Corrective Action Plans

Finding 32197 (2022-003)

None 2022

ME

Reporting School Nutrition Programs

Management Response/Corrective Action Plan: All schools in the RSU are now using the same software and process at their point of sales. All impacted staff have been trained on this new software and the Business Department will continue to review reports for meal counts on a monthly basis.

View Audit 35037

Finding 32196 (2022-001)

Material Weakness 2022

Howard County Public School System

MD

Internal Control / Segregation of Duties Reporting

A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Financial Statement Findings: Finding 2022-001 a. Comments on the Finding and Each Recommendation: Management agrees with the finding and concurs with the recommendation. b. Action(s) Taken or Planned on the Fin...

A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Financial Statement Findings: Finding 2022-001 a. Comments on the Finding and Each Recommendation: Management agrees with the finding and concurs with the recommendation. b. Action(s) Taken or Planned on the Finding: To ensure the integrity of its financials, HCPSS is in the process of reengineering its internal processes as it pertains to the accounting of its Restricted Programs Fund. As such, the following actions will be taken: 1. HCPSS is working with their IT department to configure its financial system to differentiate between the different types of grants within its Restricted Programs Fund. This will allow for greater oversight and ensure revenue is being recognized correctly in compliance with generally accepted accounting principles throughout the year. 2. HCPSS has funding allocated to hiring a Grant Budget Analyst and Grant Accountant III. With these additional resources supporting the Restricted Programs Fund, there will be an improvement in internal controls as well as more thoroughly defined roles and responsibilities. This will include a more refined monthly analysis of the individual grants comprising the Restricted Programs Fund

View Audit 32134

Finding 32195 (2022-003)

Significant Deficiency 2022

Northern Marianas College

MP

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding No. 2022 ? 001, Payroll (Renewal of Personnel Action) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the situation is unique to disputes that arise...

Finding No. 2022 ? 001, Payroll (Renewal of Personnel Action) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the situation is unique to disputes that arise between the employee and supervisor during the employee personnel action renewal process. Personnel Actions are implied as renewed per employee contract terms. In order to resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of personnel actions. Finding No. 2022 ? 002, Payroll (Contract Renewals) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts. Finding No. 2022 ? 003, Payroll Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as it is related to Finding No. 2022-002. The three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts.

View Audit 30795

Finding 32194 (2022-002)

None 2022

Universal Technology College of Puerto Rico, INC

PR

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

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria Accordi...

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

View Audit 30794

Finding 32193 (2022-001)

None 2022

Universal Technology College of Puerto Rico, INC

PR

Questioned Costs Student Financial Aid Subrecipient Monitoring

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate ...

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student?s parent, is eligible to receive for that payment period. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. The monthly evaluation, verification and reconciliation will include an internal audit performed by another office responsible for comparing the COD system with the student ledger to reinforce the actual disbursement control procedures ensuring that all disbursements are correctly posted and that the student?s ledger correctly shows all the activity performed on the COD system. The institution already refunded the questioned cost of $3,247.50

View Audit 30794 Questioned Costs: $1

Finding 32192 (2022-001)

Material Weakness 2022

International Registration Plan, Inc.

VA

Internal Control / Segregation of Duties Material Weakness Reporting

2022 CORRECTIVE ACTION PLAN June 30, 2023 Federal Motor Carrier Safety Administration International Registration Plan, Inc. respectfully submits the following Corrective Action Plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Blue & Co., LLC 250 We...

