Corrective Action Plans

Finding 34983 (2022-001)

Significant Deficiency 2022

Village Cooperative of Asbury

IA

Internal Control / Segregation of Duties Significant Deficiency

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

View Audit 33772

Finding 34982 (2022-001)

None 2022

Community Programs of Westchester Jewish Community Services, Inc.

NY

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

Section III- Federal Awards Findings and Questioned Costs Findings 2022-001, Allowable Costs (Assistance listing No. 93.498 Provider Relief Fund) Persons Responsible: Irene Math, CFO Karen Rosenthal, Controller View of responsible officials: The tablets were purchased for a legitimate COVID purp...

Section III- Federal Awards Findings and Questioned Costs Findings 2022-001, Allowable Costs (Assistance listing No. 93.498 Provider Relief Fund) Persons Responsible: Irene Math, CFO Karen Rosenthal, Controller View of responsible officials: The tablets were purchased for a legitimate COVID purpose, to allow, during a period of restricted visitation, community residence individuals to communicate with their families. This type of communication is essential for the wellbeing of the individuals. After the tablets were purchased but before they were deployed, family members themselves purchased tablets for the individuals in the residences. The tablets did not need to be deployed and except for two have been unused since purchase. Future use of the tablets is ear marked for use in the group homes. The Agency incurred costs to prevent, prepare for, or respond to the coronavirus in excess of Provider Relief Funds received. Had Provider Relief Funds not been used for the tablets in question, the Provider Relief funds would have been used for other appropriate costs. The Agency will review their policies to assure that expenditures charged to programs are used for intended purposes.

View Audit 30581

Finding 34981 (2022-002)

Significant Deficiency 2022

Community Programs of Westchester Jewish Community Services, Inc.

NY

HUD Housing Programs

Section III ? Federal Awards Findings and Questioned Costs Finding 2022-002,Replacement Reserves Deposits (Assistance Listing No. 14.181) Persons Responsible: Irene Math, CFO Karen Rosenthal, Controller View of Responsible Officials: To address this issue the monthly replacement reserve bank transfe...

Section III ? Federal Awards Findings and Questioned Costs Finding 2022-002,Replacement Reserves Deposits (Assistance Listing No. 14.181) Persons Responsible: Irene Math, CFO Karen Rosenthal, Controller View of Responsible Officials: To address this issue the monthly replacement reserve bank transfers have been set up in the banking system as ongoing automatic recurring transfers. A separate Financial Close and Compliance Check list will be put in place for Maple- Claremont and a step is will be added to the to reconcile cash (review and post recurring bank transfer activity) quarterly. An additional step will be added to assess any future changes to the replacement reserve transfer levels when the Contract renews annually. Estimated completion date: March 2023

View Audit 30581

Finding 34978 (2022-001)

Material Weakness 2022

Durant Community School District

IA

We have reviewed procedures and plan to make the necessary changes to improve internal control.

View Audit 30579

Finding 34976 (2022-001)

Significant Deficiency 2022

Westhampton Beach Union Free School District

NY

Eligibility Significant Deficiency Internal Control / Segregation of Duties

This corrective action plan is in response to the school district?s external auditor?s Single Audit report dated June 30, 2022 prepared by R.S. Abrams & Co, LLP. 1. Recommendation: We recommend the district develop a system of internal control to have the maintenance of effort calculator reviewed an...

This corrective action plan is in response to the school district?s external auditor?s Single Audit report dated June 30, 2022 prepared by R.S. Abrams & Co, LLP. 1. Recommendation: We recommend the district develop a system of internal control to have the maintenance of effort calculator reviewed and approved with all supporting documentation by a responsible administrator prior to submitting it to the State. We also recommend the district officials contact the State to verify procedures to file a revised MOE calculation, if considered necessary. Corrective Action: For the past five years the District has utilized a third party to process and submit its maintenance of effort calculations through the PPS office. Moving forward the business office will process, maintain and submit the maintenance of effort calculations to the State. Anticipated Completion Date: March 2023 with oversight from the Assistant Superintendent for Business.

View Audit 38144

Finding 34974 (2022-001)

Significant Deficiency 2022

Island Park Union Free School District

NY

School Nutrition Programs Cash Management Reporting

Current Year Finding #2022-001- Repeat Finding for 2021-001 According to 2 CFR section 200.305(b)(5), when non-federal entities are funded under the reimbursement method, the entity should pay for costs for which reimbursement ...

