Corrective Action Plans

Finding 21259 (2022-001)

Significant Deficiency 2022

IL

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to d...

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to determine whether there is a significant Incident of incorrect income projections and/or tenant rent calculations. The Initial audit will entail 230 HCVP files randomly sampled (approximately 10% of the program.) The file audit process will continue to include more randomly selected files as Indicated by the results of the initial audit. 2) SCCHA will Increase monitoring and review of HCVP files to increase accuracy and ensure compliance with regulatory and statutory requirements related to income projection and rent determinations. 3) Any staff members with rent calculation certifications older than ten years will be required to attend HCVP rent calculation training and pass the corresponding certification exam. Anticipated Completion Date: 1) Within six months; 2) Initiated within 60 days and on-going thereafter; 3) Within twelve months depending on third-party trainer availability Persons Responsible: Larry McLean, Executive Director; Pam Jackson, HCV Program Director; and Shanae Golliday, Program Integrity & Compliance Coordinator

View Audit 23389

Finding 21258 (2022-001)

Significant Deficiency 2022

St. Peter's Housing, Inc. 053-Ee103

NC

HUD Housing Programs

St. Peter's Housing, Inc. Winston-Salem, NC CORRECTIVE ACTION PLAN February 16, 2023 U.S. Department of Housing and Urban Development Atlanta Regional Office Five Points Plaza Building 40 Marietta Street Atlanta, GA 30303 St. Peter's Housing, Inc. respectfully submits the following Corrective Action...

St. Peter's Housing, Inc. Winston-Salem, NC CORRECTIVE ACTION PLAN February 16, 2023 U.S. Department of Housing and Urban Development Atlanta Regional Office Five Points Plaza Building 40 Marietta Street Atlanta, GA 30303 St. Peter's Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year Ended December 31, 2022 The finding for the year ended December 31, 2022 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs: Finding 2022-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly, Assistance Listing #14.157 Recommendation: We recommend that management should continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: We agree with Finding 2022-001 described in the accompanying schedule of findings and questioned costs. Management will transfer funds to provide adequate FDIC insurance coverage for all funds. Additionally, management will re-evaluate its policies and procedures to determine any necessary changes. If HUD has questions regarding this corrective action plan, please call (336) 765-0424. Sincerely yours, Laura Grimes Accounting Manager Community Management Corporation Managing Agent

View Audit 23066

Finding 21248 (2022-010)

Material Weakness 2022

Municipality of Arecibo

PR

Reporting

We are taking the necessary steps to speed up the process for submitting financial reports under current circumstances in order to comply within the required period.

View Audit 18708

Finding 21247 (2022-001)

Significant Deficiency 2022

Huron Intermediate School District

MI

Questioned Costs Allowable Costs / Cost Principles § 200.430

Huron Intermediate School District respectfully submits the following corrective action plan for the year ended June 30, 2022 Auditor: Anderson, Tuckey, Bernhardt, & Doran, P.C. 715 E. Frank St. Caro, MI 48723 Audit Period: Year ended June 30, 2022 District Contact Person: Candice Halifax, Di...

Huron Intermediate School District respectfully submits the following corrective action plan for the year ended June 30, 2022 Auditor: Anderson, Tuckey, Bernhardt, & Doran, P.C. 715 E. Frank St. Caro, MI 48723 Audit Period: Year ended June 30, 2022 District Contact Person: Candice Halifax, Director of Finance and Carrie Brabant, Special Education Accountant The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding ? Federal Award Programs Audit Finding 2022-001 ? Significant Deficiency in Internal Control over Compliance Recommendation: The District should adhere to documented time and effort reporting procedures and maintain effective internal controls that ensure salaries and wages allocated to federal cost objectives are based on records that accurately reflect the work performed. Action to be taken: The School District will review the time and effort reporting and align it with the staff federal cost objectives on a quarterly basis to ensure the documentation accurately reflects the work performed.

View Audit 19434 Questioned Costs: $1

Finding 21246 (2022-003)

Material Weakness 2022

Crisis Assistance Center, Inc. Dba Community Assistance Center

TX

Material Weakness Reporting Internal Control / Segregation of Duties

Finding #2022-003 ? Material Weakness and Other Noncompliance Applicable federal program: U. S. Department of the Treasury Passed through Montgomery County, Texas COVID-19 ? Emergency Rental Assistance Program Assistance Listing #: 21.023 Contract Number: CARES ERA Contract Year: 07/01/21 ? 06/...

