Corrective Action Plans

Finding 34813 (2022-002)

Significant Deficiency 2022

Brighter Bites

TX

Procurement, Suspension & Debarment

Finding #2022-002 ? Significant Deficiency and Other Non-compliance Condition and context: Brighter Bites? procurement policy does not include procedures to verify that vendors are not suspended, debarred, or otherwise excluded. During the audit, we tested five out of the 21 vendors subject to pr...

Finding #2022-002 ? Significant Deficiency and Other Non-compliance Condition and context: Brighter Bites? procurement policy does not include procedures to verify that vendors are not suspended, debarred, or otherwise excluded. During the audit, we tested five out of the 21 vendors subject to procurement, to determine if they had been suspended, debarred, or otherwise excluded and no exceptions were identified. Recommendation: Revise Brighter Bites? procurement policy to include procedures to verify vendors have not been suspended, debarred, or otherwise excluded. Planned corrective action: Brighter Bites will implement a policy to verify vendors have not been suspended, debarred, or otherwise excluded. Responsible officer: Amy Priebe and Rich Dachman Estimated completion date: December 31, 2023

View Audit 33833

Finding 34810 (2022-002)

Material Weakness 2022

Triad Local School District

OH

Subrecipient Monitoring Cash Management School Nutrition Programs § 200.208 § 200.305

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Oper...

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

View Audit 32571

Finding 34807 (2022-010)

Material Weakness 2022

San Francisco Unified School District

CA

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

Views of Responsible Officials: The District has not identified any payments that are the result of fraud. The District will work on developing procedures to identify and recover payments resulting from fraud. Name of Responsible Person: Pamela Geisler, Budget & Policy Director Implementation ...

Views of Responsible Officials: The District has not identified any payments that are the result of fraud. The District will work on developing procedures to identify and recover payments resulting from fraud. Name of Responsible Person: Pamela Geisler, Budget & Policy Director Implementation Date: Fiscal Year 2023-2024

View Audit 24006

Finding 34802 (2022-009)

Material Weakness 2022

San Francisco Unified School District

CA

Questioned Costs Cash Management Material Weakness

Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Respon...

Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Responsible Person: Jennifer LaBarre, Executive Director of Student Nutrition Services Implementation Date: Fiscal Year 2023-2024

View Audit 24006 Questioned Costs: $1

Finding 34796 (2022-008)

Material Weakness 2022

San Francisco Unified School District

CA

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.200 § 200.430

Views of Responsible Officials: District is reviewing the internal procedures related to documenting salaries and wages charged to federal programs and will work with our auditors to ensure we meet this requirement. Name of Responsible Person: Anne Marie Gordon, Interim Chief Financial Officer ...

Views of Responsible Officials: District is reviewing the internal procedures related to documenting salaries and wages charged to federal programs and will work with our auditors to ensure we meet this requirement. Name of Responsible Person: Anne Marie Gordon, Interim Chief Financial Officer Implementation Date: Fiscal Year 2023-2024

View Audit 24006 Questioned Costs: $1

Finding 34795 (2022-004)

Material Weakness 2022

Anderson Healthcare

IL

Questioned Costs Allowable Costs / Cost Principles

During the testing of compliance for Federal Assistance Listing No. 93.498, U.S. Department of Health and Human Services Direct Program: COVID-19 Provider Relief Fund and the American Rescue Plan (ARP) Rural Distribution, it was determined the Organization had incorrectly re-reported $778,860 in Per...

