WITH KARLA PADDOCK THE RESPONSIBILE PERSON FOR IMPLEMENTATION.

View Audit 31205 Questioned Costs: $1

Finding 38189 (2022-001)

Significant Deficiency 2022

Cuba City School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Eligibility

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the...

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

View Audit 30666

Finding 38174 (2022-002)

Significant Deficiency 2022

The School District of Kansas City, Missouri

MO

Subrecipient Monitoring School Nutrition Programs Special Tests & Provisions

Identifying Number: 2022-002 Finding: In our sample of ten schools, Kansas City Public Schools (the District) obtained the requisite two food safety inspections at each school during the school year; however the food safety inspection reports identified critical violations at four schools, which w...

Identifying Number: 2022-002 Finding: In our sample of ten schools, Kansas City Public Schools (the District) obtained the requisite two food safety inspections at each school during the school year; however the food safety inspection reports identified critical violations at four schools, which were not corrected by a specified date. The District did not comply with food storage, preparation, and service standards established by the KCMO Health Department. Corrective Actions Taken or Planned: The Child Nutrition Services Department and the Facilities Departments will perform training with staff regarding the Health Department requires to address violations. Procedures will be updated to reflect the responsibilities with CNS staff to report violations, monitor work order progress and escalated resolution to meet Health Department deadlines. The CNS Director will contact the Health Department to provide documentation the violation has been corrected. The corrective action plan has been implemented. The contact person responsible for the corrective action plan is Erin Thompson, Interim Chief Finance and Operations Officer.

View Audit 35893

Finding 38173 (2022-003)

Material Weakness 2022

The School District of Kansas City, Missouri

MO

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Identifying Number: 2022-003 Finding: During discussion, observations, and our understanding of internal control, we observed the District followed the State of Missouri's guidelines for construction projects, which states that public works projects valued at $75,000 and under are not subject to...

Identifying Number: 2022-003 Finding: During discussion, observations, and our understanding of internal control, we observed the District followed the State of Missouri's guidelines for construction projects, which states that public works projects valued at $75,000 and under are not subject to prevailing wage regardless of federal funding source. Two of the seven construction contracts paid with federal assistance funds that were below $75,000, but in excess of the applicable $2,000 federal threshold, did not have prevailing wage rate clauses. Question costs - $13,420. Corrective Actions Taken or Planned: The Procurement and Facilities/Operations Department will update procedures and provide additional training of staff of the Davis Bacon Act requirements. The training of staff, updating of procedures is underway, and anticipated to be completed by January 31, 2023. The two vendors have been contacted. The District will collect documentation from the vendors and calculate any differential due. The contact person responsible for the corrective action is Erin Thompson, Interim Chief Finance & Operations Officer. The District will revise Board Policy FEF-2 Construction Contracts Bidding and Awards. The contact person is William Thornton, Chief Legal Officer. It is anticipated to be completed by March 31, 2023.

View Audit 35893 Questioned Costs: $1

Finding 38172 (2022-003)

Material Weakness 2022

The Housing Authority of the City of Aiken, South Carolina

SC

HUD Housing Programs Eligibility Material Weakness

2022-003 - Eligibility ? Tenant Files Section 8 Housing Choice Vouchers ? CFDA Number 14.871 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-005 (Originally reported as finding 2020-005 at 09/30/20) Condition: Out of a total tenant population of approxi...

2022-003 - Eligibility ? Tenant Files Section 8 Housing Choice Vouchers ? CFDA Number 14.871 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-005 (Originally reported as finding 2020-005 at 09/30/20) Condition: Out of a total tenant population of approximately 884 leased vouchers, 25 files were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 error where the lease agreement was not signed by the owner ? 1 error where the file did not contain a signed lease agreement ? 1 error where the file did not contain a signed HAP contract. Also, during our New Admissions testing (11 tested out of 108 new admissions) we noted the following: ? 1 error where the HAP contract was signed but not dated by the Authority. ? 1 error where the lease agreement was not signed by the owner. ? 4 errors where the RFTA was signed but not dated by the landlord and/or by the tenant. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has hired an outside CPA firm to conduct quarterly reviews of files and to assist in training staff on HUD compliance requirements. The noted deficiencies in the tested files are being corrected and staff will continue to receive adequate training involving the compliance of all the Department of Housing Urban Development (HUD) requirements.

