Corrective Action Plans

Finding 36607 (2022-010)

Significant Deficiency 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.332

2022-010 Improve Controls over Subrecipient Monitoring Federal Agency: U.S. Department of Education State Entity: Department of Education (GaDOE) Corrective Action Plans: We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently perform...

2022-010 Improve Controls over Subrecipient Monitoring Federal Agency: U.S. Department of Education State Entity: Department of Education (GaDOE) Corrective Action Plans: We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs local educational agency (LEA) audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st Century Community Learning Centers (CCLC) Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators. Estimated Completion Date: June 30, 2023 Contact Person: Metsehet Ketsela, Assistant Director Telephone: 678-472-7898; E-mail: metsehet.ketsela@doe.k12.ga.us

View Audit 26105

Finding 36606 (2022-031)

Significant Deficiency 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

2022-031 Continue to Improve Internal Controls over Federal Financial Reporting Federal Agency: U.S. Department of the Treasury State Entity: Office of the Governor Corrective Action Plans: The Office of Planning and Budget shall maintain written documentation showing independent review and approv...

2022-031 Continue to Improve Internal Controls over Federal Financial Reporting Federal Agency: U.S. Department of the Treasury State Entity: Office of the Governor Corrective Action Plans: The Office of Planning and Budget shall maintain written documentation showing independent review and approval of data entered for reporting prior to submission of all federal reports. Estimated Completion Date: March 31, 2022 Contact Person: Stephanie Beck, Deputy Director Telephone: 678-245-0675; E-mail: stephanie.beck@opb.georgia.gov

View Audit 26105

Finding 36600 (2022-032)

Material Weakness 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303 § 200.53

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Em...

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

View Audit 26105

Finding 36599 (2022-030)

Material Weakness 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303 § 200.511 § 200.514

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and...

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and Economic Security Act (CARES Act) matters, impediments such as limited workforce and system restrictions hindered progress. Such factors, imposed upon the intents to make system changes, corrections and enhancements. We have taken the following corrective actions in an ongoing effort to bring these findings to full resolution: 2020- 036 Improve Controls Over Eligibility Determinations In addition to steadily reviewing and determining eligibility of responses providing proof of Pandemic Unemployment Assistance (PUA) employment and wages, a task force has been established to assist with this effort. An ongoing campaign is in progress to onboard additional resources to increase the cadence of addressing these items. Claimants who fail to provide adequate proof are manually reconsidered and overpayments established appropriately. Since this process is manually reviewed by staff rather than by system automation, we anticipate this effort will take approximately 60 weeks to complete. When there are indications of potential fraud, additional investigation is pursued to determine if fraud penalties should be imposed. 2021-036 ? Improve Controls over Employer-Filed Claims Effective December 6, 2021, the Employer-Filed Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Summary We are currently seeking funding to modernize our UI benefits system which will incorporate and improve the controls cited. GDOL will develop and implement procedures to ensure the status of each prior audit finding is reported in an accurate manner. GDOL will ensure staff responsible for submitting the status of prior period audit findings are trained and understand their responsibilities associated with the Summary Schedule of Prior Audit Findings under the Uniform Guidance. Estimated Completion Date: December 6, 2021 Contact Person: Racquel Robinson, Unemployment Policy and Procedures Chief Telephone: 404-232-3190; E-mail: Racquel.Robinson@gdol.ga.gov

View Audit 26105

Finding 36598 (2022-029)

Material Weakness 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Reporting Special Tests & Provisions Subrecipient Monitoring § 200.303

2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recordin...