2022 CORRECTIVE ACTION PLAN June 30, 2023 Federal Motor Carrier Safety Administration International Registration Plan, Inc. respectfully submits the following Corrective Action Plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Blue & Co., LLC 250 West Main Street, Suite 2900 Lexington, KY 40507 Audit period: October 1, 2021 - September 30, 2022 The findings from the June 30, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section II - Financial Statement Findings 2022-001 Finding: Preparation of Financial Statements Criteria or specific requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that supports accurate external financial reporting. Condition: IRP does not have in place the processes and controls that would assure the preparation of external year-end financial statements and related note disclosures in accordance with accounting principles generally accepted in the United States of America. Effect: Recognizing the above condition IRP engages the external independent auditors to assist with the drafting of the year-end external financial statements. Once drafted, the financial statements are submitted to management for review, revision, and approval. While this practice is common and practical, it is considered a material weakness in internal control over financial reporting since the year-end external financial statement preparation cannot be performed in-house. Cause: Such preparation would require the in-house ability to maintain appropriate technical knowledge, including the ability to research current and changing accounting standards as well as unique industry considerations. Recommendation: The external auditors have recommended management review and, if practical, enhance the external financial reporting procedures and controls in place to address the preparation and review of external year-end financial statements. Views of responsible officials and planned corrective actions: Management concurs with the above finding and, accordingly, has engaged the auditors to assist with the preparation of the 2022 year-end external financial statements. Management is currently reviewing the procedures and controls in place to address the preparation and review of external year-end financial statements and will revise and enhance as warranted. Respectfully submitted, Timothy A. Adams CEO IRP, Inc.

View Audit 36723

Finding 32166 (2022-004)

Significant Deficiency 2022

City of Richmond

VA

Student Financial Aid Eligibility Significant Deficiency

2022-Single Audit 01 Department of Social Services Title IV-E Adoption Assistance A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibilit...

2022-Single Audit 01 Department of Social Services Title IV-E Adoption Assistance A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Recommendations: ? We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. ? We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Explanation of disagreement with audit finding: n/a ? no disagreement Action planned/taken in response to finding: Audit Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. RDSS Corrective Action Plan: The Reunification and Permanency Program Manager or designee will conduct quarterly adoption case reviews using the VDSS Guidance Section 3.9.3 - Adoption Records. The quarterly case sample represents 10% of the case and all cases will be reviewed at least once annually. Any findings will be documented to include corrective actions, person responsible and timeframe for correction. The Reunification and Permanency Program Manager or designee will review cases to confirm corrections. Audit Recommendation: We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. RDSS Corrective Action Plan: All RDSS Adoptions files must include the VDSS Adoption File Checklist and the child?s adoptive family documentation. The required adoptive parent documentation includes: o Criminal Background Check Results - Licensed Child Placing Agencies ( Non-Conviction and/or Conviction Letter); Local Department of Social Services (Office of Background Investigations Determination Letter) o Sworn Statement of Affirmation o Child Abuse and Neglect Central Registry Check results for adoptive parent and adult household members. The Adoption and Resource Families Supervisors are responsible for monitoring compliance with documentation requirements for completion of the background checks, including insuring that documentation is requested from child ?placing agencies and third parties. Standard documentation requirements regarding background checks will be included in the quarterly review by the Reunification and Permanency Program Manager or designee. Name(s) of the contact person(s) responsible for corrective action: Brinette Jones, Deputy Director, Division Children, Families and Adults Lavinia Hopkins, Reunification and Permanency Program Manger Planned completion date for corrective action plan: Ongoing, beginning 2nd quarter 2023 If there are any questions regarding this plan, please contact Brinette Jones at (804) 646-4543.

View Audit 35530

Finding 32163 (2022-005)

Significant Deficiency 2022

City of Richmond

VA

Eligibility Significant Deficiency Internal Control / Segregation of Duties

2022-Single Audit 02 Department of Social Services TANF Eligibility A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 cases files tested did not contain adequate documentation to verify eligibility requirements...

2022-Single Audit 02 Department of Social Services TANF Eligibility A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 cases files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Recommendations: ? We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned/taken in response to finding: All supervisors within the Economic Support & Independence Division of the Richmond Department of Social Services (RDSS) will be expected to complete a minimum of three case readings per month for each direct report assessing eligibility within the TANF program. In addition, all team members who assess TANF eligibility will be required to complete refresher trainings on uploading documents to the Document Management Imaging System (DMIS), Documentation and Verifications, and Application Processing, which will include categorical requirements and conditions of eligibility. Name(s) of the contact person(s) responsible for corrective action: Sarah Raring & Tricia Wyatt Planned completion date for corrective action plan: June 30, 2023 If there are any questions regarding this plan, please contact Sarah Raring at (804) 646-3332 or sarah.denhamraring@rva.gov.