View Audit 34476

Finding 38168 (2022-004)

Significant Deficiency 2022

The Housing Authority of the City of Aiken, South Carolina

SC

Internal Control / Segregation of Duties Eligibility HUD Housing Programs

2022-004 - Eligibility ? Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Significant Deficiency in Internal Control, Other Matters Required to be Reported Repeat of 9/30/21 Finding 2021-003 (originally reported at 9/30/19 as Finding 2019-009) Condition: Out of a total tenant po...

2022-004 - Eligibility ? Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Significant Deficiency in Internal Control, Other Matters Required to be Reported Repeat of 9/30/21 Finding 2021-003 (originally reported at 9/30/19 as Finding 2019-009) Condition: Out of a total tenant population of approximately 141 tenants, 15 files were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 tenant file where the tenant?s flat rent was overstated by $4 due to a miscalculation. ? 1 tenant file where the tenant?s flat rent was overstated by $2 due to a miscalculation. ? 1 tenant file where the tenant?s income was miscalculated. Correcting this error caused the tenant?s rent to increase by $6. ? 1 tenant file where the tenant?s income was miscalculated. Correcting this error caused the tenant?s rent to decrease by $63 ? 1 tenant file where the tenant?s General Assistance was coded as wages on the 50058 form. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has hired an outside CPA firm to conduct quarterly reviews of files and to assist in training staff on HUD compliance requirements. The noted deficiencies in the tested files are being corrected. Although this is a repeat finding, the Authority has made great strides in the current fiscal year reducing the error rate by 72% from the prior year. The Authority will continue to improve file reviews and training procedures to ensure the files meet the required guidelines. Effective Date: June 26, 2023 Contact Information Chanosha N.E. Lawton, CEO Housing Authority of the City of Aiken, South Carolina PO Box 889 Aiken, South Carolina 29802 (803) 617-7978

View Audit 34476

Finding 38167 (2022-002)

Material Weakness 2022

The Housing Authority of the City of Aiken, South Carolina

SC

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

2022-002 ? Activities Allowed or Unallowed: Loans to Related Parties Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-002 (Originally reported as finding 2019-005 and 2019-010 at 09/30/19) Condition...

2022-002 ? Activities Allowed or Unallowed: Loans to Related Parties Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-002 (Originally reported as finding 2019-005 and 2019-010 at 09/30/19) Condition: In prior years, the Authority had loaned PIH monies to related parties. As of September 30, 2022, approximately $209,000 of PIH loans remain outstanding to related parties and approximately $127,000 to other programs of the Authority. Recommendation: Management of the Authority should continue to pursue collections of these amounts. Action Taken: The Authority understands and adheres to the federal guidelines to ensure that restricted funds are not advanced to other related parties or programs. Management is actively pursuing collection efforts.

View Audit 34476

Finding 38166 (2022-001)

Material Weakness 2022

The Housing Authority of the City of Aiken, South Carolina

SC

Internal Control / Segregation of Duties Material Weakness Reporting

2022-001 - Inadequate Controls Over Financial Reporting Public and Indian Housing Program ? CFDA 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-001 (originally reported at 9/30/19 as Finding 2019-004) Condition: Our audit identified deficiencies...

2022-001 - Inadequate Controls Over Financial Reporting Public and Indian Housing Program ? CFDA 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-001 (originally reported at 9/30/19 as Finding 2019-004) Condition: Our audit identified deficiencies in the design and/or operation of internal controls that adversely affected the Authority?s ability to produce reliable financial statements. As a result, more than fifty audit adjustments and reclassifications were proposed that resulted in material changes to financial statement amounts as follows: ? Total assets increased by $358,336 ? Total liabilities increased by $227,891 ? Total equity decreased by $257,671 ? Total revenue increased by $81,191 ? Total expenses decreased by $306,925 Recommendation: We recommend the Authority adopt policies and procedures that require timely financial reporting at the end of each month and fiscal year end. The procedures should include a full review of the balances as of the close of the year with reconciliations and workpapers prepared and agreed to supporting information. In order to accomplish this, the Authority should provide additional training to its accounting personnel. During the fiscal year, the Authority was assisted by an independent outside fee accountant with the monthly accounting and the closing of its year-end accounting for the federal programs, but was not involved with the other programs of the Authority. We recommend that the Authority also engage the fee accountant with the other programs of the Authority. Action Taken: During fiscal year 2022, the Authority hired an outside CPA firm to assist with the financial statements for the Public and Indian Housing Program and Section 8 Housing Choice Voucher Program. Although the finding continues in the current year, the Authority has made great strides to clean up the financial statements of the programs mentioned, reducing the material adjustment effect on equity by 61% from the prior period. The Authority will continue to improve efficiency and procedures/workpapers to ensure the year-end closing procedures become more effective and reliable in the coming years.