Current Year Finding #2022-001- Repeat Finding for 2021-001 According to 2 CFR section 200.305(b)(5), when non-federal entities are funded under the reimbursement method, the entity should pay for costs for which reimbursement was requested prior to the date of the reimbursement request. During our audit, we noted the monthly claims for reimbursement were not compared to reports from the point of sale ("POS") system by an individual other than the preparer of the claims report prior to submission. We recommended that the district have an individual other than the preparer of the claims report, review the reports from the POS system prior to submission to verify that the number of meals claim based on actual meals served. Corrective Action: Effective July 30th, 2022, the Food Service Manager will prepare and review the meal count and meal reimbursement to the reports from the point-of-sale system, then prior to submittal will give to the reports from the POS system to the Business Administrator, Mr. Salvatore Carambia to verify and approve the reports from the POS system that the number of meals claimed was based on actual meals served.

View Audit 36444

Finding 34970 (2022-002)

Significant Deficiency 2022

Davinci Academy of Arts and Science

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties School Nutrition Programs

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Findi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR ? 180 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. The Academy did not have sufficient controls in place within its child nutrition cluster of federal programs to ensure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred, from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned ? The Academy will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services exceeding $25,000 are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible ? The Academy?s Interim Executive Director, Holly Fischer. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Interim Executive Director, Holly Fischer, will ensure appropriate internal controls are in place to verify that any vendor with which the Academy contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 36442

Finding 34948 (2022-001)

Significant Deficiency 2022

Independent School District No. 2397

MN

Reporting Special Tests & Provisions

2022-001 Claims Approval Corrective Action Plan (CAP): 1.Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2.Actions Planned in Response to Finding The Business Manager continues training dealing with governmental financial/accounting practices. 3.Offici...

2022-001 Claims Approval Corrective Action Plan (CAP): 1.Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2.Actions Planned in Response to Finding The Business Manager continues training dealing with governmental financial/accounting practices. 3.Official Responsible for Ensuring CAP Jim Wagner, Superintendent of Schools, is the official responsible for ensuring continued implementation of certain control measures. 4.Planned Completion Date for CAP June 30, 2023. 5.Plan to Monitor Completion of CAP The Le Sueur-Henderson School Board monitors this corrective action plan. Sincerely, Jim Wagner Superintendent of Schools

View Audit 36441

Finding 34947 (2022-001)

None 2022

Pacific School of Religion

CA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The find...

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary: and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Recommendation: The School should revise its procedures to ensure accurate enrollment information is sent to NSLDS with the required timeframe for all students. Corrective Action Plan: Procedural changes implemented by the school during the Spring 2022 semester that allow for more frequent and timely enrollment reporting will correct this type of enrollment reporting error going forward. In addition, school administration will update procedures to verify status start dates for any enrollment changes specifically match the student?s enrollment in the student information system. Sincerely, Natasha Lee Vice President for Finance and Administration

View Audit 34647

Finding 34946 (2022-001)

None 2022

National Church Residences of Travis County Tx Dba Cobblestone Court

OH

Reporting

Finding Number: 2022-001 Condition: The Corporation failed to make the required reserve for replacements deposits in the current fiscal year, which caused an underfunding to the reserve for replacement totaling $33,658. Planned Corrective Action: The project did not have sufficient cash on hand to m...

Finding Number: 2022-001 Condition: The Corporation failed to make the required reserve for replacements deposits in the current fiscal year, which caused an underfunding to the reserve for replacement totaling $33,658. Planned Corrective Action: The project did not have sufficient cash on hand to make the required deposits in May and June. Management believes they have appropriate controls in place to make required deposits to the replacement reserve; however, was unable to do so without sufficient cash on hand. Management intends to make up the underfunded deposits during the year ended June 30, 2023. Contact person responsible for corrective action: Jill Kolb Anticipated Completion Date: 6/30/2023

View Audit 33426

Finding 34945 (2022-001)

None 2022

Rose-Hulman Institute of Technology

IN

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

The Institute will examine the documented destruction date on other student related files related to federal compliance requirements to ensure accuracy of document destruction date.