View Audit 35530

Finding 32162 (2022-006)

Material Weakness 2022

City of Richmond

VA

Subrecipient Monitoring Material Weakness Reporting

2022-006 CDBG Entitlement Grant Cluster and COVID-19 ? Community Development Block Grant - CV ? Assistance Listing No. 14.218 Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop cont...

2022-006 CDBG Entitlement Grant Cluster and COVID-19 ? Community Development Block Grant - CV ? Assistance Listing No. 14.218 Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Housing and Community Development will work with the appropriate Federal regulatory department and review applicable guidance to determine the required reporting frequency, register with all necessary reporting systems, and receive any necessary training by June 30, 2023. Beginning July, 2023, Housing and Community Development will begin submitting the fiscal year 2024 reports while concurrently submitting any and all delinquent reports for fiscal year 2023. Name(s) of the contact person(s) responsible for corrective action: Sherrill Hampton Planned completion date for corrective action plan: October 31, 2023

View Audit 35530

Finding 32161 (2022-001)

None 2022

Southern Regional School District

NJ

Cash Management School Nutrition Programs

Purchase Needed Equipment

View Audit 35067

Finding 32160 (2022-003)

Material Weakness 2022

Imagine the Possibilities, Inc.

IA

Allowable Costs / Cost Principles § 200.303

Finding 2022-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 2 TIN#237224698 Federal Financial A...

Finding 2022-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 2 TIN#237224698 Federal Financial Assistance Listing/CFDA Number: 93.498 Finding Summary: Imagine the Possibilities, Inc. final eligible expenditure listing identified as eligible and claimed under the Provider Relief Fund program was not reviewed and approved by a separate individual outside of the preparer. In addition, the Organization?s special report submitted to the Department of Health and Human Services for Period 2 TIN #237224698 was not reviewed and approved by a separate individual outside of the preparer. There were also expenses within that listing and also included on the submitted report that were unallowable. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. The Organization will review the internal controls and implement improvements related to allowability of all federal cost claimed, including those regarding the identification of duplicate items and approved costs. Anticipated Completion Date: March 31, 2023

View Audit 35066

Finding 32159 (2022-002)

Material Weakness 2022

Imagine the Possibilities, Inc.

IA

Reporting Material Weakness

Finding 2022-002: Preparation of Schedule of Expenditures of Federal Awards Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 2 TIN#237224698 Federa...

Finding 2022-002: Preparation of Schedule of Expenditures of Federal Awards Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 2 TIN#237224698 Federal Financial Assistance Listing/CFDA Number: 93.498 Finding Summary: The Organization does not have an internal control system designed to provide for a complete and accurate schedule being audited. We were requested to draft the schedule and notes to the schedule. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. However, management feels that committing the resources necessary to remain current on SEFA reporting requirements and corresponding footnote disclosures would lack benefit in relation to the cost, but will continue to evaluate on a regular basis. Anticipated Completion Date: Ongoing

View Audit 35066

Finding 32145 (2022-002)

Significant Deficiency 2022

College of Mount Saint Vincent

NY

Student Financial Aid Special Tests & Provisions Eligibility

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updat...

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updated the students' records on the NSC and will monitor the NSLDS portal weekly to ensure that all student updates are processed and correct on both the campus and program levels. In regard to the publication of the length of the Master?s level program, the College is revising its documentation and publication of the length of the Master?s program to reflect adjustments to the program that reduced the amount of time needed to complete the program. In addition, the College?s student information system was reviewed/updated to accurately reflect the published length for each program. To assure that the information is being transmitted correctly, the College will monitor the next six months of enrollment updates to ensure that each student, in the different programs, has the correct publication program length.

View Audit 31463

Finding 32144 (2022-001)

Significant Deficiency 2022

College of Mount Saint Vincent

NY

Student Financial Aid Reporting Significant Deficiency

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for mo...