Finding #2022-003 ? Material Weakness and Other Noncompliance Applicable federal program: U. S. Department of the Treasury Passed through Montgomery County, Texas COVID-19 ? Emergency Rental Assistance Program Assistance Listing #: 21.023 Contract Number: CARES ERA Contract Year: 07/01/21 ? 06/30/22 Recommendation: Community Assistance Center should establish written policies and procedures and provide training to its employees related to review and approval of all billings and reconciling between the client tracking system and the general ledger. Planned corrective action: The Board of Directors hired a new CEO in 2022. In addition, the CEO hired a new Director of Finance. The CEO and Director of Finance are working with the Board of Directors? Finance Committee to update policies and procedures to address these findings with a primary focus on revenue recognition and grant recording, tracking/reconciliation and reporting. Responsible officer: Chief Executive Officer, Jennifer Huffine Estimated completion date: June 8, 2023

View Audit 19985

Finding 21245 (2022-001)

None 2022

Harris County Hospital District

TX

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Finding Number: 2022-001 Management?s Corrective Action Plan: Management will review procedures regarding receipt accruals for purchase orders to ensure only amounts received are receipted into the system. Responsible Official: Kari McMichael, Vice President - Controller Estimated Completion Date: P...

Finding Number: 2022-001 Management?s Corrective Action Plan: Management will review procedures regarding receipt accruals for purchase orders to ensure only amounts received are receipted into the system. Responsible Official: Kari McMichael, Vice President - Controller Estimated Completion Date: Procedures will be reviewed and processes corrected by February 28, 2023.

View Audit 18927 Questioned Costs: $1

Finding 21241 (2022-001)

Significant Deficiency 2022

Arts Academy in the Woods

MI

Significant Deficiency Special Tests & Provisions

Finding Number: 2022-001 Condition: Payroll was paid to a contractor under prevailing wage provisions, but the required certified payrolls were not received from the contractor. Planned Corrective Action: The Academy will require certified payrolls to be provided for any future payroll paid under co...

Finding Number: 2022-001 Condition: Payroll was paid to a contractor under prevailing wage provisions, but the required certified payrolls were not received from the contractor. Planned Corrective Action: The Academy will require certified payrolls to be provided for any future payroll paid under construction contracts where federal funds are used to finance the expenditure. Contact person responsible for corrective action: Cynthia Schwark Anticipated Completion Date: 11/15/2022

View Audit 18655

Finding 21239 (2022-002)

None 2022

Rochester Academy Charter School

NY

Finding 2022-002 - Elementary and Secondary School Emergency Relief Fund (ESSER) - COVID-19 - Assistance Listing No. 84.425D and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) - COVID-19 - Assistance Listing No. 84.425U Recommendation: The School should ensure th...

Finding 2022-002 - Elementary and Secondary School Emergency Relief Fund (ESSER) - COVID-19 - Assistance Listing No. 84.425D and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) - COVID-19 - Assistance Listing No. 84.425U Recommendation: The School should ensure that all federally funded construction contracts over $2,000 should include the required provision to follow the Act and the School should ensure that the contractors are following the regulations and paying proper wages. Action Taken: Details of the process and action plan explained above still applies to here. In addition to securing future processes if Federal Grant is used; the School will ensure that all future federally funded construction contracts over $2,000 will include the required provision to follow the Act. The Business Administrator will monitor the contractors involved in any future contracts to ensure that they are complying with wage requirements. The CEO will monitor the Business Administrator and ensure this is occurring.

View Audit 23415

Finding 21237 (2022-001)

Material Weakness 2022

Rochester Academy Charter School

NY

Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2022-001 - Elementary and Secondary School Emergency Relief Fund (ESSER)- COVID-19 - Assistance Listing No. 84.425D and American Rescue Plan - Elementary and Secondary School Emergency Relief(ARP ESSER) - COVID-19 -Assistance Listing No. 84.425U Recommendation: The School should ensure that ...

