Corrective Action Plans

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Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying ...
Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement Procurement Audit Finding: Material Weakness Condition and Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirement. The School Corporation utilizes two vendors for the majority of food and supplies purchases for the food service program. One vendor is procured through a purchasing cooperative, Southwest Indiana Co-op, where the School Corporation is a member. The other vendor met the simplified acquisition threshold for fiscal year 2023 and the small purchase threshold for fiscal year 2024. The School Corporation was unable to provide any supporting documentation for the procurement process undertaken as required by the School Corporation's procurement policy. Management stated the items purchased were chosen based on a comparison of prices with two other vendors, however, management had no documented support for the rationale or process to determine which vendor would be selected for food and supplies purchases. The sample item amount disbursed was $151,511 for food purchases in FY23 and $129,583 for food purchases in FY24. The School Corporation did properly confirm the vendor was not debarred or suspended. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will provide the food service director with quarterly vendor reports so the spending thresholds can be monitored. In the event it is known that expenditures will exceed the threshold, the food service director will work to provide rationale for the vendor choice and/or procure items using the bid/RFP process. Responsible Party for Corrective Action: Tamara L. Asdell, Treasurer Timeline for Completion: Immediately
Suspension and Debarment - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Board review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation o...
Suspension and Debarment - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Board review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CCPS will require verification that an entity isn’t suspended or debarred through sam.gov for every purchase order issued. The documentation with headers and footers showing the date that it is verified will be attached to every purchase order before it is issued and before any payments are made. CCPS policy is to have purchase orders for all transactions except in the case of an emergency. If an accounts payable check is issued without a purchase order, accounts payable will get the sam.gov report from purchasing and attach the report before issuing the check. To ensure that all purchase orders have a suspension and debarment search, the Purchasing Assistant will update the desk reference to include the requirement for a suspension and debarment search to be completed before a purchase order can be issued and that it must be date stamped and attached to each purchase order. Name of the contact person responsible for corrective action: Nelson Sample Planned completion date for corrective action plan: July 2024 If the Department of the Treasury has questions regarding this plan, please call Sherri Fisher-Davis at 301-934-7352.
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Authority will continue to review internal controls and work to design modifications that will increase internal control and the ability to detect material mis...
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Authority will continue to review internal controls and work to design modifications that will increase internal control and the ability to detect material misstatements. Officer Responsible for Ensuring CAP: Executive Director Planned Completion Date: March 2025
The audit engagement letter will include the 90-day requirement for completion of the audit for fiscal year ending June 30, 2025.
The audit engagement letter will include the 90-day requirement for completion of the audit for fiscal year ending June 30, 2025.
CORRECTIVE ACTION PLAN - Recognizing the need/requirement to maintain property records appropriately, the district is working to schedule/complete a comprehensive physical inventory that should assist in identifying the location of equipment funded by the Education Stabilization Fund (ESF), resultin...
CORRECTIVE ACTION PLAN - Recognizing the need/requirement to maintain property records appropriately, the district is working to schedule/complete a comprehensive physical inventory that should assist in identifying the location of equipment funded by the Education Stabilization Fund (ESF), resulting in questioned costs of $2,186,066 per this finding (in addition to all other equipment carried by the district regardless of funding source). The district plans are to continue to work with NEFEC to enact property records within Skyward to capture accurate information and a base starting point per completion of a physical inventory. All property records will then be maintained in Skyward to capture all information required under Federal funding provisions and a reconciliation to physical inventory counts will be prepared no less than every 2 years. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Walter Copeland, Interim CFO
View Audit 349482 Questioned Costs: $1
Finding 538769 (2024-002)
Significant Deficiency 2024
Official withdrawals will be calculated for potential R2T4 upon receipt of notification from the records department. Unofficial withdrawals will be completed within 45 days of receipt of notification from the records department. Financial Aid will keep a record of when a withdrawal is received and w...
Official withdrawals will be calculated for potential R2T4 upon receipt of notification from the records department. Unofficial withdrawals will be completed within 45 days of receipt of notification from the records department. Financial Aid will keep a record of when a withdrawal is received and when R2T4s are processed. This spreadsheet will be checked on a regular basis. R2T4 calculations will be checked for accuracy in Banner by the director or another staff member before submission.