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for more timely drawdowns of federal funds. Those measures were and continue to be to extract and submit reporting to COD on a minimum weekly basis (with a goal of daily) to remain within the 15-day reporting requirement. Between the 2021-2022 aid years, the College?s Financial Aid department has experienced the leadership transition of three directors, and our current Director is identifying and implementing process refinements to previous steps taken to further improve internal controls. Further, the College has taken steps to both continue and enhance ongoing staff professional development sessions and training. In addition, the College contracted a Financial Aid consultant in the Fall of 2022 for an assessment of our system configurations and processes. The consultant has been retained to undertake a quarterly review of our setups and processes and assist in training the team. In accordance with best practices, Financial Aid?s goal is to continue to eliminate such errors. The findings continue to be addressed.

View Audit 31463

Finding 32143 (2022-001)

Material Weakness 2022

Madison Interfaith Residential Community, Inc.

CT

CORRECTIVE ACTION PLAN April 25, 2023 Federal Audit Clearinghouse 1201 East 10th Street Jefferson, Indiana 47132 Madison Interfaith Residential Community, Inc. d/b/a Concord Meadows (the Project) respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. Hoyt, Fi...

CORRECTIVE ACTION PLAN April 25, 2023 Federal Audit Clearinghouse 1201 East 10th Street Jefferson, Indiana 47132 Madison Interfaith Residential Community, Inc. d/b/a Concord Meadows (the Project) respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. Hoyt, Filippetti & Malaghan, LLC 1041 Poquonnock Road Groton, Connecticut 06340 Audit Period: Year ended June 30, 2022 The findings from the June 30, 2022 Schedule of Federal Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2022-001 BANK RECONCILIATIONS Criteria: Bank reconciliations should be prepared in a timely manner (i.e. monthly). Condition: During our audit testing, we noted that some bank reconciliations were not prepared monthly, but rather they were prepared in batches months after the statement date. Cause: Bank statements are not being reviewed and reconciled monthly. Effect: Transactions may be omitted from the general ledger system or bank errors may go undetected if accounts are not reconciled monthly. Questioned Costs: N/A Recommendation: We recommend that management ensure that all bank accounts are reconciled monthly to ensure proper recording of transactions. Management?s Views and Corrective Action Plan: Management has implemented the protocol with staff members to reconcile the bank statements by the 10th of each month. If you have any questions regarding this plan, please contact Matthew Scibek at 860-398-5425, or matt@westfordmgt.com.

View Audit 27758

Finding 32138 (2022-002)

Significant Deficiency 2022

Fall River School District

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Finding #2022-002 ? Inconsistencies Between General Ledger Project and PI-1086 Grant Claim Education Stabilization Fund- ESSER II (#84.425D) Federal Grantor - US. Department of Education Pass-through Award Number ? 2022-111736-DPIESSERFII-163 Pass-through Entity - Wisconsin Department of Public Inst...

