Corrective Action Plans

Finding 540801 (2024-001)

Material Weakness 2024

South Florida Regional Transportation Authority

FL

Reporting Subrecipient Monitoring Cash Management § 200.502 § 200.508 § 200.510 § 200.71

Condition: The SEFA for the year ended June 30, 2024 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective actions implemented for capital grants will be expanded to include the operating grants. Contact...

Condition: The SEFA for the year ended June 30, 2024 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective actions implemented for capital grants will be expanded to include the operating grants. Contact person responsible for corrective action: Joseph Khouzami Anticipated Completion Date: March 1, 2025

View Audit 350453

Finding 540799 (2024-001)

None 2024

Vanderbilt University

TN

Student Financial Aid Subrecipient Monitoring Reporting

The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2024-001: Notification of Title IV loan disbursements and the borrower’s right to cancel all or part of the loan was not provided ap...

The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2024-001: Notification of Title IV loan disbursements and the borrower’s right to cancel all or part of the loan was not provided appropriately. Management’s View The University agrees with this finding. Two separate issues contributed to the finding. Vanderbilt identified both issues internally and implemented immediate measures to mitigate the impact to students ensuring all notifications are properly delivered prospectively. First, human error, primarily due to incomplete documentation and a new staff member running the process, caused the issue of some loan notifications not being sent. However, the University implemented quality control steps in July of 2024 to resolve the issue. These steps included providing additional training to the staff member, correcting the documentation, and updating the scheduled run control of the process to correctly identify all students with any federal loan disbursement. In addition, the University implemented a quality control process creating a daily report, generated from multiple PeopleSoft queries, that identifies any students who have a federal loan either initially or subsequently disbursed who are missing the required notifications. Second, a data merge issue combined with larger than usual volumes of students receiving loan disbursements caused a processing error resulting in blank information on loan notifications. The initial run in the spring semester included a larger than usual number of students with loan disbursements who shared the same start date, whereas in comparison fall start dates generally are more varied. The University identified this issue in January through manual reviews and manually sent subsequent notifications to affected students. Corrective Action Plan As a corrective measure, Vanderbilt took the following actions to address the identified issues: 1. Reviewed and updated documentation related to the Peoplesoft notification process to ensure completeness and accuracy. 2. Provided additional staff training to the personnel responsible for running the notifications process within Peoplesoft. 3. Created a quality review process to review a daily report from Peoplesoft that identifies any student with a federal loan disbursement that is missing required notifications. 4. Updated queries related to communication generation to run more efficiently. 5. Modified the communication generation process to run nightly instead of weekly to ensure data limits are appropriate to allow the process to run completely and accurately. 6. Created a quality review process to review a weekly report from PeopleSoft to timely identify any missing information in student notifications. Vanderbilt fully implemented the steps above by September 2024. For follow-up questions and information, please contact Brent Tener, Assistant Provost and Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.

View Audit 350451

Finding 540795 (2024-008)

Material Weakness 2024

Rochester Community School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirements. Context: During testing of the Allowable Costs/Cost Principles compliance requirements, there were two vendor vouchers in a sample of 60, where the School Corporation was unable to locate any supporting documentation. These two selections totaled $1,530 charged to the grant. It was further noted that during our testing of payroll costs charged to the COVID-19 – Education Stabilization Fund, for 2 selections in a sample of 40, the School Corporation was unable to provide any support to validate the amount of payroll charged to the grant. These two selections totaled $414 charged to the COVID-19 – Education Stabilization Fund. Corrective Action Plan: The School Corporation will establish a system of internal controls to ensure that documentation is maintained and that expenditures charged to the grant comply with the grant agreement and are allowable. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

View Audit 350448 Questioned Costs: $1

Finding 540793 (2024-006)

Material Weakness 2024

Rochester Community School Corporation

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S...

