Corrective Action Plans

Finding 26120 (2022-002)

Material Weakness 2022

The Willow Domestic Violence Center, Inc.

KS

Reporting Internal Control / Segregation of Duties

Management of the Willow Domestic Violence Center concurs with the audit finding and will implement corrective action during the year ended June 30, 2024.

View Audit 27640

Finding 26119 (2022-001)

Material Weakness 2022

The Willow Domestic Violence Center, Inc.

KS

Reporting Internal Control / Segregation of Duties

Management of the Willow Domestic Violence Center concurs with the audit finding and will implement corrective action during the year ended June 30, 2024.

View Audit 27640

Finding 26118 (2022-001)

None 2022

Accessible Space North, Inc.

MN

Questioned Costs HUD Housing Programs

ACCESSIBLE SPACE NORTH, INC. HUD PROJECT NO. 092-11429 CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Accessible Space North, Inc. respectfully submits the following corrective action plan for the y...

ACCESSIBLE SPACE NORTH, INC. HUD PROJECT NO. 092-11429 CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Accessible Space North, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 The Project paid the expense of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

View Audit 27311 Questioned Costs: $1

Finding 26117 (2022-001)

Significant Deficiency 2022

Village Cooperative of Lee's Summit

MO

Internal Control / Segregation of Duties Significant Deficiency

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

View Audit 25689

Finding 26116 (2022-003)

Significant Deficiency 2022

Housing Authority of the City of Beaumont

TX

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Finding 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance ? N. Special Tests and Provisions - Recording of Declarations of Trust/Declaration of Restrictive Covenants A...

Finding 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance ? N. Special Tests and Provisions - Recording of Declarations of Trust/Declaration of Restrictive Covenants Against Public Housing Property Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: A current Declaration of Trust ("DOT"), in a form acceptable to HUD, must be recorded against all public housing property owned by PHAs (or private entities for public housing developed under 24 CFR Part 905, Subpart F) that has been acquired, developed, maintained, or assisted with funds from the US Housing Act of 1937. A DOT is a legal instrument that grants HUD an interest in public housing property. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were properties that the Authority owns and insures that did not have DOTs on file during the time of audit. Context: The Authority owns six (6) public housing properties. During the audit, it was noted that two (2) out of six (6) public housing properties did not have DOTs on file. Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to the recording of DOTs against public housing property. The Authority has not properly filed DOTs in compliance with program requirements. Effect: The Public and Indian Housing Program is in non-compliance with the special tests and provisions type of compliance related to the recording of DOTs against public housing property. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and will design and implement internal controls over compliance in order to ensure all necessary DOTs are recorded. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

View Audit 23692

Finding 26115 (2022-002)

Significant Deficiency 2022

Housing Authority of the City of Beaumont

TX

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Finding 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Programs Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financi...

Finding 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Programs Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were failed inspections that did not pass reinspection within 30 days without penalty. Context: There are approximately 489 units with failed inspections. Of a sample size of twenty-five (25) failed inspections, three (3) failed inspections did not pass reinspection within 30 days. HAP was not abated nor was the tenant evicted. Our sample size is statistically valid. Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of insufficient staffing. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to the software conversion from HAB to Yardi. BHA has completed the software conversion, and this should not be an issue going forward. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

View Audit 23692

Finding 26114 (2022-001)

Significant Deficiency 2022

Housing Authority of the City of Beaumont

TX

HUD Housing Programs Eligibility Significant Deficiency

Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Significant ...

Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 1,805 units. Of a sample size of thirty-one (31) tenant files, the following was noted: ? Annual inspection report was missing in 1 file ? HUD 50058 Form was missing in 1 file ? Verification of income and assets was missing in 1 file. Our sample size is statistically valid. Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

View Audit 23692

Finding 26110 (2022-001)

Significant Deficiency 2022

Polk County School District

GA

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.403

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: ...

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021), S425W210011 (Year: 2021) Questioner Costs: 99,748 Prior Year Finding: No Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The School District will work with all entities to confirm that all existing internal controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures are compliant with all applicable policies and regulations. Estimated Completion Date: June 30, 2023 Contact Person: Tammy McDonald, Executive Finance Director Telephone: 770-748-3821 Email: tammy@polk.k12.ga.us

View Audit 23422 Questioned Costs: $1

Finding 26109 (2022-001)

None 2022

Puerto Rico Medical Services Administration

PR

Questioned Costs Eligibility

Galindez LLC Urb. Perez Morris, 19 Ponce St. San Juan, PR 00917 Dear CPA Marcos Claudio: In connection with the Schedule of Findings and Questioned Cost of Administracion de Servicios Medicos de Puerto Rico (ASEM) for the year ended June 30, 2022, below please find our comments, and planned co...