Finding 2022-001 - Elementary and Secondary School Emergency Relief Fund (ESSER)- COVID-19 - Assistance Listing No. 84.425D and American Rescue Plan - Elementary and Secondary School Emergency Relief(ARP ESSER) - COVID-19 -Assistance Listing No. 84.425U Recommendation: The School should ensure that processes are in place to require contractors and subcontractors to comply with the Act, including proper provisions in any construction contracts over $2,000. The School should also require documentation that the contractors are following the regulations and paying proper wages and the School should review and confirm that the contractors are compliant. Action Taken: In regard to the ESSER II Grant finding; the school signed a contract without a prevailing wage requirement with the best bidder and the school used its general funds to pay the contractor for its labor-related charges which are generally allowed for the charter schools. The total project cost is $1,433,266 of which only $277,174 is paid using the Federal ESSER II Grant. The cost of the materials for this project is a minimum $372,377(See Document#1). The remaining amount of the cost is a combination of the materials and the labor costs. The school's intention was to use ESSER II funds to pay for materials only. The school will contact its NYSED ESSER Agency to find out if this finding can be removed based on the aforementioned clarification. In regard to the ESSER III Grant finding; the school signed a contract without a prevailing wage requirement with the best bidder and the school used its general funds to pay the contractor for its labor related charges except the labor cost of $22,400 (See Document#2). The total project cost as of 6-30-2022 is $1,981,026 of which $757,400 is from the Federal ESSER III Grant. The school paid $735,000 for materials only. The remaining $22,400 was paid for the labor. We will contact NYSED ESSER Agency to amend the Federal Grant to remove payment for labor and replace it with materials because the total cost for materials only is more $757,400. As a result of the amendment, all of the Federal Funds will be used for covering materials cost only. The school still improve its current procedures to align with the federal requirements for future projects if Federal Grant will be used for the construction wages. The school will educate the Business Administrator, CEO and the Finance Committee on the requirements of the Davis-Bacon Act. The school will add the requirement to its federal procurement policy and procedures. The school will also add this requirement to its bid proposal for any future federally funded construction contracts in excess of $2,000. The finance committee will review and approve any future federally funded construction contracts over $2,000 so that they can ensure the proper verbiage is included. The Business Administrator will monitor the contractors involved to ensure that they are complying with wage requirements. The CEO will monitor the Business Administrator and ensure this is occurring. See Corrective Action Plan for chart/table.

View Audit 23415

Finding 21235 (2022-001)

Significant Deficiency 2022

Southwestern Illinois College Community College District #522

IL

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-001 Higher Education Emergency Relief Fund ? CFDA No. 84.425E; 84.425F Recommendation: We recommend that the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Explanation of disagreement with audi...

2022-001 Higher Education Emergency Relief Fund ? CFDA No. 84.425E; 84.425F Recommendation: We recommend that the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of audit finding and 2022-001, the College implemented a process that includes formalized review and approval of drawdowns of federal awards. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/23

View Audit 23196

Finding 21234 (2022-002)

None 2022

The Shire, Inc.

MD

Reporting

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all EIV system compliance requirements. Action Taken: The Shire, Inc. did not retain EIV information because in their opinion they had more current and detailed information on clients' fina...

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all EIV system compliance requirements. Action Taken: The Shire, Inc. did not retain EIV information because in their opinion they had more current and detailed information on clients' financial status than EIV provided; however, The Shire, Inc. will retain the EIV information in the tenant file as required.

View Audit 18513

Finding 21233 (2022-001)

Material Weakness 2022

The Shire, Inc.

MD

Questioned Costs HUD Housing Programs Reporting

Recommendation: In conjunction with The Shire, Inc. and their local HUD field office, it was determined that the related party should invoice the Organization for project expenses on a monthly basis. In turn,The Shire, Inc. should pay the invoice amount on a monthly basis. Action Taken: The auditor...

Recommendation: In conjunction with The Shire, Inc. and their local HUD field office, it was determined that the related party should invoice the Organization for project expenses on a monthly basis. In turn,The Shire, Inc. should pay the invoice amount on a monthly basis. Action Taken: The auditors have worked with the auditee in conjunction with their local HUD field office to determine a course of action. All parties agreed with the recommendation to avoid unauthorized distributions.