View Audit 34476

Finding 38150 (2022-001)

None 2022

City of Franklin, Tennessee

TN

Subrecipient Monitoring Reporting

The City of Franklin respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact Person/Persons Responsible for Implementing Corrective Action: Eric Stuckey, City Administrator, 615-791-3217 2022-001: Franklin Transit Authority Program Review Action Taken/Plan...

The City of Franklin respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact Person/Persons Responsible for Implementing Corrective Action: Eric Stuckey, City Administrator, 615-791-3217 2022-001: Franklin Transit Authority Program Review Action Taken/Planned: As recommended, the City of Franklin and the Authority have clarified the federal grant organization as follows: For transit services, the organization is as follows: (1) Recipient: Franklin Transit Authority (2) Contractor (current): The TMA Group For the regional vanpool program, the organization is as follows: (1) Recipient: Franklin Transit Authority (2) Sub-Recipient: Regional Transportation/Williamson County (3) Contractor (current): The TMA Group The Authority has previously and will continue to be reported as part of the City of Franklin in a special revenue fund and includes the Authority?s grants in its single audit. For the fiscal year 2022 audit, the City and the Contractor have coordinated to ensure federal grants for transit services and vanpool services are excluded from the Contractor audit. For fiscal year 2023, the City and the Contractor developed backup needed for oversight of each payment to the Contractor for contracted transit services and grant-related contracted vanpool services. Monthly reporting will clarify financial activities of the recipient (Franklin Transit), subrecipient (Regional Transportation Authority/Williamson County), and contractor (The TMA Group). For capital expenditures that the City and the Authority have ownership, the City will continue to pay the vendor directly. The City of Franklin and the Authority have developed a job description, issued a job posting, and conducted interviews for a part-time Contract Compliance Monitor. The position, the Authority?s only employee, will monitor the activities of the Contractor (currently The TMA Group) and the subrecipient (Williamson County) to ensure that the awards are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the contract or subaward. Based on the amount and level of work required, the position is under direction of the Authority. The monitor essentially functions in a control/compliance role. The position is anticipated to be paid through the City?s payroll process from the Authority fund. Anticipated Completion Date/Date Completed: January 2023

View Audit 29988

Finding 38149 (2022-001)

Significant Deficiency 2022

Springfield Housing Authority

TN

Cash Management HUD Housing Programs

This was an error. Will remember the 3-day window so it does not happen again.Anticipated Completion Date: April 6, 2023 Contact Person: Brandi Claborn Chief Financial Officer 808 Rose Hill Cr. Springfield, TN 37172

View Audit 29784

Finding 38147 (2022-006)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Material Weakness Reporting

Corrective action has been taken consisting in the timely preparation of the bank conciliations. However, the corrective actions needed to evidence the HAP and Administrative Fee equity balances calculation will be taken by the Municipal Finance Office and the Program Accountants. Also, adequate mea...

Corrective action has been taken consisting in the timely preparation of the bank conciliations. However, the corrective actions needed to evidence the HAP and Administrative Fee equity balances calculation will be taken by the Municipal Finance Office and the Program Accountants. Also, adequate measurements addressed to reconcile the VMS with the Financial Data Schedule (FDS) will be taken. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 33033

Finding 38146 (2022-005)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

The Department of Finance and Budget of the Municipality establish a new monitoring procedure for the preparation and authorization of journal entries to each transaction related to assets, liabilities, revenues and expenditures. Also, the Section 8 Program will give financial training to the person...

The Department of Finance and Budget of the Municipality establish a new monitoring procedure for the preparation and authorization of journal entries to each transaction related to assets, liabilities, revenues and expenditures. Also, the Section 8 Program will give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports in order to make sure that the accounting system complies with state and federal laws. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 33033

Finding 38145 (2022-004)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

As indicated to the finding 2022-002, the Municipality uses a mechanized accounting system (SIMA), which is also used by the Section 8 Program. The accounting system contains some reports that provide reliable financial data used to prepare the unaudited REAC Report. The Section 8 Program is taking ...