Galindez LLC Urb. Perez Morris, 19 Ponce St. San Juan, PR 00917 Dear CPA Marcos Claudio: In connection with the Schedule of Findings and Questioned Cost of Administracion de Servicios Medicos de Puerto Rico (ASEM) for the year ended June 30, 2022, below please find our comments, and planned corrective actions for Finding identified. Finding No. 2022-001 Eligible Uses Providing Premium Pay to Eligible Workers As more fully explained to your representative during the audit, the Administrator of this Premium Pay Program was the Health Department of Puerto Rico (HD) who was in charge of developing the program to all Public Hospital in Puerto Rico, among them, the Administracion de Servicios Medicos de Puerto Rico (ASEM). At all times, ASEM followed the instructions provided by the HD. Furthermore, we provided the HD with the list of possible eligible employees, including the information of the requirements established by them. The salary $40,000.00's limit was not a requirement to be considered. After the review done by HD, they provided ASEM with the authorized list of employees eligible for the benefit which ASEM used for the payment. Accordingly, it was never the intention of ASEM to pay this benefit to not eligible beneficiaries, it was only a matter of not providing ASEM with the actual requirements from the Program's Administrator. Should you have any question, please call at your convenience. Paul Barreras Diaz, CPA Finance & Budget Director

View Audit 21496 Questioned Costs: $1

Finding 26105 (2022-003)

Significant Deficiency 2022

Shiprock Assiciated Schools, Inc.

NM

Special Tests & Provisions Significant Deficiency

2022 003 Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior Title Indian School Equalization Program Federal Assistance Listing Number 15.042 Questioned Costs None Condition: During our testwork over special tes...

2022 003 Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior Title Indian School Equalization Program Federal Assistance Listing Number 15.042 Questioned Costs None Condition: During our testwork over special tests and provisions, we noted 3 instances where the employee's background and character investigation were not completed before these employees started working, 2 instances where we did not see the certification of investigation and adjudication. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual meet standards of character, no less stringent than those prescribed under Subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: We recommend that the School ensure that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: ? The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. ? Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team

View Audit 20587

Finding 26104 (2022-002)

Significant Deficiency 2022

Shiprock Assiciated Schools, Inc.

NM

Procurement, Suspension & Debarment § 200.213

2022 002 Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior, U.S. Department of Education Title Indian School Equalization Program Federal Assistance Listing Number 15.042, 84.027 Questioned Costs None Condition:...

2022 002 Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior, U.S. Department of Education Title Indian School Equalization Program Federal Assistance Listing Number 15.042, 84.027 Questioned Costs None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non federal entities are subject to the non procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team

View Audit 20587

Finding 26093 (2022-001)

Significant Deficiency 2022

New Jersey Association on Correction and Morrow Holding Corporation

NJ

Reporting Significant Deficiency

The Organization plans to reorganize job duties and increase staff in the finance department to assist in the preparation of quarterly fiscal and programmatic reports to file on a timely basis. This was a result of staff turnover which created delays in filing complete and accurate reports.

View Audit 20585

Finding 26090 (2022-003)

Material Weakness 2022

Food Lifeline

WA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

The Organization has a policy outlining procurement and suspension and debarment procedures. The Organization also has standard forms in place guiding purchasing decisions. However, those forms lack elements that prompt staff to perform document procurement and suspension debarment procedures. The O...

The Organization has a policy outlining procurement and suspension and debarment procedures. The Organization also has standard forms in place guiding purchasing decisions. However, those forms lack elements that prompt staff to perform document procurement and suspension debarment procedures. The Organization did not maintain adequate documentation that procurement practices were performed in accordance with the Uniform Grant Guidance requirements. The Organization also did not perform or document suspension and debarment checks on prospective vendor sub-recipients. The corrective action plan by the Organization is as follows: 1. This process was implemented and followed but supporting documentation was not stored properly so compliance couldn?t be verified. Paper documentation has been moved to a secure storage file in Finance. Subsequently, the verification for suspension and debarment has been moved to an electronic verification process through Verifycomply.com and the supporting documentation is being stored electronically and on the company?s portal. Completed 02/21/2023 Responsible Individual: Samantha Franklin, CFO SamanthaF@foodlifeline.org - 206.432.3601

View Audit 22864

Finding 26084 (2022-002)

Material Weakness 2022

Food Lifeline

WA

Subrecipient Monitoring Eligibility § 200.303

Compliance activities were temporarily suspended during the COVID-19 pandemic; however, the eligibility requirements resumed during the year ending June 30, 2022. The Organization did not resume eligibility verification when the requirements were reinstated. A risk assessment spreadsheet is maintain...