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation was not able to provide a complete capital asset listing with the required information to support that the equipment purchases of $46,727 and $12,408 with COVID-19 – Education Stabilization Fund ESSER II and ESSER III funds had been added to the capital asset listing. Additionally, the School Corporation was not able to provide support that an inventory of capital assets had taken place at least once in the last 2 year. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the capital asset listing is updated at least annually to include all equipment and real property acquisitions as well as dispositions that took place. The School Corporation will ensure the capital asset listing includes all required information. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

View Audit 350448

Finding 540792 (2024-007)

Material Weakness 2024

Rochester Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identi...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I amount reported on the Year 3 report ($266,367) did not agree to the underlying expenditure record ($96,019) for the period of July 1, 2021 through June 30, 2022. Additionally, the ESSER II and ESSER III amount reported on the Year 2 report ($1,433,207, and $643,771, respectively) did not agree to the underlying expenditure records ($1,400,698, and $630,465 respectively) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($4,291 and $1,522,378, respectively) did not agree to the underlying expenditure records ($4,590 and $1,774,722, respectively) for the period of July 1, 2022 through June 30, 2023. Additionally, the School Corporation was not able to provide any support for the 288 full-time equivalent (FTE) positions on September 30, 2022, reported on the Year 2 CrossAct report or the 338 full-time equivalent (FTE) positions on September 30, 2023, reported on the Year 3 CrossAct report. Crowe also noted that the School Corporation reported 0 full-time equivalent (FTE) positions paid by ESSER on September 2023, but there were ESSER positions reported in the ESSER applications. Corrective Action Plan: The School Corporation will implement a system of internal controls and an effective review process to ensure amounts reported on annual data reports agrees to the underlying transaction detail or other supporting documentation. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect with the next annual data report submission.

View Audit 350448

Finding 540785 (2024-004)

Material Weakness 2024

Rochester Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 8...

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card/High School Graduation Rate Audit Finding: Material Weakness Condition: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Context: The School Corporation had not established internal controls to ensure required documentation to support the reason for a student's removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. For three of the eight students tested, the School Corporation was unable to provide documentation to support the removal of the student from the graduation cohort. Corrective Action Plan: The Head Secretary at Rochester High School will document any student that is removed from the high school graduation cohort. The secretary will have the high school principal review and approve this documentation, and the secretary will place in the student’s permanent file. Person responsible for implementation and projected implementation date: The secretary and the high school principal will be responsible for overseeing the implementation of the corrective action plan, which will start in April 2025.

View Audit 350448

Finding 540784 (2024-003)

Material Weakness 2024

Rochester Community School Corporation

IN

Internal Control / Segregation of Duties Eligibility Material Weakness § 200.303

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbe...

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of eligibility, we noted three out of 25 eligibility samples that were reported as free or reduced socioeconomic status to the Indiana Department of Education in the October 2022 data exchange count, but supporting documentation supported these students as a paid status. These three students should not have been reported as free or reduced socioeconomic status. Corrective Action Plan: The School Corporation will establish a system of internal controls to review the applications submitted for free or reduced socioeconomic status to ensure the students are classified correctly within the system. The School Corporation will ensure that applications are signed off on as reviewed after the review has taken place. Person responsible for implementation and projected implementation date: In cooperation with the Food Service Director, the Curriculum Director and Business Manager will be responsible for overseeing the implementation of the corrective action plan which will be implemented with the applications for the 2025-2026 school year. This has already been implemented with the Food Service Director and records maintained in her office.

View Audit 350448

Finding 540783 (2024-002)

Material Weakness 2024

Rochester Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Oth...

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Context: We noted that for 11 payroll claims in a sample of 60, the School Corporation was not able to provide semi-annual certifications or support that the personnel were approved to be paid with Title I funds. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure semi-annual certifications or other forms of support are maintained to certify employees are approved to be paid with Title I funds. Person responsible for implementation and projected implementation date: The Curriculum Director and Business Manager will oversee the implementation of the corrective action plan, which will be implemented immediately. The CD has already implemented the requirements of certifications beginning August 1, 2025 and are on file in the Title I records.