2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: The Georgia Department of Labor disagrees with this finding. USDOL provides guidance and recommended procedures for crossmatches but does not dictate a frequency or cadence for performing them. The crossmatch process is conducted using third party software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. The audit report indicates misinterpretation of the data reflected on the federal reports, specifically the ETA 227. The ETA 227 is for reporting of overpayment detection and recovery activities that the Agency performed in a quarter. It is not for reporting the amount of benefits overpaid for specific weeks during that quarter. A federal reporting team was created to accurately identify and track overpayments. The Department is taking necessary actions to complete the overpayment reconciliation for the ETA 227 and 902 reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it would require multiple GDOL staffing levels to review all cross matches, requiring increased levels of state and federal funding. Summary GDOL has developed an aggressive plan to complete all remaining state and pandemic program cross matches. We have filled all of our budgeted positions for the Overpayment Unit and are utilizing non-overpayment staff to assist with identification and overpayment investigations. Additionally, we are utilizing temp agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. In early 2022, we started to freeze the overpayment data at the end of every month so that we can conduct periodic reconciliation of the overpayment records. GDOL is coordinating with USDOL to ensure the timely and accurate identification, tracking and reporting of overpayments. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: January 1, 2022 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

View Audit 26105

Finding 36597 (2022-028)

Material Weakness 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.53

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagre...

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

View Audit 26105 Questioned Costs: $1

Finding 36596 (2022-027)

Significant Deficiency 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

2022-027 Improve Controls over Administrative Expenditures Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The seven transactions related to utility bills for some local career centers did not have an approval signature from Regional Operat...

2022-027 Improve Controls over Administrative Expenditures Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The seven transactions related to utility bills for some local career centers did not have an approval signature from Regional Operations. Each was processed by line staff after being reviewed by a lead worker/manager in Accounts Payable to assure that the account numbers belonged to GDOL. The accounts were confirmed as longstanding accounts and the invoice amounts were reviewed to assure that they were in line with prior billings. These invoices are reviewed again at the end of the day the payment was processed to assure they were processed as appropriate. As stated, we had several regular billers redirect invoices directly to Financial Services in an attempt to avoid misdirected mail during the vestiges of the pandemic. We wanted to avoid the risk of creating adverse relations with any biller or have to use precious time dealing with penalties and fees being added to account balances or service terminations as a result of going beyond the standard payment window. These were standard billings for critically needed utility services that needed to continue uninterrupted. Currently, approval signatures are required on all invoices as was customary prior to the pandemic. Estimated Completion Date: March 15, 2023 Contact Person: John Williams, Accounting Director II Telephone: 404-232-3577; E-mail: john.williams@gdol.ga.gov

View Audit 26105

Finding 36594 (2022-026)

Significant Deficiency 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

2022-026 Improve Controls over Transparency Act Reporting Federal Agency: U.S. Department of Housing and Urban Development State Entity: Department of Community Affairs (DCA) Corrective Action Plans: Since the State audit, DCA has revised its processes and procedures related to the submission of th...

2022-026 Improve Controls over Transparency Act Reporting Federal Agency: U.S. Department of Housing and Urban Development State Entity: Department of Community Affairs (DCA) Corrective Action Plans: Since the State audit, DCA has revised its processes and procedures related to the submission of the Federal Funding Accountability and Transparency Act (FFATA) for all federal programs, including CDBG-DR and CDBG-MIT. These processes include a formal review and approval of the report by the Office Director and the Division Director prior to submission. Estimated Completion Date: February 3, 2023 Contact Person: Nina Gyasi, Financial Ops and Reporting Manager Telephone: 404-679-5820; E-mail: nina.gyasi@dca.ga.gov

View Audit 26105

Finding 36589 (2022-026)

Significant Deficiency 2022

State of Texas C/o Comptroller of Public Accounts

TX

Allowable Costs / Cost Principles Special Tests & Provisions Subrecipient Monitoring § 200.303

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff memb...

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff member has both roles assigned to ensure separation of duties in the system roles. We are also looking at potential technical solutions that would automate and prevent staff being assigned certain roles based on separation of duties. Implementation date(s): February 28,2023 Responsible Persons: Heather Hall, CIO

View Audit 28519

Finding 36588 (2022-016)

Significant Deficiency 2022

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: The OOG?s Public Safety Office (PSO) Performance and Records Coordinator staff position, which is the position responsible for submitting the FFATA reports into the federal reporting system, was vacant at the time the May 2022 report was due. This position is now filled and...