Finding #2022-002 ? Inconsistencies Between General Ledger Project and PI-1086 Grant Claim Education Stabilization Fund- ESSER II (#84.425D) Federal Grantor - US. Department of Education Pass-through Award Number ? 2022-111736-DPIESSERFII-163 Pass-through Entity - Wisconsin Department of Public Instruction Condition: ESSER II grant reimbursement claims are submitted to the Wisconsin Department of Public Instruction using a PI-1086 report. A PI-1086 reimbursement claim includes the approved budget and the actual allowable program expenditures incurred to date. A PI-1086 claim is a summary report and the detail to support the claim must be maintained by the District. ESSER funding was audited as a major federal program for the year ended June 30, 2022. During the audit, we noted that general ledger costs in Project 163 (ESSER II project) were not consistent with the approved budget amounts or actual disbursement amounts in the PI-1086. Payroll costs included in the approved budget were not recorded to Project 163, and construction costs not included in the approved budget, were recorded to Project 163. After bringing to the District?s attention, late journal entries were made to reallocate the approved budgeted payroll cost to Project 163. Construction costs not included in the ESSER II budget were moved out of Project 163. Criteria: The District is required to track costs claimed on PI-1086 in detail by each grant?s specific project code. Project code numbers are provided by DPI to aid in tracking allowable reimbursable costs claimed to a grant. Reimbursement claims submitted to DPI should agree to the actual costs reported in the general ledger for that grant?s project code. Cause: The District?s approved ESSER II budget was $234,748. An ESSER II grant claim submitted reflected actual disbursements to date of $234,748. The PI-1086 reflected that actual costs incurred were the same as the approved budget. The unaudited general ledger Project 163 expenditures totaled $234,748, however, the breakdown of costs by Account Code object and function was not consistent with the approved budget. This caused confusion about what costs were being claimed. Effect: Costs claimed for reimbursement need to be consistent with the Wisconsin Department of Instruction approved budget. A reimbursement request could be made and paid by DPI for expenditures that did not comply with the approved budget or grant requirements. Context: Education Stabilization Fund (ESSER) was new grant funding in response to the rising costs associated with COVID-19 coronavirus. The federal government provided ESSER grants to aid schools in operating safely. Recommendation: Establish controls to ensure PI-1086 claims are made with information consistent with the District?s general ledger. Reclassify costs as needed with a journal entry to move costs in or out of a grant project based on costs claimed under the grant. If needed, request that the Wisconsin Department of Public Instruction amend an approved budget to be consistent with actual allowable costs incurred by District. Response: The District will evaluate its controls to ensure grant project codes are being properly utilized and costs claimed under the grant are appropriately coded. Prior to filing PI-1086 grant claims, we will ensure costs submitted are consistent with our general ledger and the approved budget. Contact Person: Dennis Birr Anticipated Completion: June 30, 2023

View Audit 28280

Finding 32137 (2022-001)

Significant Deficiency 2022

Fall River School District

WI

Internal Control / Segregation of Duties

Finding #2022-001 ? Lack of Segregation of Duties Condition:The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Internal controls should be in place that provide adequate segregation of duties. Cause: The District has determined that hiring a...

Finding #2022-001 ? Lack of Segregation of Duties Condition:The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Internal controls should be in place that provide adequate segregation of duties. Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the District?s operations. Response: We agree with the finding but do not believe it is cost effective to increase the office staff in attempt to bring about a more effective segregation of duties. Contact Person: Dennis Birr Anticipated Completion: Not Applicable

View Audit 28280

Finding 32093 (2022-004)

Significant Deficiency 2022

Carteret Board of Education

NJ

Procurement, Suspension & Debarment Eligibility

The District publishes or solicits proposals for all contracts equal to or in excess of $25,000. Vendors are required to include a Certification Regarding Debarment, Suspension, and Other Responsibility Matters and SBA will verify vendor certification at https:www.beta.sam.gov/

View Audit 33557

Finding 32092 (2022-003)

Significant Deficiency 2022

Carteret Board of Education

NJ

Allowable Costs / Cost Principles

The district will develop written procedures and update existing ones to meet the standards of the Uniform Grant Guidance.

View Audit 33557

Finding 32091 (2022-002)

Significant Deficiency 2022

Carteret Board of Education

NJ

Ending times on timesheet include 30 minutes of "prep time" and total number of hours worked. Charges for salaries are assigned to school-specific location codes. Records are maintained to document activities and responsibilities of Title I designated staff members. All staff members charged to ESSE...

Ending times on timesheet include 30 minutes of "prep time" and total number of hours worked. Charges for salaries are assigned to school-specific location codes. Records are maintained to document activities and responsibilities of Title I designated staff members. All staff members charged to ESSER grants are approved in the official minutes.

View Audit 33557

Finding 32090 (2022-001)

Significant Deficiency 2022

Carteret Board of Education

NJ

Cash Management

Assistant BA reviews expenditures and submits reimbursement requests on a monthly basis.

View Audit 33557

Finding 32088 (2022-004)

Significant Deficiency 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding Reference: 2022-004 Federal Agency: Department of Treasury Compliance Requirement: Activities Allowed, Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: ...