View Audit 350448

Finding 540781 (2024-005)

Significant Deficiency 2024

Rochester Community School Corporation

IN

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

Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Iden...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Context: The School Corporation did not obtain price or rate quotes for one out of four vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation of vendor contract, bids or the School Corporation's process and rationale for the chosen vendor was not available for audit. Further, the School Corporation could not provide evidence that a suspension and debarment check had been performed on the vendor prior to entering into contract. Corrective Action Plan: The Special Education Director will obtain pricing quotes from the appropriate amount of qualified sources, when cumulative costs are projected to exceed the micro purchase threshold. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Person responsible for implementation and projected implementation date: The Special Education Director, the Business Manager, and the Superintendent will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

View Audit 350448

Finding 540756 (2024-006)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.324

CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a ...

CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District will conduct a cost or price analysis for all contracts over the Simplified Acquisition Threshold of $250,000 before receiving bids and proposals. The timeframe for implementation of this procedure is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540755 (2024-005)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.300

CONDITION: During my review of the District’s compliance with the requirements of the Public-School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods be...

CONDITION: During my review of the District’s compliance with the requirements of the Public-School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, were obtained for the following vendors: Pittsburgh Area Community Schools Deborah Coppula Allegheny Intermediate Unit CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will document at least three price or rate quotations for procurements over $10,000. All procurements over $10,000 will be reviewed by the Superintendent to see evidence that three (3) verifiable price quotes were received before authorizing the requested procurement and will be placed in a file for audit purposes. The timeframe for implementation is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540754 (2024-004)

Material Weakness 2024

Sto-Rox School District

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.320

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the...

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the School District adhere to Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement, as well as the District’s Procurement Policy for Federal Programs (#626.5). MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will maintain procurement records, including why the noncompetitive procurement contract was necessary with appropriate documentation vetted by the District Solicitor. Additionally, the District will conduct an analysis to support that the price paid was reasonable. This analysis is needed to justify procurements that are not competitively bid. The timeframe for implementation is effective immediately.

View Audit 350447 Questioned Costs: $1

Finding 540753 (2024-003)

Material Weakness 2024

Sto-Rox School District

PA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.403

CONDITION: During my review of a random sample of eleven (11) invoices related to the District’s expenditure of federal funds, I noted that there was not an approved purchase order issued in eight (8) of those instances. This is a repeat Finding (2023-003) from the prior fiscal year. CRITERIA: In ...

CONDITION: During my review of a random sample of eleven (11) invoices related to the District’s expenditure of federal funds, I noted that there was not an approved purchase order issued in eight (8) of those instances. This is a repeat Finding (2023-003) from the prior fiscal year. CRITERIA: In accordance with the District’s Procurement Policy for Federal Programs (#626.5), the District shall use properly prepared and approved purchase orders for federal purchases. In addition, Section 2 CFR 200.403(g) of the Uniform Guidance requires that all expenditures (costs) must be adequately documented. RECOMMENDATION: I recommend that the District utilize properly prepared and approved purchase orders for all future federal program purchases in compliance with its Procurement Policy for Federal Programs (#626.5) and Section 2 CFR 200.403(g) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will ensure that purchase order documentation is maintained as part of internal purchasing procedures. Regarding the timeframe for completion, the District has already implemented procedures regarding the documentation of costs and will continue to follow and improve them going forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor documentation procedures to ensure that they are followed appropriately.

View Audit 350447

Finding 540752 (2024-002)

Material Weakness 2024

Sto-Rox School District

PA

CONDITION: The Sto-Rox School District Did not submit a budget revision to the Pennsylvania Department of Education (PDE) for ARP ESSER in instances where 1) variances to the approved budget exceeded 20 percent by function code (9 instances), 2) function code categories remained unspent (5 instances...