Corrective action plan: The OOG?s Public Safety Office (PSO) Performance and Records Coordinator staff position, which is the position responsible for submitting the FFATA reports into the federal reporting system, was vacant at the time the May 2022 report was due. This position is now filled and PSO updated the written policy and procedure to include additional staff positions that will prepare the FFATA report in the event the Coordinator is unavailable. In addition, the FFATA policy has been updated to include dates by which certain steps in the process should be met. See excerpt from revised PSO Policy 5.40 FFATA: ?FFATA Reports are prepared by the Grants Administration Performance and Records Coordinator and will be reviewed by the appropriate Program Manager(s). The Grants Administration Director will review and approve reports prior to submission in the FFATA Subaward Reporting System (FSRS). In the event the Performance and Records Coordinator is not available to prepare the FFATA reports, either the Grants Administration Business Operations Specialist or the Grants Administration Compliance and Operations Administrator will prepare and route the reports for review. On or about the 5th day of the month in which the report is due, the Performance and Records Coordinator, or backup, will pull new award data and grant adjustment data from eGrants. On or about the 10th day of the month in which the report is due, the Records and Performance Coordinator, or backup, will route the report to the appropriate Program Manager(s) for review. On or about the 15th day of the month the report will be routed to the Grants Administration Director for review and approval. Monthly reports will be prepared and submitted at https://www.fsrs.gov/ no later than the last day of the current month for awards made during the prior month.? Implementation date(s): The vacant Performance and Records Coordinator position was filled in July 2022. The FFATA policy was updated February 3, 2023. Responsible persons: Zach Lohbauer, Performance and Records Coordinator Angie Martin, Director of Grants Administration

View Audit 28519

Finding 36585 (2022-010)

Significant Deficiency 2022

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Allowable Costs / Cost Principles § 200.303

Corrective action plan: The formula error was identified, corrected and reallocations are now correct. Also, the outdated reallocation journal tool is no longer used. The new journal reallocation tool includes edits to identify discrepancies before a reallocation journal is posted. As an addition...

Corrective action plan: The formula error was identified, corrected and reallocations are now correct. Also, the outdated reallocation journal tool is no longer used. The new journal reallocation tool includes edits to identify discrepancies before a reallocation journal is posted. As an additional verification step, which began with March 2022 reallocations, a new verification report (Fund Source Allocation Compare Report) is run that compares the date the factor was updated to the date the reallocation journal was entered to ensure no changes have been made to the factor. HHSC Accounting will work with Chief Financial Officer (CFO) Operation Support to establish an automated process to strengthen existing verifications. Implementation date(s): August, 31, 2023 Responsible persons: Director, Funds Management

View Audit 28519 Questioned Costs: $1

Finding 36584 (2022-009)

Significant Deficiency 2022

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Corrective action plan: Texas Integrated Eligibility Redesign System (TIERS) - In order to bring password settings into compliance with the HHSC Information Security (IS) Security Policy, the TIERS Operations team released tool/method (113.0) successfully into production without any adverse impact. ...

Corrective action plan: Texas Integrated Eligibility Redesign System (TIERS) - In order to bring password settings into compliance with the HHSC Information Security (IS) Security Policy, the TIERS Operations team released tool/method (113.0) successfully into production without any adverse impact. This release was completed on 09/24/2022 and contained the security requirements to restrict minimum allowed password changes from zero (unlimited) to one meaning users are allowed "only" one password change a day. This was verified by CliftonLarsonAllen LLP (CLA) auditors on 12/21/22. Screenshots were also provided to CLA auditors. Implementation date(s): September 24, 2022 Responsible Persons: Director, Information Technology (IT) Infrastructure Services

View Audit 28519

Finding 36574 (2022-001)

None 2022

Greater Johnstown Area Vocational Technical School

PA

Cash Management Material Weakness

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: The Greater Johnstown Area Vocational Technical School currently has procedures in place for cash monitoring to ensure compliance with U.S. Department of Education Federal Student Aid guidelines which are similar to the...