View Audit 349478 Questioned Costs: $1
Finding 538768 (2024-001)
Significant Deficiency 2024
Annually update the college website with contract and/or cost information regarding the third-party provider. Provide contract information URL to ED for publication in the Cash Management Contracts Database.
Annually update the college website with contract and/or cost information regarding the third-party provider. Provide contract information URL to ED for publication in the Cash Management Contracts Database.
Management deposited the underfunded amount in to the replacement reserve account prior to issuance of the audit.
Management deposited the underfunded amount in to the replacement reserve account prior to issuance of the audit.
View Audit 349462 Questioned Costs: $1
Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awarene...
Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awareness: OBT has provided training to all relevant personnel, especially those involved in procurement, expenditure documentation collection, and allocation designation to ensure they understand the requirements of federal awards and the importance of proper documentation. 3. New Technology: OBT Has purchased new technology to better support documentation collection and allocations for all orders made. 4. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement all four steps within this plan by March 31, 2025, with ongoing monitoring and improvement.
View Audit 349461 Questioned Costs: $1
Plan: 1. Mandatory Time and Program Effort Records: OBT will continue to allocate as many staff as possible to a single contract that reflects where they spend 100% of their time. Further, as of July 2025, OBT will only have one such federal contract and this contract has a required staffing patte...
Plan: 1. Mandatory Time and Program Effort Records: OBT will continue to allocate as many staff as possible to a single contract that reflects where they spend 100% of their time. Further, as of July 2025, OBT will only have one such federal contract and this contract has a required staffing pattern of six full-time staff who must spend 100% of their time on this program. 2. Internal Controls: Payroll reports are reviewed every payroll for accuracy. OBT has implemented internal controls to review and verify the accuracy of time and effort records, ensuring that charges to federal awards comply with regulations. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement this plan by March 31, 2025, with ongoing monitoring and improvement.
View Audit 349461 Questioned Costs: $1
Finding 2024-005 – Special Tests and Provisions – Public Housing Waiting List ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA review its policies and procedures surrounding the selections of applicants to ensure compliance with federal, state and loca...
Finding 2024-005 – Special Tests and Provisions – Public Housing Waiting List ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA review its policies and procedures surrounding the selections of applicants to ensure compliance with federal, state and local regulations. The PHA should then develop a documentation system that ensures a clear trail can be provided on the movement of applicants while on the waiting list. Finally, they should ensure that documentation is available for review when requested. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will review our policies and procedures over waitlist management and updated as necessary. We will work with our software provided to obtain the current listing and best practices for maintaining data in the system. Finally, we will conduct an outreach to all applicants on the current list to obtain updated applications and determine eligibility status. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-004 – Special Tests and Provisions – Public Housing Inspections ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA schedule annual inspections to occur in conjunction with the annual recertifications. Alternatively, the PHA could schedule al...
Finding 2024-004 – Special Tests and Provisions – Public Housing Inspections ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA schedule annual inspections to occur in conjunction with the annual recertifications. Alternatively, the PHA could schedule all annual inspections to occur at one time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct a review of our existing inspection procedures and update the timing of inspections to align with the annual recertification dates. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-003 – Special Tests and Provisions – SEMAP reporting ALN 14.871 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA personnel obtain the appropriate training for SEMAP documentation and certification and appropriately document the SEMAP reports in futur...
Finding 2024-003 – Special Tests and Provisions – SEMAP reporting ALN 14.871 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA personnel obtain the appropriate training for SEMAP documentation and certification and appropriately document the SEMAP reports in future years. We also recommend that the PHA utilize the existing computer system to adequately document SEMAP on a regular basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct regular training sessions for staff involved in SEMAP submission process to reinforce proper procedures and documentation management. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear ...
Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear audit trail should be maintained to ensure proper approval, as well as documentation to support the allowability and eligibility of costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will enhance our internal controls over purchasing and Develop detailed procedures for creating, approving, and managing purchase orders. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-001 – Capital Fund Program Accounting– Cash Management & Program Compliance ALN 14.872 – Grant years 2018, 2019, 2021, 2022 – Noncompliance & Material Weakness Recommendation: We recommend that the PHA establish an appropriate cash management procedure that facilitates timely requests ...
Finding 2024-001 – Capital Fund Program Accounting– Cash Management & Program Compliance ALN 14.872 – Grant years 2018, 2019, 2021, 2022 – Noncompliance & Material Weakness Recommendation: We recommend that the PHA establish an appropriate cash management procedure that facilitates timely requests and reimbursements of grant costs as incurred. We also recommend that the applicable PHA staff undergo Capital Fund training to ensure grant requirements are met prior to their deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct a comprehensive review of existing cash management policies and procedures and update policies to align with current best practices and regulatory requirements for the Capital Fund Program. We will ensure that all staff members are informed of the updated policies and receive appropriate training. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The district did not have proper internal controls in place and documentation to track property or capital assets that were purchased with federal grant funds. Conta...
FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The district did not have proper internal controls in place and documentation to track property or capital assets that were purchased with federal grant funds. Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As federal funds are used and expended, property and capital assets that meet or exceed the threshold will be entered on a spreadsheet by the Business Manager or Grant Administrator which will contain a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property Anticipated Completion Date: All expenditures initiated after March 12, 2025
FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants Assistance Listings...
FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - 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; dmason@dkeschools.com 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. E INDIANA STATE BOARD OF ACCOUNTS 25 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
FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the findin...
FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to procurements thresholds, ACS will prepare a policy to follow the necessary federal guidelines. For small purchases, three quotes or bids will be obtained to ensure compliance with the procurement guidelines. For all vendors expected to exceed over $25,000 in expenditures will be kept in a binder by the Special Ed Director to ensure that they are not suspended or debarred from federal awards. The CFO will then review and approve the documentation supporting this via signature. Anticipated Completion Date: June 30, 2025
FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective A...
FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to expenditures for non-public schools, ACS will assign a unique tracking number to each school, allowing expenditures to be easily traced for this requirement. The overall earmarking requirements will be compiled annually by the Special Education Director and sent to the CFO for review and approval, ensuring compliance with the requirements. Anticipated Completion Date: March 31, 2025
FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of C...
FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For eligibility, the federal grants director will prepare the PE report and enrollment and poverty data, and will give to the Assistant Superintendent for review and approval via signature. Anticipated Completion Date: December 31, 2025
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our Information Technology department to ensure the criteria used for triggering the notification emails is correct a...
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our Information Technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the Financial Aid department to review to then send the appropriate notification. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: May 31, 2025
Condition: The College did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The College has begun training additional individuals on the reconciliation process and has updated its procedures to include what documentation needs to be retained on a monthly ...
Condition: The College did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The College has begun training additional individuals on the reconciliation process and has updated its procedures to include what documentation needs to be retained on a monthly basis to ensure accuracy between the amount the College shows as disbursed and the amount the Department of Education shows has been disbursed. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025
Condition: Out of 60 students tested for return to Title IV, we identified 24 students whose calculations were performed incorrectly. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identifying those students ...
Condition: Out of 60 students tested for return to Title IV, we identified 24 students whose calculations were performed incorrectly. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identifying those students who unofficially withdrew. Once the students are identified, individuals with the appropriate skills and knowledge would be able to determine if a Return of Title IV calculation is necessary, and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025
View Audit 349445 Questioned Costs: $1
Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2...
Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2025.
Auditee Response: Management concurs with the finding. We have passed the relevant adjustments to correct the misclassification in our FY24 financial statements. We will also update our accounting policies and procedures Per the Audit recommendation. The adjusted financial statements will be submitt...
Auditee Response: Management concurs with the finding. We have passed the relevant adjustments to correct the misclassification in our FY24 financial statements. We will also update our accounting policies and procedures Per the Audit recommendation. The adjusted financial statements will be submitted to the federal awarding agency by the end of March 2025.
View Audit 349443 Questioned Costs: $1
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