CONDITION: The Sto-Rox School District Did not submit a budget revision to the Pennsylvania Department of Education (PDE) for ARP ESSER in instances where 1) variances to the approved budget exceeded 20 percent by function code (9 instances), 2) function code categories remained unspent (5 instances), and 3) there were expenditures coded to unbudgeted function codes (9 instances). CRITERIA: In accordance with Pennsylvania Department of Education regulations, when the expenditure for a function code (line item) exceeds the last approved budgeted amount by 20% or more, the Schol District must submit a budget revision prior to submitting the Final Expenditure Report. In addition, the School District should not begin new programs/services or spend federal grant funds on expenses other than what is in the approved budget until written approval is obtained from the PDE Division of Federal Programs. RECOMMENDATION: I am recommending that the management of the School District implement procedures, as a matter of policy, for the timely submission of budget revisions to PDE when the expenditure for a function code (line item) exceeds the last approved budgeted amount by 20% or more, prior to submitting the Final Expenditure Report. In addition, the implemented procedures should ensure that the School District has measures in place for not beginning new programs/services or spending federal grant funds on expenses other than what is in the approved budget until written approval is obtained from the PDE Division of Federal Programs. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The StoRx School District will implement procedures for timely and accurate reporting of Final Expenditure Reports, budget modifications, and other reporting requirements. The District’s business office, in concert with our Director of Federal Programs, will submit budget revisions for unspent function codes, unbudgeted function codes, and/or function codes with a variance greater than 20 percent for clarity and transparency. If circumstances require the re-opening of previous reports, the District will contact the Regional Coordinator or Technical Administrator from the AIU #3.

View Audit 350447

Finding 540751 (2024-001)

Material Weakness 2024

Sto-Rox School District

PA

Reporting § 200.344

RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE...

RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The StoRx School District will implement procedures for timely and accurate reporting of the Final Expenditure Report (FER). The financial information in the FER will accurately reflect internal reporting information according to the Manual of Accounting and Financial Reporting for Pennsylvania Local Educational Agencies and the PA Chart of Accounts. The timeframe for completion will be effective for the 2024-2025 fiscal year.

View Audit 350447

Finding 540746 (2024-001)

Significant Deficiency 2024

Interfaith Residence D/b/a Doorways and Related Entities

MO

Subrecipient Monitoring HUD Housing Programs Reporting

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity t...

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.

View Audit 350444

Finding 540745 (2024-001)

Significant Deficiency 2024

Biomedical Research Foundation of Northwest Louisiana

LA

Reporting

BRF, LLC believed it was in compliance with federal reporting guidelines and internal policies in the reporting of federal funds as BRF was in communication with the reporting agency regarding late submission and received guidance that submission late was understandable due to the federal holiday sc...

BRF, LLC believed it was in compliance with federal reporting guidelines and internal policies in the reporting of federal funds as BRF was in communication with the reporting agency regarding late submission and received guidance that submission late was understandable due to the federal holiday schedule and federal reporting system technical issues. BRF, LLC will implement the following corrective action: Educate its employees to request and receive formal extension letter for reporting period timelines if technical issues arise with a reporting portal. Michael Mazur, CFO, is responsible for completing the corrective action plan. The Corrective Action Plan has already been communicated with employees and will be recommunicated with employees before September 30, 2025.

View Audit 350435

Finding 540744 (2024-001)

Significant Deficiency 2024

Chicago Urban League

IL

Reporting Internal Control / Segregation of Duties

Corrective Action Plan Finding 2024-001 – Controls over Financial Statement Preparation Organization’s Response: We concur with this finding. Our Controller was absent during the later part of the year and transactions that are normally made were not entered. Going forward we will ensure that all tr...

Corrective Action Plan Finding 2024-001 – Controls over Financial Statement Preparation Organization’s Response: We concur with this finding. Our Controller was absent during the later part of the year and transactions that are normally made were not entered. Going forward we will ensure that all transactions are made by the Senior Accountant and reviewed by the CFO. Name of contact person and title: Curtis A. Whittaker, Sr., CPA Interim CFO Anticipated Completion Date: June 30, 2025

View Audit 350433

Finding 540743 (2024-001)

Material Weakness 2024

County of Glenn

CA

Procurement, Suspension & Debarment

The County’s fiscal staff has been reminded of the suspension and debarment compliance requirement. All contracts submitted for approval to the Department Heads or the Board of Supervisors must contain appropriate documentation that the contractor/vendor is not on the suspended or debarred vendor li...