View Audit 18513 Questioned Costs: $1

Finding 21232 (2022-001)

Significant Deficiency 2022

Independent School District No. 831

MN

Internal Control / Segregation of Duties Special Tests & Provisions Significant Deficiency

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION ? COVID-19 ? EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-001 Internal Control Over Compliance With Special Tests and Provisions Requirements Finding Summary 47 CFR ? 54.1711 require...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION ? COVID-19 ? EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-001 Internal Control Over Compliance With Special Tests and Provisions Requirements Finding Summary 47 CFR ? 54.1711 requires that Independent School District No. 831 (the District) only seek support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. The District did not have sufficient controls in place within its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. Corrective Action Plan Actions Planned ? The District will review its procedures relating to special tests and provisions requirements specifically relating to eligible equipment for which the District could seek reimbursement to ensure compliance in the future with any additional federal awards. Official Responsible ? Chrissy Rehnberg-Eide, Director of Business Services. Planned Completion Date ? April 30, 2023. Disagreement With or Explanation of Finding ? The District is in agreement with this finding. Plan to Monitor ? The District?s Director of Business Services will ensure appropriate controls are in place to verify the District?s compliance with federal special tests and provisions requirements.

View Audit 23248

Finding 21231 (2022-003)

Material Weakness 2022

Purdue University

IN

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

2022-003 Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Condition The University did not properly design or implement an effective internal control system to ensure HEERF reports were properly completed and posted....

2022-003 Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Condition The University did not properly design or implement an effective internal control system to ensure HEERF reports were properly completed and posted. Views of Responsible Officials and Planned Corrective Actions PFW Contact Person Responsible for Corrective Action: Ron Herrell, Director of Financial Aid Contact Phone Number: 260-481-6242 The PFW Office of Financial Aid Director will complete the quarterly reports and a dual review process will be implemented to ensure accuracy. The quarterly report will be updated on the HEERF site and sent to the Assistant Director of Enrollment and Institutional Scholarships to post. The information posted will be compared to the reports submitted quarterly. Anticipated Completion Date: February 2023 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently. PNW Contact Person Responsible for Corrective Action: Michael Biel, Executive Director of Financial Aid Contact Phone Number: 219-989-2510 PNW acknowledges that, while it had the appropriate Institutional HERF reporting completed, they missed updating the required student portion questions and answers that get posted to the reporting webpage. Once that was discovered, it was corrected in April 2022. PNW has ensured that the process now identifies looking at both the combined (updated) reporting PDF and the questions and answers that are required to be posted to the reporting webpage. PNW has spent all of its HEERF funding and no further reporting except the final annual report should be required. Completion Date: April 2022 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

View Audit 18358

Finding 21230 (2022-002)

Significant Deficiency 2022

Purdue University

IN

Procurement, Suspension & Debarment Reporting Significant Deficiency § 200.303

2022-002 Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Condition The Purdue Fort Wayne campus did not have adequate controls in place to ensure invoices related to technology services were properly recorded in acc...

2022-002 Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Condition The Purdue Fort Wayne campus did not have adequate controls in place to ensure invoices related to technology services were properly recorded in accordance with GAAP. Views of Responsible Officials and Planned Corrective Actions Contact Person Responsible for Corrective Action: Glen Nakata, Vice Chancellor for Financial and Administrative Affairs Contact Phone Number: 260-481-4199 The University system, including the Purdue Fort Wayne (PFW) Campus, has internal controls and training in place related to non-catalog purchases and the review of Goods Receipt/Invoice Receipt (GRIR) discrepancies. In the case of these two purchase orders, it appears these were isolated instances where established controls were not fully implemented as designed. These processes will be covered in staff meetings on all campuses and Procurement Services will review and update non-catalog order instructions and GRIR report documentation to ensure clear guidance is given. Anticipated Completion: March 2023 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

View Audit 18358

Finding 21227 (2022-001)

Significant Deficiency 2022

Purdue University

IN

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

2022-001 Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Condition Special Tests and Provisions - Return of Title IV Fu...

2022-001 Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with the requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Views of Responsible Officials and Corrective Action Plan Contact Person Responsible for Corrective Action: Ron Herrell, Director of Financial Aid Contact Phone Number: 260-481-6242 The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window. Anticipated Completion Date: December 2022 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

View Audit 18358

Finding 21223 (2022-004)

Significant Deficiency 2022

Purdue University

IN

Reporting Significant Deficiency § 200.510

2022-004 Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Condition Purdue did not have adequate controls in ...

2022-004 Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Views of Responsible Officials and Planned Corrective Actions Contact Person Responsible for Corrective Action: Susan Corwin, Purdue West Lafayette Director of Post Award Contact Phone Number: 765-494-1052 ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created. Anticipated Completion Date: Monthly report review will start February 2023, Annual report review will start in May 2023 prior to the preliminary SEFA creation. Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

View Audit 18358

Finding 21222 (2022-003)

Significant Deficiency 2022

Hamilton Community Schools

IN

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

FINDING 2022-003 Subject: Special Education Cluster - Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). The School Corporation did not have adequate internal controls in place to e...