As indicated to the finding 2022-002, the Municipality uses a mechanized accounting system (SIMA), which is also used by the Section 8 Program. The accounting system contains some reports that provide reliable financial data used to prepare the unaudited REAC Report. The Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. Also, the Central Accounting Department have established a working sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 33033

Finding 38141 (2022-007)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

As indicated for the finding 2022-004, the Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data and audited financial information electronically to HUD. As a part of such measurements, a new accountant has been r...

As indicated for the finding 2022-004, the Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data and audited financial information electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Section 8 Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. The Central Accounting Department have established a work sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 33033

Finding 38139 (2022-008)

Significant Deficiency 2022

Autonomous Municipality of Ponce

PR

Reporting Significant Deficiency Internal Control / Segregation of Duties

The Finance and Budget Department will take the necessaries measurements to achieve that the single audit report of the fiscal year 2022-2023 be submitted to the Federal Audit Clearinghouse in a timely manner. Implementation Date: March 31, 2024 Responsible Persons: Mrs. Damaris Suliveres ...

The Finance and Budget Department will take the necessaries measurements to achieve that the single audit report of the fiscal year 2022-2023 be submitted to the Federal Audit Clearinghouse in a timely manner. Implementation Date: March 31, 2024 Responsible Persons: Mrs. Damaris Suliveres Finance and Budget Director

View Audit 33033

Finding 38134 (2022-001)

Material Weakness 2022

Morgan Hill Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Material Weakness

Views of Responsible Officials The District agreed with the finding and the accompanying financial statements reflected this change. Further, the District is in the process of sending notifications to the private schools about participation opportunities for the past fiscal year ended June 30, 202...

Views of Responsible Officials The District agreed with the finding and the accompanying financial statements reflected this change. Further, the District is in the process of sending notifications to the private schools about participation opportunities for the past fiscal year ended June 30, 2022. These notifications will allow the private schools to receive participation opportunities in combination with the June 30, 2023 participation opportunities.

View Audit 31378

Finding 38126 (2022-006)

None 2022

Gratz College

PA

Cash Management

Finding 2022-006 Corrective Action Plan The College acknowledges withdrawing all remaining funds from the appropriate awarding agency before the expiration date of December 31, 2021. However, it should be noted that the disbursement of these funds drawn was in anticipation of settling an invoice for...

Finding 2022-006 Corrective Action Plan The College acknowledges withdrawing all remaining funds from the appropriate awarding agency before the expiration date of December 31, 2021. However, it should be noted that the disbursement of these funds drawn was in anticipation of settling an invoice for an allowable expense within three calendar days of the draw. However, because of unforeseen delays on the part of the vendor, the invoice was settled outside of this timeframe. It should be further noted that all funds drawn are kept in a non-interest bearing bank account separate from the College?s normal operating account (from which all vendor invoices are paid) until the funds are disbursed. Upon disbursement, the funds are then transferred to the College?s operating account. To ensure that disbursements of federal awards are made within the allowed timeframe, the College?s management will have received an invoice for an allowable expenditure before withdrawing federal funds to settle that invoice. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033

Finding 38125 (2022-005)

Significant Deficiency 2022

Gratz College

PA

Cash Management Procurement, Suspension & Debarment Significant Deficiency

Finding 2022-005 Corrective Action Plan To ensure that disbursements of Federal awards are made within the allowed timeframe, the Manager of Business Operations and Facilities and the Manager of Financial Reporting will review the program requirements of each award and document these disbursement re...

Finding 2022-005 Corrective Action Plan To ensure that disbursements of Federal awards are made within the allowed timeframe, the Manager of Business Operations and Facilities and the Manager of Financial Reporting will review the program requirements of each award and document these disbursement requirements on the College?s reconciliation of grant funds expended prior to drawing down funds. Dates will be added to the College?s reconciliation of grant funds to indicate the last day when funds must be disbursed. Any remaining funds after this date will be returned to the granting agency. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033

Finding 38124 (2022-004)

Material Weakness 2022

Gratz College

PA

Questioned Costs

Finding 2022-004 Corrective Action Plan The College acknowledges that it erroneously applied the funds awarded to students to the incorrect subprogram. To ensure that federal funds are administered in accordance with program compliance requirements, the College will review and document, in summary ...

