Corrective Action Plans

Finding 38147 (2022-006)

Material Weakness 2022

PR

HUD Housing Programs Material Weakness Reporting

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

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

View Audit 33033

Finding 38146 (2022-005)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

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

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

View Audit 33033

Finding 38145 (2022-004)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

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

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

View Audit 33033

Finding 38141 (2022-007)

Material Weakness 2022

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Material Weakness

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

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

View Audit 33033

Finding 38139 (2022-008)

Significant Deficiency 2022

Autonomous Municipality of Ponce

PR

Reporting Significant Deficiency Internal Control / Segregation of Duties

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

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

View Audit 33033

Finding 38134 (2022-001)

Material Weakness 2022

Morgan Hill Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Material Weakness

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

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

View Audit 31378

Finding 38126 (2022-006)

None 2022

Gratz College

PA

Cash Management

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

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

View Audit 36033

Finding 38125 (2022-005)

Significant Deficiency 2022

Gratz College

PA

Cash Management Procurement, Suspension & Debarment Significant Deficiency

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

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

View Audit 36033

Finding 38124 (2022-004)

Material Weakness 2022

Gratz College

PA

Questioned Costs

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

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

View Audit 36033 Questioned Costs: $1

Finding 38123 (2022-003)

None 2022

Gratz College

PA

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

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

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

View Audit 36033

Finding 38122 (2022-002)

None 2022

Gratz College

PA

Reporting

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

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

View Audit 36033

Finding 38121 (2022-001)

Material Weakness 2022

Gratz College

PA

Material Weakness Reporting Internal Control / Segregation of Duties

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

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

View Audit 36033

Finding 38115 (2022-002)

Significant Deficiency 2022

Crazy Horse School

SD

Reporting Internal Control / Segregation of Duties HUD Housing Programs

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

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

View Audit 35706

Finding 38114 (2022-002)

None 2022

The Havens, Inc.

NC

HUD Housing Programs

Corrective Action Plan: The work on the grounds was in progress at the time of the inspection and was finished shortly thereafter (14.96 points). Quality Sprinkler was called to replace the ring on the sprinkler head immediately (10 points). Auditee Contact: Mickie Helms (Citywide Realty Servic...

Corrective Action Plan: The work on the grounds was in progress at the time of the inspection and was finished shortly thereafter (14.96 points). Quality Sprinkler was called to replace the ring on the sprinkler head immediately (10 points). Auditee Contact: Mickie Helms (Citywide Realty Services, Inc.), Management Agent

View Audit 35349

Finding 38113 (2022-001)

Material Weakness 2022

The Havens, Inc.

NC

HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Plan: Due to cost restraints, the Organization will not hire any additional staff. The Organization will continue to rely on compensating controls in place. ...

Corrective Action Plan: Due to cost restraints, the Organization will not hire any additional staff. The Organization will continue to rely on compensating controls in place. Auditee Contact: Mickie Helms (Citywide Realty Services, Inc.), Management Agent

View Audit 35349

Finding 38109 (2022-001)

Significant Deficiency 2022

Town of Evansville

WY

Internal Control / Segregation of Duties

This letter is in response to finding 2022-001 Federal Awards 2022-001 Preparation of the Financial Statements. We have separated duties to the largest extent as possible and have implemented compensating controls to monitor the accounting activities. Chad Edwards Mayor Town of Evansville, Wyoming

View Audit 35348

Finding 38102 (2022-002)

Material Weakness 2022

Boscobel Area School District

WI

Questioned Costs Procurement, Suspension & Debarment Cash Management

Finding #2022-002 ? #84.425D COVID-19 Education Stabilization Fund ? ESSER II and III Condition: There was one Education Stabilization Fund construction project performed by a contractor. Grant expenditures for the project totaled $170,924.50. There was not a prevailing wage clause in the contract ...

Finding #2022-002 ? #84.425D COVID-19 Education Stabilization Fund ? ESSER II and III Condition: There was one Education Stabilization Fund construction project performed by a contractor. Grant expenditures for the project totaled $170,924.50. There was not a prevailing wage clause in the contract and certified payrolls were received. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Questioned Costs: $170,924.50. Context: The construction projects began and were completed in June 2022 before the District was aware of wage rate requirements. After becoming aware of the requirement, there were no further construction projects. Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Consider determining if the contractor performing the project in 2021-2022 paid prevailing wage rates for costs reimbursed by the grant. Response: The District became aware of wage rate requirements after finishing the project. Before bidding any future construction project more than $2,000, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received for any such contracts. Anticipated Completion: June 30, 2023

View Audit 35345 Questioned Costs: $1

Finding 38099 (2022-001)

Significant Deficiency 2022

Boscobel Area School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding #2022-001 ? Limited Segregation of Duties (Prior Year Finding #2021-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detect...