During the testing of compliance for Federal Assistance Listing No. 93.498, U.S. Department of Health and Human Services Direct Program: COVID-19 Provider Relief Fund and the American Rescue Plan (ARP) Rural Distribution, it was determined the Organization had incorrectly re-reported $778,860 in Period 1 expenses in the Period 3 submission, which resulted in overstating expenses claimed against PRF funds of $778,860. In addition, the Organization incorrectly double counted $81,350 in Contract Labor in the Period 3 submission. This resulted in a total $860,210 of COVID-19 expenses that were charged and reported which were duplicative and/or unsupported. Corrective Action Plan: Management continues to improve our understanding of the nuances within the guidance as it relates to charging and reporting direct expenses. Additionally, the Organization continues to implement additional controls over future reporting periods to help ensure guidance is followed, which is being achieved through educational sessions and additional layers of review over future reporting periods to help ensure guidance is properly followed. It should be noted that while the expenses were erroneously double counted, the Organization had sufficient unused Lost Revenues to cover the use of these funds. Personnel Responsible for Corrective Action: Mike Marshall, Chief Financial Officer. Anticipated Completion Date: Change is in process and full adoption is anticipated by September 30, 2023.

View Audit 24005 Questioned Costs: $1

Finding 34790 (2022-003)

None 2022

Regional School Unit #56

ME

Management response/corrective action plan: We will attempt to include this information on construction contracts moving forward.

View Audit 29907

Finding 34789 (2022-001)

None 2022

La Maison Acadienne, Inc.

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, La Maison Acadienne, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2022. ...

Oversight Agency for Audit, La Maison Acadienne, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2022-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, CFDA 14.155 Recommendation: The Project should make sufficient deposits to the escrow accounts in a timely manner. Action Taken: The shortfall was due to premium increases and a change in accounting staff. The required additional deposit was deposited in December. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

View Audit 23840

Finding 34788 (2022-005)

Significant Deficiency 2022

Panthera Corporation

NY

Subrecipient Monitoring § 200.332

Panthera has now adopted the implementation of the Federal Assistance Listing Numbers on each agreement with subrecipients, and will ensure a formal approval is issued on all expenditure reports.

View Audit 34492

Finding 34787 (2022-004)

Significant Deficiency 2022

Panthera Corporation

NY

Procurement, Suspension & Debarment § 200.320

Panthera will conduct additional training and enhance the expenses review process to ensure newly issued 2023 procurement policy guidelines are being followed.

View Audit 34492

Finding 34786 (2022-003)

Significant Deficiency 2022

Panthera Corporation

NY

Matching / Level of Effort / Earmarking § 200.303 § 200.306

We already implemented a formal review and approval process in 2023 and anticipate this finding to be resolved on our next year audit. We will also ensure the review and approval is properly documented.

View Audit 34492

Finding 34785 (2022-002)

Significant Deficiency 2022

Panthera Corporation

NY

Cash Management § 200.303

Panthera implemented an approval workflow in Chrome River, but we will also ensure a formal written approval is issued on quarterly expenditure reports going forward.

View Audit 34492

Finding 34784 (2022-001)

Material Weakness 2022

Panthera Corporation

NY

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.405

Panthera implemented Chrome River which is a platform that enables electronic review and approval of invoices as part of Panthera?s expense management process. As Panthera expands its operations internationally we plan to implement more controls and procedures to ensure foreign affiliates are proper...

Panthera implemented Chrome River which is a platform that enables electronic review and approval of invoices as part of Panthera?s expense management process. As Panthera expands its operations internationally we plan to implement more controls and procedures to ensure foreign affiliates are properly maintaining all required expenditures documentation and approvals on spending.

View Audit 34492 Questioned Costs: $1

Finding 34783 (2022-003)

None 2022

Randall University

OK

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

FINDING 2022-003? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.063 ($684,817) 84.007 ($34,837) Award Number: P268K223315 P063P213315 P...

