Corrective Action Plans

Finding 547072 (2024-004)

Material Weakness 2024

City of Temecula

CA

Matching / Level of Effort / Earmarking Special Tests & Provisions Material Weakness § 200.303 § 200.326

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Vear: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisi...

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Vear: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions -Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City will further strengthen its internal controls to ensure timely reviews of certified payroll submissions are performed. This will include procedures to ensure that the information provided to the City by its consultant project manager is accurate. Additionally, ensure that the contractors and subcontractors submit the required certified payroll in a timely manner and in case of delinquencies, appropriate actions are taken. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

View Audit 351438

Finding 547066 (2024-002)

Significant Deficiency 2024

City of Temecula

CA

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

2024-002 Program: CDBG - Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Inter...

2024-002 Program: CDBG - Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City has implemented the appropriate changes in the fourth quarter of fiscal year 2024 immediately after the findings were communicated. The City will continue to carry out the corrective actions that have been implemented. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

View Audit 351438

Finding 547061 (2024-002)

Material Weakness 2024

Operation Samahan, Inc.

CA

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness

2024-002 – Special Tests and Provisions (repeat of Finding 2023-002) Corrective action planned: Management will implement a series of corrective actions to address the findings to ensure consistent application of sliding fee discount. Actions to be taken are as follows: * Review of the sliding fee a...

2024-002 – Special Tests and Provisions (repeat of Finding 2023-002) Corrective action planned: Management will implement a series of corrective actions to address the findings to ensure consistent application of sliding fee discount. Actions to be taken are as follows: * Review of the sliding fee application to facilitate data collection for sliding fee discount program. * Implement a self-declaration or attestation for patients who cannot provide proof of income * Comprehensive training on the sliding fee program for all relevant staff * Implement monthly internal audits for sliding fee claims and provide feedback to staff based on findings and observations. Anticipated Completion Date: June 2025 Person Responsible for Corrective Action: Elizabeth David, CFO

View Audit 351435

Finding 547060 (2024-001)

Significant Deficiency 2024

City of Pittsfield, Massachusetts

MA

The city will continue its effort to reconcile the variance between its general ledger and the amounts reported to Treasury.

View Audit 351428

Finding 547054 (2024-004)

Significant Deficiency 2024

Cooperative Educational Service Agency #5

WI

Internal Control / Segregation of Duties Reporting Significant Deficiency

Action planned/taken in response to finding: Management remains cognizant of the internal control structure and continues to evaluate cost effective opportunities for further improvement. Name(s) of the contact person(s) responsible for correction action: Mike Koltes, Business Services Director Pl...

Action planned/taken in response to finding: Management remains cognizant of the internal control structure and continues to evaluate cost effective opportunities for further improvement. Name(s) of the contact person(s) responsible for correction action: Mike Koltes, Business Services Director Planned completion date for corrective action: Ongoing

View Audit 351427

Finding 547053 (2024-002)

Significant Deficiency 2024

Concordia University Texas

TX

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

An action plan has been made in conjunction with IT to ensure more timely and accurate notifications of student schedule changes/withdrawals and processing of required adjustments to aid. We will be implementing a more automatic process that will assist with the work flow and efficiency of these pro...

An action plan has been made in conjunction with IT to ensure more timely and accurate notifications of student schedule changes/withdrawals and processing of required adjustments to aid. We will be implementing a more automatic process that will assist with the work flow and efficiency of these processes.

View Audit 351424

Finding 547052 (2024-001)

Significant Deficiency 2024

Concordia University Texas

TX

Questioned Costs Student Financial Aid Subrecipient Monitoring

The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process ...

The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process when a Title IV credit balance exceeds the allowable time frame. 2. Providing and accessing additional training to financial aid and student accounts personnel on Title IV regulations regarding credit balances and timely refunds. 3. Establishing a formalized procedure for escalating unresolved balances to senior financial administrators for immediate corrective action.