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: The Greater Johnstown Area Vocational Technical School currently has procedures in place for cash monitoring to ensure compliance with U.S. Department of Education Federal Student Aid guidelines which are similar to the requirements for the HEERF funds. Due to unfamiliarity with the HEERF guidelines during the COVID-19 pandemic, these funds were drawn down in the G5 system earlier than needed. In the future, GJCTC will follow existing procedures to ensure compliance with cash management. Anticipated Completion Date: June 30, 2023.

View Audit 27025

Finding 36571 (2022-002)

None 2022

Greater Johnstown Area Vocational Technical School

PA

Allowable Costs / Cost Principles Reporting

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: Due to the retirement of Greater Johnstown Area Vocational Technical School?s long time business manager and the sudden resignation of the replacement, the audit was unable to be completed timely. Greater Johnstown Are...

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: Due to the retirement of Greater Johnstown Area Vocational Technical School?s long time business manager and the sudden resignation of the replacement, the audit was unable to be completed timely. Greater Johnstown Area Vocational Technical School currently has a business manager in place and is expected to file its audit timely beginning with the June 30, 2023, fiscal year ending. Anticipated Completion Date: November 30, 2023.

View Audit 27025

Finding 36570 (2022-004)

Significant Deficiency 2022

Springfield Metropolitan Housing Authority

OH

HUD Housing Programs

4. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation d. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Tenant Files Housing Choice Vouchers Move-ins: 1. In two (2) instances out of ten (10) tenant fil...

4. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation d. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Tenant Files Housing Choice Vouchers Move-ins: 1. In two (2) instances out of ten (10) tenant files tested, the date on the lease agreement did not agreement to the effective move-in date. 2. In six (6) instances out of ten (10) tenant files tested, the lease agreement was not maintained in the tenant's file. 3. In one (1) instance out of ten (10) tenant files tested, the lease agreement did not indicate the initial lease date or the rent amount. 4. In ten (10) instances out of ten (10) tenant files tested, the "Lease Addendum" - Violence Against Women and Justice Department Reauthorization Act of 2005, was not signed by the Landlord. 5. In four (4) instances out of ten (10) tenant files tested, the HAP Contract was not signed by the Owner. Tenant Files (continued) Move-Ins: 6. In three (3) instances out of ten (10) tenant files tested, the Tenancy Addendum was not maintained in the tenant's file. 7. In two (2) instances out of ten (10) tenant files tested, the Voucher expired prior to the issuance of the Request for Tenancy Approval. 8. In one (1) instance out of ten (10) tenant files tested, the "Reasonableness Valuation" form was not maintained in the tenant's file. 9. In one (1) instance out of ten (10) tenant files tested, the "Addition to Landlord and Tenant Lease" was not maintained in the tenant's file. Recertification: 1. In fifteen (15) instances out of twenty-five (25) tenant files selected for testing, that the notification of corrective actions was indicated to the Landlord, without indicating the number of days allowed for the correction. 2. In one (1) instance out of twenty-five (25) tenant files selected for testing, the annual recertification was not performed, during the 2022 fiscal year. 3. In one (1) instance out of twenty-four (24) tenant files selected for testing, the Authorization for the Release of Information (Form HUD-9886), was not dated by the tenant. Recertification: (continued) 4. In two (2) instances out of twenty-four (24) tenant files selected for testing, the annual income was not verified in accordance to ?Part III: Verifying Income and Assets ? 7-III.A. Earned Income?. 5. In four (4) instances out of twenty-four (24) tenant files selected for testing, the inspection report maintained in the tenant's file, indicated that the inspection failed and/or was inconclusive; therefore, no Pass inspection was obtained, prior to the tenant?s effective move-in date. Move-outs: 1. In four (4) out of five (5) tenant files, selected for test, there was no notice sent to the landlord, indicating the termination date. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that Springfield Metropolitan Housing Authority should 1) determines the rent reasonableness, prior to making a subsidy payment to the landlord; 2)obtain the tenant and landlord signature, prior to making a subsidy payment to the landlord; 3) obtain the lease-addendum ? violence against women form, prior to making a subsidy payment to the landlord; 4) The HAP should be signed by the tenant and the owner, prior to the tenant occupying the housing unit; 5) obtain the tenant?s signature and date on the authorization for release of information, prior to requesting household income information, and 6) Annual income should be verified by the PHA, prior to the tenant occupying the housing unit. By performing these procedures, the risk of incurring questioned costs will be significantly reduced. (2) Actions Taken on the Finding. Springfield MHA will review all files from this audit to make necessary corrections. SMHA will review and update policy to ensure all program requirements are met.