Compliance activities were temporarily suspended during the COVID-19 pandemic; however, the eligibility requirements resumed during the year ending June 30, 2022. The Organization did not resume eligibility verification when the requirements were reinstated. A risk assessment spreadsheet is maintained and submitted to the funder annually, which details if sub-recipients meet the required eligibility criteria. However, the Organization does not have controls in place to review these eligibility determinations to verify that they are complete and correct. The corrective action plan by the Organization is as follows: 1. Training on 2 CFR section 200.303 and related federal statutes for all staff involved in the management and implementation of the program. Estimated date of completion 04/03/2023 2. Improve controls through the implementation of a new annual verification process with each sub-recipient participating in the program (this is in addition to regularly scheduled check-ins required by WSDA and annual risk assessment). Estimated date of completion 04/28/2023 Responsible Individual: Samantha Franklin, CFO SamanthaF@foodlifeline.org - 206.432.3601

View Audit 22864

Finding 26080 (2022-002)

Significant Deficiency 2022

Northern Wyoming Community College District

WY

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

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.268, 84.033 Finding Summary: 34 CFR Section 668.22 states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a pa...

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.268, 84.033 Finding Summary: 34 CFR Section 668.22 states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. During our testing of compliance with Return of Title IV Funds (R2T4), there was 1 instance out of 38 where the District calculated the incorrect amount to be returned to the Department of Education (ED). Responsible Individuals: Heidi Balster, Director of Student Financial Aid Corrective Action Plan: During each payment period of an award year, the Financial Aid Office will review 20% of all R2T4 calculations (unduplicated) to ensure accuracy of the calculation and students? earned aid. The Financial Aid Office will use the random (RAND) formula in Excel to randomly select the R2T4 student population for testing. Within one week after all midterm grades are posted for the payment period, the Financial Aid Office will randomly select 10% of R2T4 calculations processed and review each calculation to ensure the correct period of enrollment was used in the calculation. After the end of each payment period, within a week after all unofficial withdrawals are processed, the Financial Aid Office will randomly select an additional 10% of R2T4 calculations (unduplicated) and review each calculation to ensure the correct period of enrollment was used in the calculation. If it is determined that a student?s R2T4 calculation is incorrect, the Financial Aid Office will complete the following steps prior to processing a corrected R2T4 calculation: 1. Obtain screenshots of incorrect R2T4 calculation and print copies into the Perceptive Content imaging system 2. Purge the incorrect R2T4 calculation and leave comments in student?s record for reason of purged calculation 3. Update all Title IV aid awards back to original amounts disbursed prior to R2T4 calculation 4. Run the Colleague?s Batch FA Transmittal Register (FATR) process and review aid adjustments 5. Notify the Business Office to have them run the Batch FA Transmittal Update (FATP) process 6. Once FATP is processed, re-run R2T4 calculation with the corrected enrollment Anticipated Completion Date: January 2023

View Audit 22863

Finding 26075 (2022-001)

None 2022

Town of San Anselmo

CA

Subrecipient Monitoring Cash Management Reporting

Finding reference number: SA2022-01 Review of Required Reports Submitted To Grantor CFDA number 20.205 CFDA Title: Highway Planning and Construction Grant Name of Federal Agency: Department of Transportation Federal Award Identification number and year: 1. STPL-6084(206) 2016 2. CMLNI-6419(0...

Finding reference number: SA2022-01 Review of Required Reports Submitted To Grantor CFDA number 20.205 CFDA Title: Highway Planning and Construction Grant Name of Federal Agency: Department of Transportation Federal Award Identification number and year: 1. STPL-6084(206) 2016 2. CMLNI-6419(027) 2017 3. BRLS-5159(017) 2016 4. BRLS-5159(018) 2016 5. BPMP-5159(022) 2016 Name of pass-through Entity: Metropolitan Transportation Commission California Department of Transportation Name(s) of the contact person: Jeff Zuba, Finance & Administrative Services Director Corrective Action Plan: The Finance team and Engineering/Public Works department will implement a new procedure for preparing and reviewing reimbursement requests. Assistant Public Works Director prepares reimbursement request and Finance Director reviews it before the reimbursement request submission. Anticipated Completion Date: April 1, 2023

View Audit 17938

Finding 26037 (2022-001)

Significant Deficiency 2022

Independent School District 695

MN

Internal Control / Segregation of Duties Subrecipient Monitoring

Actions Planned - The school district has implemented a plan to eliminate this finding for federal programs by distributing duties, and adding additional oversite. Program managers have been assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign ...