FINDING 2022-003 Subject: Special Education Cluster - Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). The School Corporation did not have adequate internal controls in place to ensure that the Cooperative complied with the earmarking requirements. Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for 19611-042-PN01 and 20611-042-PN01 grant awards could not be verified for the individual schools to verify the minimum amount per the grant awards was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirements for the 19611-042-PN01 and 20611-042-PN01 grant awards were $1,095 and $1,791, respectively. The lack of internal controls and noncompliance were isolated to the 19611-042-PN01 and 20611-042-PN01 grant awards. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Hamilton Community Schools will work with the Northeast Indiana Special Education Cooperative to ensure proper oversight and internal controls are maintained of awarded monies. Responsible Party and Timeline for Completion: Brittany Taylor, Business Manager Completion Date: 6/30/2023

View Audit 57985

Finding 21219 (2022-002)

Material Weakness 2022

Allamakee Community School District

IA

Reporting

We will continue to review our procedures and implement additional controls where possible.

View Audit 18074

Finding 21218 (2022-001)

None 2022

Cooperative for Assistance and Relief Everywhere, Inc. (care)

GA

Subrecipient Monitoring Reporting § 200.170

Corrective Action Plan Finding no 2022-001 CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on fede...

Corrective Action Plan Finding no 2022-001 CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on federal awards, including subaward activities, be made available to the public through a website maintained by the Office of Management and Budget (OMB). Application and Requirements FFATA applies to all US Government (USG) grants, cooperative agreements and contracts managed by CARE as the prime recipient. Under FFATA, CARE must report any subgrant greater than or equal to $30,000 and any subsequent obligation increase through the FSRS.gov website by the end of the month following the month of the subaward. Compliance Issues Identified as part of the FY2022 Audit Based on the finding in the FY21 Single Audit corrective actions were implemented in FY22. The delays identified in the FY22 Single Audit occurred in the first six months of the fiscal year, before planned FY22 corrective actions were fully implemented. Root Causes The root causes for the delay in reporting the partner organizations (i.e., subrecipients) information with whom CARE works with is as follows: ? Failure by the partner organization to timely adhere to the FFATA requirements delineated in the partner funding agreement (PFA). ? Delay in and confusion by the partner about registering the organization in SAM.gov (a USG database) and system difficulties in obtaining a Unique Entity Identifier Number (UEI), through SAM.gov. Recommended Solutions by CARE Management Team by June 30, 2023 1. Award Management Solutions (AMS) team will: a. Issue additional guidance and notification to all CARE business units involved with FFATA compliance. b. Deliver refresher training for all CARE country offices and HQ units involved with FFATA compliance. c. Complete the terms of reference and initiate the development of an award management platform for COs and HQ units to manage the donor compliance reporting and administration across the organization. 2. CARE will implement preventative controls to reduce the risk of future non-compliance, including: a. Ensure that partners are aware of SAM.gov registration at the proposal development stage; require partners to submit the completed FFATA form before full execution of the PFAs and PFA modifications; and include the completed FFATA form in the approval process. b. AMS will review the PFA templates to include partner DUNS/UEIN and assign a field for a PFA reference number. c. SSC to modify the Project ID (PID) set-up form to include a DUNS/UEIN. d. SSC will strictly enforce the submission of the FFATA collection form before setting up a new PID for USG PFAs and for PFA obligation increases. SSC will continuously monitor for compliance and notify the CARE Country Director of non-compliance instances, copying in the Regional Director (HQ Technical Director for non-CARE USA COs), VP IPO (or VP Program Strategy & Impact) the CFO and the AVP AMS. A Key Performance Indicator (KPI) on donor reporting timeliness will be included on the Country Director KPI dashboard. Repeated instances of non-compliance will be considered a personnel performance issue with the CARE Country Director or a contractual performance issue with the non-CARE USA CO. 3. SSC will monitor: (i) first tier partner funding spending against obligation under USG awards to anticipate potential modifications; (ii) USG awards spending and set-up in the system; and (iii) the completeness of USG awards and PFA documents. SSC will provide a monitoring report to AMS. AMS will spot check the report and provide a response to SSC on non-compliance issues identified and recommended corrective actions. AMS will escalate concerns on gaps identified to the CFO. Responsible Contact: ? Jason Zeno, CARE USA, AVP Grants, Contracts & Donor Compliance, email: jason.zeno@care.org

View Audit 17958

Finding 21209 (2022-003)

Significant Deficiency 2022

Career and Recovery Resources, Inc.