Finding 2022-004 Corrective Action Plan The College acknowledges that it erroneously applied the funds awarded to students to the incorrect subprogram. To ensure that federal funds are administered in accordance with program compliance requirements, the College will review and document, in summary form, all requirements made by the granting agency, including but not limited to proper use of funds, timeline for disbursement of federal funds, and reporting requirements. This documentation will be used by the responsible persons the ensure that the administration of the program and its related expenditures follow the guidelines of the granting agency Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033 Questioned Costs: $1

Finding 38123 (2022-003)

None 2022

Gratz College

PA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Equipment & Real Property Management

Finding 2022-003 Corrective Action Plan To ensure that funds drawn under the ESF properly allocated to the appropriate sub-program and are used in accordance with guidance provided by the granting agency, the College will develop a reconciliation process that includes a review of allowable use of fu...

Finding 2022-003 Corrective Action Plan To ensure that funds drawn under the ESF properly allocated to the appropriate sub-program and are used in accordance with guidance provided by the granting agency, the College will develop a reconciliation process that includes a review of allowable use of funds under the granting agency?s grant award notification and a second review of the reconciliation of funds drawn and expended of the allocations made to the sub-programs against the College?s internal records. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Name of Contact Person Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033

Finding 38122 (2022-002)

None 2022

Gratz College

PA

Reporting

Finding 2022-002 Corrective Action Plan The College was posting quarterly forms based on its financial records to its website. However, the current platform that the College utilizes does not provide an activity log to show that these reports were posted in a timely manner. Going forward, the Colle...

Finding 2022-002 Corrective Action Plan The College was posting quarterly forms based on its financial records to its website. However, the current platform that the College utilizes does not provide an activity log to show that these reports were posted in a timely manner. Going forward, the College will generate screenshots that will have a timestamp to show the timely posting of these reports. To ensure that quarterly reports submitted to the Department of Education and subsequently posted to the College?s website are accurate, the Manager of Business Operations and Facilities will work with the Manager of Financial Reporting to reconcile each report to internal records prior to submission. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Name of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033

Finding 38121 (2022-001)

Material Weakness 2022

Gratz College

PA

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2022-001 Corrective Action Plan The College has documentation indicating the existence and implementation of internal controls over Reporting compliance criteria for the ESF program. This documentation will be updated to include reporting requirements, specific report preparation and reconci...

Finding 2022-001 Corrective Action Plan The College has documentation indicating the existence and implementation of internal controls over Reporting compliance criteria for the ESF program. This documentation will be updated to include reporting requirements, specific report preparation and reconciliation procedures/controls and assessment of compliance with requirements of the respective grant. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting

View Audit 36033

Finding 38115 (2022-002)

Significant Deficiency 2022

Crazy Horse School

SD

Reporting Internal Control / Segregation of Duties HUD Housing Programs

2022-002 FINDING: Internal Controls over Financial Reporting Question Cost: None noted Not considered a material weakness Response: Crazy Horse School Business Office staff will follow auditors? recommendation. The Business Manager will determine the financial statements, schedule of expenditures...

2022-002 FINDING: Internal Controls over Financial Reporting Question Cost: None noted Not considered a material weakness Response: Crazy Horse School Business Office staff will follow auditors? recommendation. The Business Manager will determine the financial statements, schedule of expenditures of federal awards and related footnotes are free of material misstatement and the audit package is filed timely. The most effective controls lie in the management and the Board of Education?s knowledge of the School?s financial operations. Supervision and review functions will be done continually during all phases of the accounting cycle. Cross training with the Business Office staff will continue to be done. The Business Manager will continue to assist with disclosure information and approve any adjusting entries to the trial balance. She reviews and approves all draft and final copies of the financial statements including disclosures. In light of the guidance of SAS 115, the Business Manager will continue additional and continuing training for herself as well as the designated staff. The goal is still to provide training in government financial reporting and current reporting standards to enable management to continue to take the responsibility for the statements and disclosures. The school will continue their implantation of their new financial policies and take steps to ensure they are being followed. All expenditures will continue to be reviewed to ensure they are properly documented, coded, and the expenditures are allowable for the grant. Review of paychecks will continue to include recalculation of hours on timesheets and leave accrual calculation. With the continue Covid closures, weather closures, and my sickness (cancer) this past year has made is very difficult at times to get things done in a timely matter. We will continue to improve and hope to have a better year. This school?s financial stability is better than it has been for years with a clean opinion and no question costs. We will continue to improve, with our outstanding business office staff, and we will continue to make sure we are on top of the internal controls daily. We are not perfect and there is always room to get better and better! ANTICIPATED COMPLETION DATE: June 30, 2024 PERSON(S) RESPONSIBLE: Leslie Cuny, Business Manager

View Audit 35706

Corrective Action Plans

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