Actions Planned - The school district has implemented a plan to eliminate this finding for federal programs by distributing duties, and adding additional oversite. Program managers have been assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on all receipts and disbursements. A principal will act as program manager for Title funds, and the Superintendent will act as program manager for all other federal funds. Request for reimbursement and receipting will be completed by the Administrative Assistant with oversight by the Business Manager and Superintendent. The key action to eliminate inadequate segregation of duties is developing strong controls over the review and approval of adjusting journal entries. This will involve detailed review by the program manager and the Superintendent. Adjusting journal entries are discussed and signed off on each month to timely detect misstatements. Official Responsible - Business Manager and Superintendent of Schools Planned Completion Date - December 31st, 2022 Disagreement with Finding - None - ISD #695 - Chisholm concurs with the finding. Plan to Monitor - The District is aware of the situation and will monitor, as it deems appropriate. Monitoring will include educating program managers to provide additional oversight for the interim and year-end reporting.

View Audit 28610

Finding 26032 (2022-001)

Significant Deficiency 2022

Thorpe Housing Development Fund Company, Inc.

NY

Allowable Costs / Cost Principles

Name of auditee: Thorpe Housing Development Fund Company, Inc. HUD auditee identification number: 012-35715 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2022 CAP prepared by: Name: Mathew Janeczko Position: Executive Director Telephone: ...

Name of auditee: Thorpe Housing Development Fund Company, Inc. HUD auditee identification number: 012-35715 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2022 CAP prepared by: Name: Mathew Janeczko Position: Executive Director Telephone: 845-359-0454 1. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. a. Management has implemented internal control procedures to ensure compliance with all requirements under the Uniform Guidance, including, but not limited to, continued review of compliance requirements related to federal grants, as well as conferring with the current independent auditor to identify critical deadlines and required submissions.

View Audit 25430

Finding 26031 (2022-006)

Material Weakness 2022

City of Atlanta

GA

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

Name of Contact Person Responsible for Corrective Action Plan: Jerry Deloach, Chief Risk Officer - Enterprise Risk Management Corrective Action Plan: The City of Atlanta?s Office of Enterprise Risk Management (ERM) will calendar the deadlines for filing of reports 90 days from the filing date and ea...

Name of Contact Person Responsible for Corrective Action Plan: Jerry Deloach, Chief Risk Officer - Enterprise Risk Management Corrective Action Plan: The City of Atlanta?s Office of Enterprise Risk Management (ERM) will calendar the deadlines for filing of reports 90 days from the filing date and each 30-day period thereafter until the filing date and filing of the report. In addition, the Office of ERM will calendar the filing date two weeks prior to filing date. ERM will file the report two weeks prior to the filing deadline date and provide the City of Atlanta?s Grants Accounting team with a copy of the filing. Anticipated Completion Date: June 30, 2023

View Audit 25356

Finding 26025 (2022-007)

Significant Deficiency 2022

City of Atlanta

GA

Internal Control / Segregation of Duties

Name of Contact Person Responsible for Corrective Action Plan: Deborah Lonon, Commissioner, Department of Grants & Community Development Corrective Action Plan: A. The City of Atlanta?s Department of Grants and Community Development (DGCD) will include the five-year Environmental Review (ER) submis...

Name of Contact Person Responsible for Corrective Action Plan: Deborah Lonon, Commissioner, Department of Grants & Community Development Corrective Action Plan: A. The City of Atlanta?s Department of Grants and Community Development (DGCD) will include the five-year Environmental Review (ER) submissions within the Consolidated (Con) Plan Y1, allowing all projects that fall under the same activity to be considered in compliance for the duration of the Con plan and all subsequent Annual Action Plans (AAP), following the procedure below: i. Completion of Annual Action Plan (AAP) After the final version of the AAP is submitted and approved along with funding remediations, the ER process can begin. ii. Exempt and CENST-level ERs can be completed Exempt ERs are defined as certain activities unlikely to have any direct impact on the environment. Accordingly, these activities are not subject to most of the procedural requirements of environmental review. B. DGCD will update all ER policies and procedures. The Office of Completive Compliance will provide a training to all DGCD staff and all DGCD staff will sign an Acknowledgment Form related to the ER Policy and Procedures. C. DGCD will internally audit the ER process to determine its compliance and effectiveness and DGCD will make necessary updates and modifications to all approved ER policies and procedures. Anticipated Completion Date: June 30, 2023

View Audit 25356

Finding 26020 (2022-003)

Significant Deficiency 2022

Laboure College of Healthcare

MA

Matching / Level of Effort / Earmarking Reporting

Finding: No. 2022-003 Higher Education Emergency Relief Funds Earmarking. Finding: The American Rescue Plan (ARP) created a new requirement that a portion of the HEERF III Institutional Funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a fina...