FINDING 2022-003? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.063 ($684,817) 84.007 ($34,837) Award Number: P268K223315 P063P213315 P007A213421 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $26.85 (84.268) $97.40 (84.007) Condition Found: The Title IV funds were not returned timely for two of the forty students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for two of the three students noted above. The incorrect number of days in the semester was used for both students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed timely and one of the additional R2T4s was not calculated correctly. Federal Pell Grant funds returned for not beginning a module course were not excluded from the R2T4 calculation. Corrective Action Plan: Management agrees with this finding. ? For the first student in question, the R2T4 was completed timely, but the incorrect number of days was used in the R2T4 calculation. $26.85 of Federal Direct Loans were returned to the Department of Education in December 2022. ? For the second student in question, the R2T4 was completed and accepted late by the third-party servicer. In addition, the incorrect number of days was used in the R2T4 calculation. An additional $65.59 of Federal Pell Grant funds were disbursed to the student in December 2022. ? For the third student in question, the R2T4 was not completed timely and accepted late by the third-party servicer. The R2T4 was not completed until April 2022 which was more than forty-five days after the date of determination. ? For the fourth student in question, the incorrect Federal Pell Grant disbursed figure was used in the calculation. An additional $97.40 of FSEOG funds were returned in December 2022. In addition, the R2T4 was not calculated within 45 days of the date of determination, so the original funds were returned late. ? For the fifth student in question, the R2T4 was not reviewed and approved by the TPA within 45 days of the date of determination. The correct post-withdrawal disbursement was made in August 2022. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

View Audit 33952

Finding 34780 (2022-001)

Material Weakness 2022

Randall University

OK

Reporting Matching / Level of Effort / Earmarking

FINDING 2022-001 ? Financial Close and Reporting Condition Found: During our audit, we noted the following: ? The University did not record the expenses related to the Paycheck Protection Program loan or HEERF funds correctly. Instead of recognizing qualified expenses as revenue, the University ...

FINDING 2022-001 ? Financial Close and Reporting Condition Found: During our audit, we noted the following: ? The University did not record the expenses related to the Paycheck Protection Program loan or HEERF funds correctly. Instead of recognizing qualified expenses as revenue, the University reduced the related expense accounts. ? Discounts for El Camino online students were not recorded correctly. Corrective Action Plan: Management agrees with the auditors? finding. Randall University, beginning in the Fall of 2021 began using an outside accounting firm to assist our business office, finance staff, and financial aid staff with financial reporting and accounting. The contract accounting firm was used in 2021-2022 to address many financial reporting and accounting processes. In response to this finding, Randall University will have an independent review of non-standard journal entries added to the contract accountant?s scope-of-work as a part of Randall University?s financial closing and reporting processes. The contract accountant will communicate with the auditing firm to seek guidance and requirements to better address this issue. Anticipated Completion Date: The corrective action is in process and will completed by June 2023. Contact Person: Todd Jenson, CFO 405-912-9475

View Audit 33952

Finding 34760 (2022-003)

Material Weakness 2022

Snohomish County

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring

See Corrective Action Plan for chart/table

View Audit 34269

Finding 34757 (2022-001)

Significant Deficiency 2022

Camden County

NC

Eligibility

Corrective Action: Procedures and controls have been established for caseworkers to follow. Additional Training is already scheduled and will continue as needed on the Written Medicaid Corrective Action Plan for FY 2021. This will keep workers reminded to follow each policy and procedure more carefu...

Corrective Action: Procedures and controls have been established for caseworkers to follow. Additional Training is already scheduled and will continue as needed on the Written Medicaid Corrective Action Plan for FY 2021. This will keep workers reminded to follow each policy and procedure more carefully to minimize errors in the application process for future audits. Director, Supervisor, and Lead Worker will conduct reviews no less than quarterly to verify accuracy. If issues arise, workers will be retrained on the specifics of what is needed. If continued errors arise, Finance Officer will do additional reviews. Proposed Completion Date: Certain controls have been created and are continuing to be reviewed and modified if needed. Management will have 1st training no later than February 1st, 2022. Supervisor and Director will continue to monitor this issue and have additional mandatory trainings for staff that fail to comply with the Written Corrective Action Plan for FY 2021.

View Audit 33865

Finding 34755 (2022-003)

Significant Deficiency 2022

Florence County

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.214 § 200.303

Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the...

Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the covered transaction with entity (2 CFR section 180.300) Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: Staff Training ? November 2023

View Audit 31014

Finding 34754 (2022-001)

Material Weakness 2022

Miles City Eagles Manor

MT

HUD Housing Programs Matching / Level of Effort / Earmarking

Miles City Eagle Manor Corrective Action Plan June 30, 2022 2022-001 Delinquent Debt Payments Underpayment of the flex subsidy loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the paym...

Miles City Eagle Manor Corrective Action Plan June 30, 2022 2022-001 Delinquent Debt Payments Underpayment of the flex subsidy loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these suggestions as of the date on this report, November 3, 2022. Karen Burkett, the Managing Agent, will work with the Organization to resolve this matter. The anticipated completion date is June 30, 2023.

View Audit 37803

Finding 34753 (2022-001)

Significant Deficiency 2022

Jobpath, Inc.

AZ

Subrecipient Monitoring Reporting

To ensure the timely submission of the monthly participant report to the pass-through entity, JobPath has modified its current process, submitting the report by the required deadline, separately from the invoice, which is due later in the month. By the next reporting date of April 5th, reports will ...

To ensure the timely submission of the monthly participant report to the pass-through entity, JobPath has modified its current process, submitting the report by the required deadline, separately from the invoice, which is due later in the month. By the next reporting date of April 5th, reports will be reviewed internally by supervisory personnel who did not prepare the report. The CEO will ensure these actions are taken. To ensure reporting accuracy, JobPath will create and maintain an electronic journal documenting individual participant funding assignments and any changes made to the funding sources, including the date, the person making the change, and the reason for the change. Only individuals with the appropriate roles and authority will have editing access. The CEO will ensure this action is implemented by the next reporting date of April 5th. Additionally, JP will work with the platform developer to add the necessary features so that changes are automatically documented and maintained and historical data/reports can be generated for control purposes. The Director of Operations will ensure this action is taken by June 30th.

View Audit 37765

Finding 34748 (2022-001)

None 2022

Crowleys Ridge College

AR

Crowley's Ridge College's Registrar is responsible for ensuring that appropriate NSLDS enrollment reporting is conducted in a timely manner. t is now understood that NSLDS enrollment reporting should only take place on the web for changes made within the 60-day range of reporting. This includes but ...

Crowley's Ridge College's Registrar is responsible for ensuring that appropriate NSLDS enrollment reporting is conducted in a timely manner. t is now understood that NSLDS enrollment reporting should only take place on the web for changes made within the 60-day range of reporting. This includes but is not limited to changes of major, withdrawal from the institution, changes in full time and part time status, etc. On March 23, 2023, the Registrar's Office successfully installed EDConnect 8.5.0 software onto the institution's computer system and ran the security patch. However, upon logging into the system, access was denied. This prompted a call to EDConnect (1-800-330-5947) and steps were provided to access the enrollment roster. According to EDConnect, David Goff is listed as the Primary DPA and Shelly Beasley is listed as the Secondary DPA. As a result, Treka Clark does not have access to modify rights thus allowing access to the enrollment roster that is currently being sent to the institution's TG53917 mailbox. twas determined that Shelly Beasley will need to call EDConnect to update the Primary and Secondary DPA personnel. She will list herself, Shelly Beasley, as the Primary DPA and Treka Clark as the Secondary DPA. This will require the completion of signature pages and will take approximately 1-2 business days to process upon receipt of the completed signature pages. h addition to updating the Primary and Secondary DPA, Shelly Beasley will also request to have the enrollment roster be sent to Treka Clark's personal TGY3180 number. Timeline for Implementation of Corrective Action Plan: Implementation of this action plan will occur immediately following the submission of the signature pages to EDConnect and request to have the enrollment reporting roster be sent to the TGY3180 number. Contact Person

View Audit 36607

Finding 34747 (2022-006)

Significant Deficiency 2022

City of McFarland

CA

Procurement, Suspension & Debarment

2022-006 Significant Deficiency Covid - 19 American Rescue Plan Act ? Assistance Listing No. 21.027 Recommendation: CLA recommends that City implement procedures to ensure that federal guidance is followed relating to procurement and debarment. Explanation of disagreement with audit finding: There i...