View Audit 23985

Finding 36569 (2022-003)

Significant Deficiency 2022

Springfield Metropolitan Housing Authority

OH

3. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation c. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Accounts Receivable - Tenants During the testing of accounts receivable tenants, there were twenty-two (22) ins...

3. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation c. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Accounts Receivable - Tenants During the testing of accounts receivable tenants, there were twenty-two (22) instances out of twenty-six (26) transactions tested, whereby, the tenant balance reported on the Resident Ledger did not agree with the tenant balance reported on the Aged Receivable Report as of September 30, 2022. As a result, the Aged Receivable report was overstated by $21,873. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that the receivable balance reported on the Resident Ledger should be reconciled to the balance reported on the Aged Receivable tenant report. Performing this procedure will reduce the risk of the Aged Receivable tenant report, being overstated. (2) Actions Taken on the Finding. Prior accounting management and staff have been removed. Accounts Receivable ? Tenants will be properly reconciled.

View Audit 23985

Finding 36568 (2022-002)

Significant Deficiency 2022

Springfield Metropolitan Housing Authority

OH

HUD Housing Programs Reporting Internal Control / Segregation of Duties

2. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation b. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Financial Statements The year-end financial statements generated from the general ledger, that were prepared an...

2. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation b. Finding 2022-002. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Financial Statements The year-end financial statements generated from the general ledger, that were prepared and presented for the audit contained inconsistencies, in comparison to the financial statements submitted to the Auditor of State, via the Hinkle Submission and the Entity Wide Balance Sheet and Entity Wide Revenue and Expense Summary, submitted via the Financial Assessment Subsystem. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that the Public Housing Authority should assess the adequacy of the design of its policies and procedures related to preparation of financial statements and the design appropriate controls as necessary to rectify inadequacies. Furthermore, the Public Housing Authority should consider where errors could occur that would cause a material misstatement in the financial statements and which policies or procedures would prevent or detect the error on a timely basis. (2) Actions Taken on the Finding. Contributing to differences between the system generated financial statements and the financial statements prepared by the Authority for distribution include balances in accounts that typically have a balance that would appear on the Liability side of the Statement of Net Position, but in any given year have a balance reported on the Asset side of the Statement of Net Position, an example being the OPEB Net Asset. Balances of grants of short duration that for grant reporting purposes are maintained cumulatively in the general ledger for which only period amounts are reported on the Statement of Revenues, Expenses, and Change in Net Position is also an example of what can cause such differences. It is unknown by current management of Springfield MHA when the mapping for the financial statements generated by the Authority's accounting software was done or last updated. The financial statements generated by the Authority's accounting software are for very limited use by management only. They are not and were not generated for publication and distribution. For audit, Springfield MHA prepares trial balance worksheets that document mapping to the unaudited Financial Data Schedule, and then the totals from the unaudited Financial Data Schedule as adjusted (if applicable) provide the basis for the Financial Statements prepared for financial reporting and distribution. In addition to considering any mapping changes needed to system generated financial statements in the Authority's accounting software, Springfield MHA will consider how to label the financial statements generated by the accounting software as For Management Use Only.