Finding: No. 2022-003 Higher Education Emergency Relief Funds Earmarking. Finding: The American Rescue Plan (ARP) created a new requirement that a portion of the HEERF III Institutional Funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. The College utilized direct emails to students, however, no evidence of direct outreach occurred as required by the program. Corrective Action Taken or Planned: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, management will have implemented a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Both the Financial Aid Director, Erin Hanlon and the VP of Administration and Finance, William McDonald will regularly monitor and manage changes to rules and regulations promulgated by the DOE effective immediately 3/29/2023.

View Audit 24461

Finding 26019 (2022-002)

Significant Deficiency 2022

Laboure College of Healthcare

MA

Reporting

Finding: No. 2022-002 Higher Education Emergency Relief Funds Reporting. Finding: Institutions that expended HEERF grant funds during the calendar quarter from January 1- March 30, 2021 are required to post the quarterly report that involved the expenditure of HEERF I CARES Act funds and HEERF II C...

Finding: No. 2022-002 Higher Education Emergency Relief Funds Reporting. Finding: Institutions that expended HEERF grant funds during the calendar quarter from January 1- March 30, 2021 are required to post the quarterly report that involved the expenditure of HEERF I CARES Act funds and HEERF II CRRSAA. The Department did not previously affirm this reporting requirement for HEERF II CRRSAA funds. As such, institutions may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. The specific errors were that the amount reported on the 12/31/2020 quarterly report was $38,750 but based on the drawdowns, no funds were drawn in this quarter and that $ 38,750 was drawn in February 2021 and was captured in the total reported on the 3/31/2021 quarterly report. The other issue is that on the 3/31/2021 and 6/30/2021, the amounts drawn for SIP should have been reported separately in the 18004(a)(2) column. Corrective Action Taken or Planned: The issue was the result of a misunderstanding of how drawdowns versus actual expenditures were reported. There were corrections made to the quarterly reports, however, the report in question was never updated on the website. The quarterly reports were corrected by the VP of Administration and Finance, William McDonald and posted to our website by the end of September 2022. according to the previous corrective action plans 06/30/2021. The issue arising is the 09/30/2021and 12/31/2021 reports for the fiscal year ending 06/30/2022 were wrong and corrected at the same time. The VP of Administration and Finance made the corrections to the quarterly report as of 09/30/2022. Corrections have been completed as of 09/30/2022.

View Audit 24461

Finding 26017 (2022-005)

Significant Deficiency 2022

Laboure College of Healthcare

MA

Cash Management Student Financial Aid

Finding: No. 2022-005- Cash Management Finding: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount...

Finding: No. 2022-005- Cash Management Finding: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time was $51,701. Corrective Action Taken or Planned: Management will review and follow internal control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Corrective action has been taken to return any amount of excess cash, as of 09/30/2022 completed by the VP of Administration and Finance, William McDonald.

View Audit 24461

Finding 26016 (2022-004)

Significant Deficiency 2022

Laboure College of Healthcare

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV...

Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: The College, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally, a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Enrollment reporting corrections have been corrected as of 03/29/2023.

View Audit 24461

Finding 26013 (2022-003)

Significant Deficiency 2022

Hopeworks

NM

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management's Response: Hopeworks will implement a quarterly tracking system to ensure the grants achieve the 25% matching requirement. On a quarterly basis the Jessica Delgado the Quality and Compliance Officer will send the Finance Department a listing of applicable expenses incurred to date. The F...

Management's Response: Hopeworks will implement a quarterly tracking system to ensure the grants achieve the 25% matching requirement. On a quarterly basis the Jessica Delgado the Quality and Compliance Officer will send the Finance Department a listing of applicable expenses incurred to date. The Finance Department will review these costs to the Medicaid billings to ensure the 25% match is being met. In the event of a shortfall Finance will coordinate with Quality and Compliance to adjust spending and/or Medicaid billings to bring the matching contribution into alignment with the grant's requirements.

View Audit 22382

Corrective Action Plans

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