TX

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303

2022-003 Compliance and Internal Controls over Allowable Costs and Earmarking (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, A Supportive Services for Veteran Families ? Shallow Subsidy, and COVID ? 19 VA Supportive Services for Veteran Famili...

2022-003 Compliance and Internal Controls over Allowable Costs and Earmarking (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, A Supportive Services for Veteran Families ? Shallow Subsidy, and COVID ? 19 VA Supportive Services for Veteran Families 2020-2021 and 2021-2022 Funding U.S. Department of Veteran Affairs Recommendation: The Agency should establish and follow an allowable indirect allocation policy based on identifiable measures. The indirect costs charged to the grant can be substantiated by actual costs incurred. Corrective Action: Management will ensure the indirect allocation policy is correct, and actual and allowable costs will substantiate the indirect charge to grants. Responsible Party: Controller and Chief Operating Officer Date Expected to be Corrected: Immediately

View Audit 23531 Questioned Costs: $1

Finding 21202 (2022-003)

Significant Deficiency 2022

Feeding South Dakota

SD

Internal Control / Segregation of Duties Eligibility Significant Deficiency § 200.303

Finding 2022-003 Federal Agency Name: Department of Agriculture Passed through State of South Dakota Department of Education Program Name: Emergency Food Assistance Program (TEFAP) CFDA # 10.569 Finding Summary: One instance in which Emergency Food Assistance Program (TEFAP) food commodities wer...

Finding 2022-003 Federal Agency Name: Department of Agriculture Passed through State of South Dakota Department of Education Program Name: Emergency Food Assistance Program (TEFAP) CFDA # 10.569 Finding Summary: One instance in which Emergency Food Assistance Program (TEFAP) food commodities were distributed to a non-approved TEFAP agency. There was no agency agreement signed on file at that time. Responsible Individuals: Matthew Burn, Chief Operations Officer Corrective Action Plan: Internal controls have been revised to include validation of agency as a TEFAP certified agency while orders are picked. As well as additional training and updated standard operating procedures.

View Audit 23414

Finding 21197 (2022-002)

Significant Deficiency 2022

Feeding South Dakota

SD

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management § 200.303

Finding 2022-002 Federal Agency Name: Department of Agriculture Passed through State of South Dakota Department of Education Program Name: Emergency Food Assistance Program (TEFAP) CFDA# 10.568,10.569 Finding Summary: Emergency Food Assistance Program (TEFAP) pounds distributed to passthrough ag...

Finding 2022-002 Federal Agency Name: Department of Agriculture Passed through State of South Dakota Department of Education Program Name: Emergency Food Assistance Program (TEFAP) CFDA# 10.568,10.569 Finding Summary: Emergency Food Assistance Program (TEFAP) pounds distributed to passthrough agencies didn't agree to underlying inventory reports. This resulted in monthly draw requests to be misstated. Responsible Individuals: Christy Carr, Chief Financial Officer Corrective Action Plan: Internal controls have been revised to include additional cross referencing of distributions reporting. As well as additional training for employees involved in the process and updated standard operating procedures.

View Audit 23414

Finding 21196 (2022-002)

Significant Deficiency 2022

Maine Maritime Academy

ME

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2022-002: Education Stabilization Fund, COVID-19 ? Higher Education Emergency Relief Fund Institutional Portion ? Earmarking Name of Contact Person: Richard Rosen, Vice President for Financial and Institutional Services Corrective Action Plan: The Academy will review the earmarking requ...

Finding 2022-002: Education Stabilization Fund, COVID-19 ? Higher Education Emergency Relief Fund Institutional Portion ? Earmarking Name of Contact Person: Richard Rosen, Vice President for Financial and Institutional Services Corrective Action Plan: The Academy will review the earmarking requirements, document the Academy?s reasoning for allocation of the funds, and follow-up with the U.S. Department of Education to ensure that the Academy is complying with the applicable provisions of the award. Planned Completion Date: September 2023

View Audit 23362

Finding 21184 (2022-002)

None 2022

Roland-Story Community School District

IA

The District has a procurement policy, but has not had sufficient time to develop the additional required written policies.

View Audit 23247

Corrective Action Plans

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