Finding #2022-001 ? Limited Segregation of Duties (Prior Year Finding #2021-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district?s operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is performed by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information on a monthly basis. Contact Person: Lisa Wallin-Kapinus Anticipated Completion: Not Applicable

View Audit 35345

Finding 38097 (2022-002)

Significant Deficiency 2022

Albion College

MI

Cash Management Reporting Significant Deficiency § 200.305

Finding Number: 2022-002 Condition: The College drew down HEERF related expenses for the institutional expenditures at a rate that differed from the final, reported expenditures. This was based on the identification of expenditures that were later not included in the final annual reporting, placing ...

Finding Number: 2022-002 Condition: The College drew down HEERF related expenses for the institutional expenditures at a rate that differed from the final, reported expenditures. This was based on the identification of expenditures that were later not included in the final annual reporting, placing the timing of drawdown for reported expenditures to be outside of the cash management regulations. By extension, the institutional quarterly reporting was also incorrect as it is based on the initial expenditure classifications. Planned Corrective Action: The College drew down funds based on expenditures that management deemed to be qualified however, at year-end, concluded to charge other expenditures to the grant causing the mismatch in the timing of drawdowns and final expenditures charged to the grant. Although HEERF and other COVID 19 Pandemic funding has ended, in the future, such expenditures will be discussed and documented prior to the drawing of funds. Contact person responsible for corrective action: Amanda Ewers, Director of Finance and Gary Black, Chief Financial Officer Anticipated Completion Date: Corrected reporting was submitted on March 22, 2023

View Audit 35343

Finding 38096 (2022-001)

Material Weakness 2022

Albion College

MI

Procurement, Suspension & Debarment § 200.212 § 200.318

Finding Number: 2022-001 Condition: The College did not have a policy in place to ensure it was complying with "Never Contract with the Enemy" and verifying that a contractor is not debarred, suspended, or otherwise excluded from doing business with federal assistance programs or activities. In addi...

Finding Number: 2022-001 Condition: The College did not have a policy in place to ensure it was complying with "Never Contract with the Enemy" and verifying that a contractor is not debarred, suspended, or otherwise excluded from doing business with federal assistance programs or activities. In addition, the College's policy does not include all provisions in 2 CFR Section 200.318-327. Planned Corrective Action: An Albion College ?Never Contract with the Enemy? policy will be put into place and have the following conditions within the policy: The ?Grants and Foundation Relations Grants Manual? will be updated to include policy information about this federal regulation and how to determine whether a subcontractor/vendor is prohibited under this policy from being paid with federal grant funds. The Grants and Foundation Relations team (?GFRT?) will include the federal regulation in every ?Grants Kickoff Meeting? checklist and will discuss with the Principal Investigators (?PI?s) during grant development so that issues can be addressed at the beginning of federal grant application process. PI?s of the federal grants will be responsible for checking the SAM excluded vendor list as they are finalizing their budget and/or planned expenditures to confirm all subcontractors/vendors are allowed and in good standing, before any contract over $50,000 is executed or any invoice greater than $20,000 is paid. The Business Office will verify that the vendors or subcontractors for federal grants have been checked against the SAM excluded vendor list during the expenditure approval process. In addition, the College with develop a procurement policy that conforms to provisions in 2 CFR Section 200.318-327 and all federal grant recipients should review and adhere to that policy for all purchases and expenditures made with federal grant funds. Consult with GFR or the Business Office if there are questions about these standards and how they may impact federal grant expenditures. Contact person responsible for corrective action: Amy Routhier-Chief Advancement Officer for Grants and Foundation Relations & Albert Hammond-Staff Accountant-Gifts and Grants Anticipated Completion Date: The GFRT has added a ?Never Contracts with the Enemy Policy? to the Grant Manual, which is presented at all ?Grant Kickoff? meetings. The team also discusses with each (?PI?) in grant development what the policy expectations are.

View Audit 35343

Finding 38089 (2022-002)

None 2022

City of Yreka

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Program Income

2022-002 Community Development Block Grants/State?s Program and Non-Entitlement Grants in Hawaii We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management?s Re...