Finding Reference: 2022-004 Federal Agency: Department of Treasury Compliance Requirement: Activities Allowed, Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAPI Charles County Condition/Context: SMTCCAC was unable to provide documentation to support review and approval for one (1) of the 40 transactions selected for testing. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: SMTCCAC was unable to locate the Expenditure Request Form that demonstrates the approval of an invoice. Effect: The risk of unallowed costs increases due to lack of supervisor review and approval of expenditures charged to the program. Questioned Costs: None Recommendation: We recommend that SMTCCAC maintain the documentation of review and approval of expenditures charged to the federal award programs. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240

Finding 32087 (2022-003)

Significant Deficiency 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding Reference: 2022-003 Federal Agency: Department of Treasury Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistanc...

Finding Reference: 2022-003 Federal Agency: Department of Treasury Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAPI Charles County Condition/Context: SMTCCAC did not provide proof of review of the shared document among participating ERAP agencies in Charles County to avoid duplication of benefits for four (4) of the 60 rental assistance claims selected for testing. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: SMTCCAC did not adequately monitor controls to ensure proper review of the shared document among participating ERAP agencies in Charles County resulting in the potential duplication of benefits. Effect: Failure to review the shared document used among participating ERAP agencies in Charles County could result in duplication of benefits. Questioned Costs: None Recommendation: We recommend that SMTCCAC consistently verify the shared document used among participating ERAP agencies in Charles County to avoid duplication of benefits. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240

Finding 32086 (2022-002)

Significant Deficiency 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303

Finding Reference: 2022-002 Federal Agency: Department of Treasury Compliance Requirement: Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023...

Finding Reference: 2022-002 Federal Agency: Department of Treasury Compliance Requirement: Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAP I Charles County Condition/Context: FSTA selected a sample of sixty disbursements of rental assistance claims for testing and noted the following errors: ? SMTCCAC mistakenly processed a duplicate payment of $7,700 for an eligible claim, which was one (1) of the 60 rental assistance claims selected for testing in Charles County ERAP I grant. ? SMTCCAC made a payment of $31,800 to a landlord for one (1) of the 60 rental assistance claims selected for testing, for which another agency had made a payment for the same claim before SMTCCAC. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: Under OMB guidance, Public Law (Pub. L.) No. 107-300, the Improper Payments Information Act of 2002, as amended by Pub. L. No. 111-204, the Improper Payments Elimination and Recovery Act, Executive Order 13520 on reducing improper payments, and the June 18, 2010 Memorandum on Enhancing Payment Accuracy - Any payment that should not have been made or that was made in an incorrect amount, including an overpayment or underpayment, under a statutory, contractual, administrative, or other legally applicable requirement; and includes ? (i) any payment to an ineligible recipient;(ii) any payment for an ineligible good or service; (iii) any duplicate payment; (iv) any payment for services not received; and (v) any payment that does not account for credit for applicable discounts. Cause: Due to staff turnover, the claim of $7,700 was submitted to Finance for payment twice. SMTCCAC did not sufficiently monitor controls to detect the duplicate payment. Additionally, SMTCCAC did not adequately monitor controls to ensure proper review of the shared document among participating ERAP agencies in Charles County to avoid the duplication of benefits for the claim of $31,800. Effect: The duplicate expenditure included in the program cost was deemed unallowable. The landlord involved in the rental assistance claim confirmed receiving two checks, each totaling $7,700. SMTCCAC did not require the landlord to return the duplicate funds, nor did it establish a repayment plan after the landlord expressed a willingness to establish a repayment agreement. Ultimately, the landlord chose to apply the duplicate payment of $7,700 towards future rents for the applicable tenant. During FY2023, Charles County identified the duplicate check and promptly requested the return of duplicate payment of $7,700 from SMTCCAC. During a program file audit by Charles County, it was determined that a duplicate expenditure included in the program cost was deemed unallowable. In FY2022, SMTCCAC paid $31,800 to a landlord who had already received payment from another participating ERAP agency. Despite notifications from SMTCCAC, the landlord has not/was not willing to return the duplicate funds to SMCTTAC. Charles County has notified SMTCCAC on numerous occasions about the need to reimburse the County for the duplicated funds. Once the funds are received, Charles County will return the monies to the State of Maryland. In March of 2023, the County also sent an invoice of $31,800 requesting SMTCCAC to return the $31,800. Questioned Costs: $7,700 ? duplicate payment made to a landlord for a rental assistance claim selected for testing. $31,800 ? duplicate payment made to a landlord for a rental assistance claim selected for testing. Recommendation: We recommend that SMTCCAC implement effective controls to prevent duplicate payments. Additionally, we recommend that SMTCCAC consistently verify the shared document used among participating ERAP agencies in Charles County to ensure that a claim has not been applied for and paid by other agencies. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240 Questioned Costs: $1