View Audit 351424 Questioned Costs: $1

Finding 547048 (2024-006)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

Internal Control / Segregation of Duties Eligibility Allowable Costs / Cost Principles

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413

Finding 547043 (2024-005)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

Internal Control / Segregation of Duties Eligibility Allowable Costs / Cost Principles

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413

Finding 547042 (2024-004)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

Internal Control / Segregation of Duties Eligibility Allowable Costs / Cost Principles

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413

Finding 547041 (2024-003)

Material Weakness 2024

Catholic Charities of the Diocese of Camden

NJ

Questioned Costs Internal Control / Segregation of Duties Eligibility

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseei...

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 351413 Questioned Costs: $1

Finding 547039 (2024-001)

Material Weakness 2024

Regent University

VA

Student Financial Aid Reporting Material Weakness § 200.303 § 200.516

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, ...

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish formalized communication protocols between departments to be enacted in the case of an NSC enrollment reporting file delay that could result in noncompliance with enrollment reporting requirements. Regent University will establish a reporting process directly between the University and NSLDS to be used in the event of an NSC backlog that cannot be mitigated within the compliance window. Regent University will implement the first and second parts of this plan by June 30, 2025 and the final component (NSLDS direct file reporting process) by September 30, 2025. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Associate Registrar)

View Audit 351409

Finding 547034 (2024-005)

Material Weakness 2024

Mount Vernon Community School Corporation

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and ex...

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

View Audit 351407

Finding 547029 (2024-004)

Material Weakness 2024

Mount Vernon Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

FINDING 2024-004 Finding Subject: A sample of 14 payroll population from the School's ESSER disbursement population was selected for testing to verify if the transactions were for allowable costs. An employee was paid 50% of the ESSER grant and no documentation was provided. Contact Person Responsib...

FINDING 2024-004 Finding Subject: A sample of 14 payroll population from the School's ESSER disbursement population was selected for testing to verify if the transactions were for allowable costs. An employee was paid 50% of the ESSER grant and no documentation was provided. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school is assuming that time & effort documentation was required for the one individual paid 50% with ESSER funds. That is occurring now, and always has with the only current federal fund that partially pays for staffing (Title 1.) It is unknown why this individual did not archive this information as they served as the Title 1 director as well during this time. No corrective plan is needed. The grant is closed, no funds are available, no further transactions will occur from this grant. Anticipated Completion Date: 3/11/2025 (the grant is closed)

View Audit 351407

Finding 547022 (2024-003)

Material Weakness 2024

Mount Vernon Community School Corporation

IN

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

FINDING 2024-003 Finding Subject: A portion of the School Corporation's Special Education allocation was required to be set aside for mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the non-proportionate share reservation. The required amount to be set aside was indica...

FINDING 2024-003 Finding Subject: A portion of the School Corporation's Special Education allocation was required to be set aside for mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the non-proportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for mandatory CEIS reservation from the non-public proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the school corporation did not have actual expenditure amounts to account for the FY2021 pre-school grant non proportionate share amount. The expenditures used were a percentage of total expenditures. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school will review all current and future Special Education grant application and set aside the required amounts for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the non-proportionate share reservation. The Special Education Director and Corporation Treasurer will determine this amount and enter it in the appropriate documentation. They will also separate the earmarking for mandatory CEIS reservation from the non-public proportionate share. The school can do nothing to correct the absence of actual expenditure amounts to account for the FY2021 preschool grant non proportionate share amount since this grant has long since closed and passed through prior audit periods. For current and future pre-school grants, the Special Education Director and Corporation Treasurer actual expenditure amounts to account for pre-school grant non proportionate share. Anticipated Completion Date: June 30, 2025

View Audit 351407

Finding 547017 (2024-001)

Significant Deficiency 2024

West Hempstead Union Free School District

NY

Equipment & Real Property Management § 200.313 § 200.439

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Governor's Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary Schoo...

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Governor's Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District did not include the capital expenditures for the “Unit Ventilators Replacement Project” paid with CRRSA ESSER 2 funds in its current year’s capital assets inventory additions. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will review and update existing procedures relating to the recording and tracking of capital assets purchased with federal funds. The cost of the unit ventilators replacement project and pertinent information will be added to the District’s capital assets inventory report. Responsible Contact Person: Brian Phillips Assistant Superintendent for Business and Operations West Hempstead Union Free School District 252 Chestnut Street West Hempstead, NY 11552 Anticipated completion date: September 1, 2025.