View Audit 32794

Finding 34943 (2022-001)

Significant Deficiency 2022

Anointed Acres Housing Development

NC

§ 200.512

Finding 2022-001: The Corporation did not submit the Data Collection Form (SF-SAC) for the year ended September 30, 2021 to the Office of Management and Budget ("OMB") in a timely manner as required by Uniform Guidance section 2 CFR 200.512. Comments on the Finding and Each Recommendation: The Corpo...

Finding 2022-001: The Corporation did not submit the Data Collection Form (SF-SAC) for the year ended September 30, 2021 to the Office of Management and Budget ("OMB") in a timely manner as required by Uniform Guidance section 2 CFR 200.512. Comments on the Finding and Each Recommendation: The Corporation should submit all future Data Collection Forms in the required time frame. Action(s) taken or planned on the finding: Management concurs with the finding and recommendations and submitted the Data Collection Form on September 27, 2022.

View Audit 31627

Finding 34942 (2022-001)

Significant Deficiency 2022

Desoto County School District

MS

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

Finding 2022-001 Corrective Action Plan a. Contact person responsible for corrective action: Stacey Graves, CFO b. Description of correction action to be taken: The district will exercise caution in ensuring calculations for indirect cost will calculated as directed by the Mississippi D...

Finding 2022-001 Corrective Action Plan a. Contact person responsible for corrective action: Stacey Graves, CFO b. Description of correction action to be taken: The district will exercise caution in ensuring calculations for indirect cost will calculated as directed by the Mississippi Department of Education. c. Anticipated completion date of corrective action: 3-24-23

View Audit 23807 Questioned Costs: $1

Finding 34940 (2022-002)

Significant Deficiency 2022

Cla Homes I, Corp.

VA

HUD Housing Programs Special Tests & Provisions

Federal agency: US Department of Housing and Urban Development CFDA number: 14.181, Supportive Housing for Persons with Disabilities Federal Award year: July 1, 2021 through June 30, 2022 Finding: 2022-02: Special Test and Provisions - Replacement Reserve Condition: The required $400 monthly de...

Federal agency: US Department of Housing and Urban Development CFDA number: 14.181, Supportive Housing for Persons with Disabilities Federal Award year: July 1, 2021 through June 30, 2022 Finding: 2022-02: Special Test and Provisions - Replacement Reserve Condition: The required $400 monthly deposit to the replacement reserve account was not made for six months during the year ended June 30, 2022. Actions Taken: Corrective action has been taken and all monthly deposits have been made for the Entity on September 19, 2022, and the Entity is up to date on its monthly deposits.

View Audit 29971

Finding 34939 (2022-001)

Material Weakness 2022

Southeast Georgia Health System, Inc.

GA

Reporting Allowable Costs / Cost Principles Material Weakness

Finding 2022-001- Material Weakness and Material Noncompliance over Reporting Contact Person: John Milazzo, VP and CFO Management?s Response: We have determined that certain expenses reported through the Department of Health and Human Services PRF reporting portal for periods 1 and 2 did not re...

Finding 2022-001- Material Weakness and Material Noncompliance over Reporting Contact Person: John Milazzo, VP and CFO Management?s Response: We have determined that certain expenses reported through the Department of Health and Human Services PRF reporting portal for periods 1 and 2 did not reconcile to the underlying expense details by nature and/or function, and therefore did not comply with PRF reporting requirements. We have implemented a monitoring control over PRF reporting to ensure that expenses submitted through the PRF portal are properly classified by nature and/or function, and that such amounts reconcile to the underlying details and accounting records. Completion Date: January 31, 2023

View Audit 29959

Finding 34938 (2022-002)

Material Weakness 2022

Nexus Family Healing

MN

Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.4...

Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Summary: Responsible Individuals: Corrective Action Plan: The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost was not subjected to formal review or approval by a separate individual outside of the preparer. Dr. Kenneth D. Varble ? Corporate Controller When summarizing lost revenue for submission, a secondary review of the summary spreadsheet prepared from the underlying supporting records will be documented. This policy will reflect the procedures needed for proper internal controls to provide assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Anticipated Completion Date: December 31, 2023

View Audit 35230

Finding 34937 (2022-001)

Material Weakness 2022

Nexus Family Healing

MN

Material Weakness Reporting Internal Control / Segregation of Duties § 200.33

Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Su...

Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Summary: The Organization claimed lost revenues attributable to coronavirus in which the final lost revenue calculation did not tie to the HHS Report. In addition, the Organization?s special report submitted to the Department of Health and Human Services (HHS) for Period 4 TIN #411419064 did not have documented review and approval by a separate individual outside of the preparer. Responsible Individuals: Dr. Kenneth D. Varble ? Corporate Controller Corrective Action Plan: A policy will be developed outlining the controls to be followed for filing reports with Federal Agencies. This policy will reflect the procedures needed for proper internal controls to provide assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Anticipated Completion Date: December 31, 2023

View Audit 35230

Finding 34936 (2022-001)

Material Weakness 2022

Lebanon Community School Corporation

IN

Questioned Costs Internal Control / Segregation of Duties Cash Management § 200.303

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance...

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirements that are performed by the Special Education Cooperative on behalf of the School Corporation. Context: The School Corporation participates in a Special Education Co-op. In 2015, the Co-op provided an avenue through a third-party company, for the member school districts to obtain reimbursement for Medicaid services. It was discovered in 2021 that the yearly parental disclosure statements had not been completed for Medicaid eligibility compliance. Due to this oversight, each member school has had to voi transactions through the third-party company and pay back the amount of these transactions from August 9, 2015 through April 23, 2021. The School Corporation?s amount owed was $481,276 for the period identified during 2015-2021. The School Corporation completed a Voluntary Self-Disclosure of Provider of Overpayments Packet through the Indiana Family & Social Services Administration?s Office of Medicaid Policy and Planning Office to reimburse the amounts owed. The amount related to this period July 1, 2020 through June 30, 2022 was indeterminable. The full amount was paid back prior to June 30, 2021. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Parental disclosure statements are completed annually for Medicaid eligibility compliance. This has already been implemented. Responsible Party and Timeline for Completion: Madeline Sandberg, Director of BCNWH Joint Services, 7/1/2021

View Audit 32733 Questioned Costs: $1

Finding 34911 (2022-006)

Material Weakness 2022

Lebanon Community School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.318

FINDING 2022-006 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Audit Findings: Material Weakness, Adverse Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to th...

FINDING 2022-006 Subject: Special Education Cluster ? Procurement and Suspension and Debarment Audit Findings: Material Weakness, Adverse Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Procurement and Suspension and Debarment compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify whether purchases were made by the Cooperative with federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34910 (2022-005)

Material Weakness 2022

Lebanon Community School Corporation

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.309 § 200.343 § 200.461

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment ...

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34909 (2022-004)

Material Weakness 2022

Lebanon Community School Corporation

IN

Equipment & Real Property Management Procurement, Suspension & Debarment Material Weakness § 200.303 § 200.313

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment r...

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Equipment and Real Property Management compliance requirement. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it indeterminable whether equipment purchases were made by the Cooperative with federal funds, or to identify equipment expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds was properly recorded and maintained in the School Corporation's equipment records. The Cooperative also did not maintain records for the disposition of equipment purchased with federal grant funds. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34908 (2022-003)

Material Weakness 2022

Lebanon Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.430

FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements relate...

FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34904 (2022-002)

Material Weakness 2022

Lebanon Community School Corporation

IN

Procurement, Suspension & Debarment School Nutrition Programs § 200.303

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspen...

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: The School Corporation contracts with a food service management company for the majority of food costs, labor costs, and operational costs, however in some cases the School Corporation will handle their own additional minor procurements outside of the food service management company. During the audit period, the School Corporation made one purchase between $10,000 and $150,000 which fell under the small purchase method for federal and state procurement regulations and was charged to Fund 0800 ? School Lunch Fund. For that purchase, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. The transaction was incurred in July 2021 in the amount of $21,668. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quotes will be sought for all purchases that fall within the small purchase threshold according to federal and state procurement regulations. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2022

View Audit 32733

Finding 34902 (2022-003)

Material Weakness 2022

Garrett-Keyser-Butler Community School District

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description ...

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls to make sure all timesheets have been received and signed by supervisors prior to payroll being completed. Anticipated Completion Date: Garrett-Keyser-Butler Community School District is no longer the LEA for the Head Start Program. However, this will be implemented immediately at the corporation.

View Audit 32731

Finding 34898 (2022-002)

Significant Deficiency 2022

Garrett-Keyser-Butler Community School District

IN

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

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Bu...

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

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Corrective Action Plans

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