2022-002 Community Development Block Grants/State?s Program and Non-Entitlement Grants in Hawaii We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management?s Response: Finance was unaware of the need to have current utility bills included with the files. Responsible Individual: It is the Finance Director?s, Emily Aldrich, responsibility to ensure that all loan files are complete and accurate. Corrective Action Plan: An annual checklist has been added to each loan file to ensure that all proper documentation is included. Anticipated Completion Date: March 31, 2023 ? all files will be updated with the necessary checklist and appropriate documentation.

View Audit 32485

Finding 38087 (2022-001)

None 2022

City of Yreka

CA

Reporting

2022-001 Water and Waste Disposal Systems for Rural Communities/Community Development Block Grants/State?s Program and Non-Entitlement Grants in Hawaii We recommend that the City reconcile federal expenditures claimed to the City?s general ledger and SEFA. Management?s Response: The Municipal Proj...

2022-001 Water and Waste Disposal Systems for Rural Communities/Community Development Block Grants/State?s Program and Non-Entitlement Grants in Hawaii We recommend that the City reconcile federal expenditures claimed to the City?s general ledger and SEFA. Management?s Response: The Municipal Projects Manager retains and holds all grant related documents. They create and submit the requests for reimbursements. Finance did not timely reconcile the variance of the general ledger with the Grant Manager?s Life-to-Date Spreadsheet of Expenditures. Responsible Individual: It is the Finance Director?s, Emily Aldrich, responsibility to ensure that all schedules provided to the auditor reconcile with the general ledger. Corrective Action Plan: The Finance Department has added two new positions of Staff Accountants. They have been charged with the responsibility of working with Public Works project managers to ensure complete and accurate reconciliation of the SEFA and general ledger on a routine basis. Anticipated Completion Date: Employees have been hired and are in the process of being trained on how to reconcile the schedule to the general ledger.

View Audit 32485

Finding 38076 (2022-003)

Significant Deficiency 2022

West Perry School District

PA

Procurement, Suspension & Debarment § 200.318 § 200.320

2022-003 - Procurement Corrective Action Planned: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget., its own existing Board Policies, and has developed administrative procedures to aid with ensuring that all procurements financed with federa...

2022-003 - Procurement Corrective Action Planned: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget., its own existing Board Policies, and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement methods. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year . Contact Person Responsible: Kenneth L. Medina, MBA, Business Manager/Board Secretary

View Audit 28774

Finding 38075 (2022-002)

Significant Deficiency 2022

West Perry School District

PA

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management

2022-002 - Cash Management and Reporting Corrective Action Planned: In December 2022, the District did review and enforce existing Board Policies and procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods a...

2022-002 - Cash Management and Reporting Corrective Action Planned: In December 2022, the District did review and enforce existing Board Policies and procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods and that they are based upon properly reconciled factual information. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year and is working through February 2023 to complete all incomplete reports. Contact Person Responsible: Kenneth L. Medina, MBA, Business Manager/Board Secretary

View Audit 28774

Finding 38074 (2022-001)

Significant Deficiency 2022

School District of Milton

WI

Questioned Costs Subrecipient Monitoring Cash Management

Finding #2022-001: #84.425U COVID-19 ? Education Stabilization Fund ? ESSER III Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-533612-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Criteria: Wage rate requirements apply...

Finding #2022-001: #84.425U COVID-19 ? Education Stabilization Fund ? ESSER III Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-533612-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by Education Stabilization Fund totaled $424,000. There was not a prevailing wage clause in the contract and certified payrolls were not received. Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $424,000. Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Consider determining if the contractor performing the project in 2021-2022 paid prevailing wage rates for costs reimbursed by the grant. Grantee Response:At the time that we committed to doing this project, we informed our referendum construction manager that we would be using federal funds to pay for this additional work. With us informing them of that, we assumed that all required paperwork would be completed to comply with the Davis-Bacon Act. Unfortunately, we thought this was sufficient notification for them to support us with compliance. In our follow-up communications with our primary HV AC subcontractor we learned at the time when referendum work was contracted in 2019, they were paying prevailing wage. We worked with legal counsel to develop a contract that is compliant with the Davis-Bacon Requirements. To make sure the paperwork is in place copies of such contracts will be sent to the business office before work commences as well as the compliance documentation when work is complete. We are also conducting a review of our written procedures to be completed by June 30, 2023. Contact Person: Carey Bradley Anticipated Completion: June 30, 2023

View Audit 29683 Questioned Costs: $1

Corrective Action Plans

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