View Audit 351405

Finding 547016 (2024-001)

Significant Deficiency 2024

City of Beverly

MA

Allowable Costs / Cost Principles Reporting Significant Deficiency

Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting por...

Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting portal by the Finance Director. Any variances or adjustments that are necessary from the Trial balance will be clearly documented for reconciliation and confirmed by the City Auditor as accurate. Upon confirmation, the Finance Director will submit the report. Planned Implementation Date of Corrective Action: Quarter 1, 2025 report (due by April 30th, 2025) Person Responsible for Corrective Action: City Auditor Finance Director

View Audit 351403

Finding 547015 (2024-002)

Significant Deficiency 2024

Weavers Way Community Fund Inc.

PA

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

To address the increase in the Organization’s activities under this program, the Certified Management Accountant of Weavers Way Community Fund, Inc. will send a performance report to the Department of Housing and Urban Development.

View Audit 351400

Finding 547013 (2024-001)

Material Weakness 2024

Marvell School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Reference number: 2024-001 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR part 200, subpart E Corrective Action: The Superintendent Prong Tran, Director of Finance, Scott McRae and Operations Manager Vicki Jones will closely review all coding and ensure that all emplo...

Reference number: 2024-001 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR part 200, subpart E Corrective Action: The Superintendent Prong Tran, Director of Finance, Scott McRae and Operations Manager Vicki Jones will closely review all coding and ensure that all employees are coded correctly according to funds, salary schedules and the correct calendars. Contact Person: Scott McCrae and Vicki Jones Anticipated Completion Date: June 30, 2025

View Audit 351398 Questioned Costs: $1

Finding 547012 (2024-002)

None 2024

Caribbean University, Inc.

PR

Student Financial Aid

The University reviewed its processes and internal controls and established training for the Register, Financial Aid Office and the Offices of Academic Deans to ensure that this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fi...

The University reviewed its processes and internal controls and established training for the Register, Financial Aid Office and the Offices of Academic Deans to ensure that this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fiscal year.

View Audit 351393

Finding 547011 (2024-001)

None 2024

Caribbean University, Inc.

PR

Student Financial Aid Matching / Level of Effort / Earmarking

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid...

The University experimented numerous personal changes in the Register and Financial Aid Office, resulting complicated the continuity of established policies and processes. However, the University reviewed its processes and internal controls and established training for the Register and Financial Aid Office to ensure this report is submitted within the regularly timeframe. The results of these efforts will be effective during the 2025-2026 fiscal year

View Audit 351393

Finding 547010 (2024-003)

Significant Deficiency 2024

Independent School District No. 601

MN

Internal Control / Segregation of Duties

2024-003 Finding 1. Correcting Plan The District will file each employee’s approved wage rate in their respective personnel file. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent,...

2024-003 Finding 1. Correcting Plan The District will file each employee’s approved wage rate in their respective personnel file. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent, Todd Selk, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP The District will implement November 1, 2024 5. Plan to Monitor Completion of CAP The superintendent will monitor completion of the CAP.

View Audit 351392

Finding 547006 (2024-006)

Material Weakness 2024

West Noble School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: W...

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Operations Officer will prepare the reports and have the Curriculum Director review for accuracy. Anticipated Completion Date: July 1, 2026

View Audit 351382

Finding 547002 (2024-005)

Material Weakness 2024

West Noble School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2024-005 Finding Subject: SPECIAL EDUCATION CLUSTER (IDEA) – PROCUREMENT AND SUSPENSION AND DEBARMENT Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to...

FINDING 2024-005 Finding Subject: SPECIAL EDUCATION CLUSTER (IDEA) – PROCUREMENT AND SUSPENSION AND DEBARMENT Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; Andrew McDaniel, Chief Financial and Operations Officer, West Noble School Corporation, 260-894-3191, mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

View Audit 351382

Finding 546996 (2024-004)

Material Weakness 2024

West Noble School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the fin...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review the directly certified student list from the state and verify that is correctly entered into the school’s software. The Chief Financial Officer will review the list from the state and review the list that is inputted into the school’s software to ensure accuracy. Anticipated Completion Date: September 30, 2025

View Audit 351382

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