View Audit 23985

Finding 36567 (2022-001)

Significant Deficiency 2022

Springfield Metropolitan Housing Authority

OH

HUD Housing Programs Reporting

1. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation a. Finding 2022-001. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Bank Reconciliation The bank reconciliations performed as of September 30, 2022 were not reconciled to the gene...

1. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation a. Finding 2022-001. U.S. Department of Housing and Urban Development Housing Choice Voucher Cluster. Bank Reconciliation The bank reconciliations performed as of September 30, 2022 were not reconciled to the general ledger. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that bank reconciliations should be reconciled to the general ledger on a monthly basis and that transfers between programs should be recognized in the due to and due from accounts. Performing these procedures will reduce the risk of an overdrawn or overstated bank balance, during the fiscal year. (2) Actions Taken on the Finding. Springfield MHA will revise standard operating procedures so that bank reconciliations for the month of September of each fiscal year-ended September 30 will reflect balances in intercompany accounts receivables and intercompany accounts payables reported in accordance with HUD Accounting Brief 14 on the Financial Data Schedule as reconciling items on the bank reconciliations. For this fiscal year-end September 30, 2022, the reporting of such balances in accordance with HUD Accounting Brief 14 was only documented on trial balance worksheets that document mapping between trial balance numbers and the Financial Data Schedule. In addition, the Authority will implement controls to ensure all reconciling items are clearly documented on bank reconciliations performed monthly.

View Audit 23985

Finding 36562 (2022-001)

None 2022

Memphis Housing Authority

TN

HUD Housing Programs Reporting Internal Control / Segregation of Duties

March 29, 2023 U.S. Department of Housing and Urban Development The Housing Authority of Memphis, Tennessee respectfully submits the following corrective action plan for the year ended June 30, 2022. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 ...

March 29, 2023 U.S. Department of Housing and Urban Development The Housing Authority of Memphis, Tennessee respectfully submits the following corrective action plan for the year ended June 30, 2022. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP 8035 Spyglass Hill Road Melbourne, FL 32940 Audit period: July 1, 2021 ? June 30, 2022 The finding from the June 30, 2022 schedule of findings and questioned costs are discussed below. FINDINGS ? FINANCIAL STATEMENTS AUDIT 2022-01 Financial Reporting Other Matter Condition: The Authority did not submit the original unaudited financial data to HUD until 6 months after their fiscal year end. For the fiscal year end June 30, 2022, the Authority's unaudited financial data schedule was submitted 4 months late. Context: The Authority's unaudited financial data submission is required to be sent to the U.S. Department of Housing and Urban Development Real Estate Assessment Center ("REAC") by August 31st of each fiscal year. In the past, due to COVID-19, waivers issued by HUD allowed for an extension of time that did not apply to the June 30, 2022 year end submission. Criteria: In accordance with HUD rules and regulations, the Authority is required to submit their unaudited financial information to REAC within 60 days after the fiscal year end, regardless of size and complexity of the agency. Cause: The completion of the prior year's approval from REAC, created delays for the current period. In prior years there have been waivers and extensions related to the initial financial close and submission to REAC, which extended into the current period and created delays for the current fiscal year to be submitted on time. Effect: The unaudited financial data was not submitted within the required time period for full points on REAC's scoring methodology for all authorities. In addition, HUD could not provide timely financial oversight based on the unaudited REAC submission. Auditor's Recommendations: The Authority should continue to monitor current HUD reporting due dates and follow up on expiration dates for any current relied upon waivers. In addition, we recommend the Authority develop a process to track compliance with timely HUD reporting for future due dates. View of Responsible Officials: With prior HUD extensions for unaudited financial submissions due to COVID-19, the Memphis Housing Authority presumed an extension was provided for FY2022 unaudited financials. The Memphis Housing Authority will make certain future unaudited and audited financial submissions are submitted by the stated deadlines. Contact: Vickie Aidridge, Chief Financial Officer, (901) 544-1329, valdridge@memphisha.org. If the Department of Housing and Urban Development has questions regarding this plan, please contact Dexter D. Washington, Chief Executive Officer, at (901) 544-1102. Sincerely yours, Dexter D. Washington, Chief Executive Officer