The County’s fiscal staff has been reminded of the suspension and debarment compliance requirement. All contracts submitted for approval to the Department Heads or the Board of Supervisors must contain appropriate documentation that the contractor/vendor is not on the suspended or debarred vendor list maintained by the General Services Administration. Contracts submitted to the Board of Supervisors will require to have an initialed and dated statement by the Department Head that the contractor/vendor is not debarred or suspended. Departments will retain the original documentation obtained to confirm that the contractor/vendor was not debarred or suspended prior to the approval of the agreement.

View Audit 350429

Finding 540741 (2024-001)

Significant Deficiency 2024

City of Columbia, Missouri

MO

Reporting Significant Deficiency

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirements and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting...

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirements and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting requirements and completed submissions, and notify departments of upcoming submission deadlines. Contact Person: Matthew Lue, Director of Finance. Ancipated Completion Date: This will be accomplished for the fiscal year 2025 year-end.

View Audit 350428

Finding 540734 (2024-003)

Significant Deficiency 2024

Town of Hanover

NH

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Audit Finding Reference: 2024-003 Management’s Response and Planned Corrective Action: The Town agrees with the identified finding and will write and adopt policies and procedures to ensure compliance with the Uniform Guidance and will address: • Determination of allowable costs • Conflict of i...

Audit Finding Reference: 2024-003 Management’s Response and Planned Corrective Action: The Town agrees with the identified finding and will write and adopt policies and procedures to ensure compliance with the Uniform Guidance and will address: • Determination of allowable costs • Conflict of interest • Employee travel • Cash management • Equipment and inventory • Procurement, Suspension and Debarment • Time & effort reporting • Subrecipient monitoring and management Name of Contact Person and Completion Date: Name 1: Ellen Bullion Name 2: Tom Grantham Anticipated Completion Date – 6/30/25, to be fully implemented for FY2026

View Audit 350426

Finding 540732 (2024-006)

Material Weakness 2024

Belcourt Public School District #7

ND

Procurement, Suspension & Debarment § 200.317 § 200.327

2024-006 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be es...

2024-006 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2024-2025

View Audit 350425

Finding 540730 (2024-005)

Material Weakness 2024

Belcourt Public School District #7

ND

Internal Control / Segregation of Duties

2024-005 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The Business Manager and the Special Education Director will collaborate to develop the budget at the beginning of each fiscal year, using the previous year’s expenditures as a baseline. At the conclusion of each quarter...

2024-005 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The Business Manager and the Special Education Director will collaborate to develop the budget at the beginning of each fiscal year, using the previous year’s expenditures as a baseline. At the conclusion of each quarter, they will meet to review the status of the Special Education Budget, ensuring that the current spending aligns with or exceeds the previous year's expenditures. Anticipated Completion Date: Fiscal Year 2024-2025

View Audit 350425

Finding 540727 (2024-004)

Significant Deficiency 2024

Belcourt Public School District #7

ND

Equipment & Real Property Management Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.311 § 200.313

2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior appr...

2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2024-2025

View Audit 350425

Finding 540724 (2024-003)

Material Weakness 2024

Belcourt Public School District #7

ND

Questioned Costs Allowable Costs / Cost Principles

2024-003 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify ...

2024-003 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify that vendor quotes reflect competitive market rates. Purchasing agents and approving administrators will also ensure staff travel requests are electronically filed; all related documentation for all related expenses will be collected. Additional training will be provided to relevant staff on federal expenditure guidelines to prevent future issues. These corrective actions will mitigate the risk of non-compliance and ensure that expenditures are reasonable and necessary for the federal award. Anticipated Completion Date: Fiscal Year 2024-2025

View Audit 350425 Questioned Costs: $1

Corrective Action Plans

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