Finding 32084 (2022-006)

Material Weakness 2022

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Questioned Costs Allowable Costs / Cost Principles

Finding Reference: 2022-006 Federal Agency: Department of Health and Human Services Compliance Requirement: Allowable Costs (Indirect Costs) Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Federal Program: 93.60...

Finding Reference: 2022-006 Federal Agency: Department of Health and Human Services Compliance Requirement: Allowable Costs (Indirect Costs) Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Federal Program: 93.600 ? Head Start; 93.569 ? CSBG; Grant Award: Various Condition/Context: During the testing of indirect cost allocations to federal programs, it was determined that SMTCCAC overcharged indirect costs on two of seven federal programs. Head Start, a major program, was one of the two programs with overcharges. The indirect costs charged to the programs exceeded the approved provisional federal indirect cost rate of 31.5% without obtaining approvals from the federal awarding agencies. As a result, an overallocation of indirect expenses was incurred by the effected federal programs. In addition, we found that SMTCCAC applied indirect cost rates inconsistently among programs and failed to calculate an actual indirect cost rate and provide composition of indirect costs for the fiscal year 2022. Criteria: On July 23, 2021, the Department of Health and Human Services approved a provisional indirect cost rate of 31.5% to be applied to total direct salaries and fringe benefit costs related to all federal programs. This rate is applicable to SMTCCAC?s grants, contract, and other agreements covered by 2 CFR 200 for the period effective from December 1, 2020 to June 30, 2023. According to the approved rate agreement, if any federal contract, grant, or other agreement is reimbursing indirect costs by a means other than the approved rate in this agreement, the organization should (1) credit such costs to the affected programs, and (2) apply the approved rate to the appropriate base to identify the proper amount of indirect costs allocable to these programs. Cause: SMTCCAC charged indirect costs to grants based on budgeted amounts per grant agreements instead of allocating indirect costs to programs based on an actual indirect rate for the fiscal year not to exceed its approved provisional indirect cost rate of 31.5%. SMTCCAC didn?t calculate an actual annual indirect cost rate for FY 2022 to compare to the approved provisional rate. The actual rate should have been calculated to determine if it was lower than the approved provisional rate. If lower, the actual rate should have been applied. If higher, the approved provisional rate should have been used. Additionally, indirect cost rates were not consistently applied across the various programs. Effect: Indirect cost rates were inconsistently applied across each federal program. SMTCCAC obtained approval from the ERAP grantor to charge indirect costs in excess of the approved provisional indirect cost rate of 31.5%. However, SMTCCAC allocated indirect costs in excess of the approved provisional rate to two of the six remaining federal programs. The remaining four programs were charged below the approved provisional rate. Questioned Costs: The questioned costs were not determinable because the actual annual indirect cost rate was not calculated. Without the actual rate, we could not determine if the actual rate was lower or higher than the approved provisional rate. However, based on our assessment using the approved provisional rate, the overallocations appear to be material. Recommendation: We recommend that SMTCCAC ensures compliance with the cost principals in 2 CFR Part 200, Subpart E, and follows the approved federal indirect cost rate agreement and calculate the actual annual indirect cost rate when determining indirect costs charged to federal awards. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

View Audit 32240 Questioned Costs: $1

Corrective Action Plans

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