View Audit 27024

Finding 36553 (2022-005)

Significant Deficiency 2022

Lewisburg Borough

PA

Internal Control / Segregation of Duties

Finding 2022-005 Grant Program/CFDA#: Community Development Block Grant Program, 14.228 Federal Agency/Pass-Through Entity: United States Department of Housing and Urban Development/Pennsylvania Department of Community and Economic Development Finding - Segregation of Duties: A limited number of per...

Finding 2022-005 Grant Program/CFDA#: Community Development Block Grant Program, 14.228 Federal Agency/Pass-Through Entity: United States Department of Housing and Urban Development/Pennsylvania Department of Community and Economic Development Finding - Segregation of Duties: A limited number of personnel are involved in accounting functions in which they are responsible for all related transactions (i.e. the same person recording transactions, preparing checks, recording cash disbursements, mailing checks and reconciling bank accounts, etc.). This lack of segregation of duties results in a weakness within the Borough's internal control system. It was recommended by the auditors that a greater segregation of duties can be achieved by the implementation of additional procedures that utilize current and new personnel. However, in evaluating this need, the Borough must weigh the cost of employing additional personnel against the benefits to be derived there from. Borough Response: The Borough understands that it only has a limited number of employees within the business office to assign certain duties. Additionally, it understands the various employees' capabilities restrict its options to achieve an optimal segregation of duties. Consequently, the Borough has determined that with its current checks and balances in place, it feels it has achieved its optimal segregation of duties. It does not expect to generate any future benefit by expending additional funding to achieve a greater segregation of duties.

View Audit 27371

Finding 36552 (2022-004)

Material Weakness 2022

Lewisburg Borough

PA

Reporting Internal Control / Segregation of Duties

Finding 2022-004 Grant Program/CFDA#: Community Development Block Grant Program, 14.228 Federal Agency/Pass-Through Entity: United States Department of Housing and Urban Development/Pennsylvania Department of Community and Economic Development Finding - General - Financial Statement Preparation: In ...

Finding 2022-004 Grant Program/CFDA#: Community Development Block Grant Program, 14.228 Federal Agency/Pass-Through Entity: United States Department of Housing and Urban Development/Pennsylvania Department of Community and Economic Development Finding - General - Financial Statement Preparation: In connection with the audit of the Borough of Lewisburg's financial statements, like most smaller local governmental entities, management has requested that its external auditors assist in the drafting of the schedule of expenditures of federal awards. Borough management has determined that it is more cost-beneficial to utilize the services of its auditors to assist in drafting the schedule of expenditures of federal awards, as opposed to hiring a professional accountant trained in such matters. While the Borough's internal accounting personnel have the ability to interpret and understand its schedule of expenditures of federal awards, they do not have sufficient experience in preparing that schedule in accordance with generally accepted accounting principles. It was recommended by the auditors that management should prepare its schedule of expenditures of federal awards. However, in evaluating this need, the Borough must weigh the cost of employing additional personnel against the benefits to be derived therefrom. Borough Response: The Borough will consider training staff to achieve these duties, but it does not expect to hire additional personnel to perform these duties.

View Audit 27371

Finding 36551 (2022-003)

Significant Deficiency 2022

Comprehend INC

KY

Allowable Costs / Cost Principles Reporting

2022-003 Improve Recordkeeping of Expense Allocations (Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.9592) Recommendation: We recommend that Comprehend maintains supporting documentation of all expense allocations and have it on file and readily available for th...