2022-006 Significant Deficiency Covid - 19 American Rescue Plan Act ? Assistance Listing No. 21.027 Recommendation: CLA recommends that City implement procedures to ensure that federal guidance is followed relating to procurement and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We acknowledge the audit finding relating to disbursements of the Covid-19 American Rescue Plan Act funds to vendors without going through the bidding process and the delayed debarment checks for two vendors. We recognize the severity of non-compliance with federal regulations and understand the need to enhance our internal controls to prevent similar issues in the future. To address this finding, we plan to undertake the following corrective actions: ? Review of Current Contracts: Immediate steps will be taken to review all existing contracts financed through the Covid-19 American Rescue Plan Act to ensure compliance with federal regulations. If any irregularities are found, they will be addressed promptly. ? Procedure Enhancement: Procedures related to procurement and debarment checks will be reviewed and strengthened to ensure they align with federal guidance. This will include an emphasis on performing debarment checks before the commencement of any work and adhering to the bidding process regardless of the urgency of the situation. ? Training: We will conduct comprehensive training sessions for all personnel involved in procurement and financial management. The training will focus on the importance of complying with federal regulations when utilizing federal funding, including procurement processes and debarment checks. ? Enhanced Oversight: An oversight mechanism will be established to ensure strict adherence to federal guidelines in the management of all federal funds. This mechanism will include regular audits and reviews to ensure that federal guidance on procurement and debarment is consistently followed. ? Policy Revision: We will revise our procurement policy to emphasize the importance of adhering to the bid process and conducting debarment checks before awarding contracts funded through federal awards. ? Improved Documentation: We will improve our record-keeping practices to document all actions related to procurement and debarment checks. This will enable us to provide evidence of compliance during any future audits. While the current finding reflects an oversight during an emergency response, we are committed to adhering to all requirements even under challenging circumstances. We appreciate the audit team's efforts to identify areas for improvement, and we will work diligently to rectify these issues. Name(s) of the contact person(s) responsible for corrective action: Diego Viramontes Planned completion date for corrective action plan: June 30, 2023

View Audit 36865

Finding 34744 (2022-002)

Significant Deficiency 2022

West Central Wisconsin Workforce Development Board, Inc.

WI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The entity has addressed this in the current year by providing additional training and expectations set forth to the subrecipient (WRI). Additionally, the Board has worked with DWD to ensure the requirement will be met in the current year. Name of the contact person responsible for corrective action: Jon Menz Planned completion date for corrective action plan: June 30, 2023 If involved agencies have any questions regarding this plan, please call Jon Menz at 715-235-8393

View Audit 36864

Finding 34743 (2022-001)

Significant Deficiency 2022

Stepping Out Housing, Inc.

CA

Subrecipient Monitoring HUD Housing Programs

Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001 Corrective Action Plan: The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits were depo...

Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001 Corrective Action Plan: The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits were deposited into the reserve fund subsequent to year-end. Name of Responsible Person: Kim Morrison, CFO Anticipated Completion Date: December 31, 2022 Signed by Kim Morrison on October 12, 2022.

View Audit 35075

Finding 34740 (2022-003)

Significant Deficiency 2022

J.f. Drake State Community and Technical College

AL

Student Financial Aid Eligibility Reporting

3) Finding 2022-003 ? Student Financial Assistance ? Enrollment Reporting Management?s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The...

3) Finding 2022-003 ? Student Financial Assistance ? Enrollment Reporting Management?s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its controls and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Mattavia Ward, Director of Admissions Implementation Date: Immediately

View Audit 36189

Corrective Action Plans

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