2022-003 Improve Recordkeeping of Expense Allocations (Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.9592) Recommendation: We recommend that Comprehend maintains supporting documentation of all expense allocations and have it on file and readily available for the audit. Action Taken: Management agrees that supporting documentation is to be maintained to comply with Grant Requirements. Comprehend is currently working with Payroll Provider; ADP, to comply with the complexity of the payroll requirement as its to reconciling allocations of payroll at the program level. This process will be in place by May 2023 under the new provider. Donna Hicks, CFO, and Melanie Hill, Accounting Assistant, are the contact persons responsible for the corrective action.

View Audit 27023

Finding 36550 (2022-002)

Material Weakness 2022

Comprehend INC

KY

Questioned Costs Reporting

2022-002 Reporting Deadlines Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing #93.498) Recommendation: We recommend that Comprehend management review all grant funding for reporting deadlines and coordinate this responsibility with the respective program di...

2022-002 Reporting Deadlines Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing #93.498) Recommendation: We recommend that Comprehend management review all grant funding for reporting deadlines and coordinate this responsibility with the respective program directors. Action Taken: Management concurs with this finding and agrees with the finding and has put in place processes to ensure that all required data reporting related to grants is done within the state required deadlines. Due to significant turnover in the finance and accounting department during the 2021 fiscal year when this grant was received, the CFO and/or CEO did not receive any communication from HRSA regarding the reporting. Management has and continues following the repayment status of HRSA Funding. The process was put into place December 2022. Donna Hicks, CFO, is the contact person responsible for the corrective action.

View Audit 27023 Questioned Costs: $1

Finding 36549 (2022-001)

Significant Deficiency 2022

Comprehend INC

KY

2022-001 Account Reconciliations Recommendation: The Organization should adopt a policy requiring monthly reconciliation of all consolidated statement of financial position accounts to their supporting documentation in order to ensure the accuracy of the monthly financial statements. Consolidated st...

2022-001 Account Reconciliations Recommendation: The Organization should adopt a policy requiring monthly reconciliation of all consolidated statement of financial position accounts to their supporting documentation in order to ensure the accuracy of the monthly financial statements. Consolidated statement of financial position reconciliations quickly identify errors and necessary corrections. If reconciliations are performed infrequently, errors and adjustments can occur, resulting in the need for significant corrections when the reconciliations are performed. Any reconciling differences should be corrected before the accounting records are closed for the month end. Action Taken: Management concurs with the finding and has processes in place to ensure that all accounts related to the monthly financial statement are reconciled monthly prior to monthly financial close. The process was implemented effective 1/1/22. Comprehend is establishing the best approach for advancing reconciliation strategies with the Finance department. Due to the historical inconsistency of programs and staffing, the implementation process is continuously evaluated for stronger internal controls for Reconciliation of all Accounts. Donna Hicks, CFO, and Melanie Hill, Accounting Assistant, are the contact persons responsible for the corrective action.

View Audit 27023

Finding 36548 (2022-002)

Significant Deficiency 2022

Woodbury University

CA

Questioned Costs Eligibility Significant Deficiency

Finding 2022-002 - Eligibility - Significant Deficiency in Internal Control Over Compliance - Recommendation: We recommend the University amend procedures so in the event that packaging is done manually, there are added reviews over the student's aid awarded. - Corrective Action Plan: We accept Moss...

Finding 2022-002 - Eligibility - Significant Deficiency in Internal Control Over Compliance - Recommendation: We recommend the University amend procedures so in the event that packaging is done manually, there are added reviews over the student's aid awarded. - Corrective Action Plan: We accept Moss Adams' recommendation and if a situation arises where we must manually package a student, the procedure will include an additional review by another individual, either the Director or a Counselor, to review the package for accuracy. An internal review of FY22 indicated this was an isolated incident. - Anticipated Completion Date: Management will complete the Corrective Action Plan by June 30, 2023. - Individual Responsible: Oscar Jones, Director of Financial Aid.

View Audit 27232 Questioned Costs: $1

Corrective Action Plans

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