Corrective Action Plans

Finding 524507 (2024-001)

Significant Deficiency 2024

OR

Finding Reference #: 2024-001 Federal Award Agency: Department of Agriculture Rural Housing Service Name of Contact Person: Paula Maden Corrective Action: 1) Establish workout plan with RD for Carson Springs, White Cap and Wy East Vista. Plan will include pause of reserve deposits. Date of Plann...

Finding Reference #: 2024-001 Federal Award Agency: Department of Agriculture Rural Housing Service Name of Contact Person: Paula Maden Corrective Action: 1) Establish workout plan with RD for Carson Springs, White Cap and Wy East Vista. Plan will include pause of reserve deposits. Date of Planned Corrective Action: 1/1/2025 Submitted by: Paula Maden

View Audit 343890

Finding 524499 (2024-002)

Significant Deficiency 2024

Franklin Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.

View Audit 343871

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524493 (2024-002)

Significant Deficiency 2024

Rogue Community College

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate report...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the student’s last date of attendance did not agree to the student’s withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Anticipated Completion Date: June 25, 2025

View Audit 343860

Finding 524492 (2024-005)

Material Weakness 2024

Henning Public School District 545

MN

Internal Control / Segregation of Duties Material Weakness Matching / Level of Effort / Earmarking

Contact Person – Melissa Sparks, Superintendent Corrective Action Plan – The District staff will work with the construction manager to ensure wage rates requirements are monitored. Completion Date – June 2025

View Audit 343854

Finding 524490 (2024-001)

Significant Deficiency 2024

Hoke County, North Carolina

NC

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Finding: 2024-001 Name of Contact Person: Diane Simmons, Program Integrity Supervisor Corrective Action/Management’s Response: Management agrees with the audit finding. The Program Integrity Investigator will ensure that all documentation and evidence relative to the case is scanned into NCFAST u...

Finding: 2024-001 Name of Contact Person: Diane Simmons, Program Integrity Supervisor Corrective Action/Management’s Response: Management agrees with the audit finding. The Program Integrity Investigator will ensure that all documentation and evidence relative to the case is scanned into NCFAST under the Program Integrity Investigative Case. The Invesitgator will complete the DSS-1682 and review for accuracy prior to submitting the form to the Program Integrity Supervisor for approval. The Program Integrity Supervisor will complete a second party review of all DSS-1682’s and documentation to ensure that investigations and forms are completed correctly and timely. The Program Integrity Investigator will enter the claim into NCFAST after approval by the Supervisor. The second party review results will be reviewed with Program Integrity Staff monthly. Remedial training will be conducted if any errors are found. Proposed Completion Date: the above mentioned procedures will be Implemented immediately.

View Audit 343849

Finding 524488 (2024-002)

None 2024

Mhmr Services for the Concho Valley

TX

Reporting

The Center has a new CFO for 2025. The CFO and one additional staff member have received their certification for 2025 along with the original employee. The CFO will ensure that multiple personnel are trained and that all certifications are kept up to date.

View Audit 343841

Finding 524484 (2024-004)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Recommendation: All debt, fixed assets and accounts payable should be reconciled monthly

View Audit 343825

Finding 524483 (2024-003)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Cash Management Matching / Level of Effort / Earmarking

Recommendation: Request reimbursement of loans throughout the project.

View Audit 343825

Finding 524482 (2024-002)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Recommendation: A standard monthly entry would provide the financial statements with an adequate representation of the depreciation expense per month.

View Audit 343825

Finding 524481 (2024-001)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Internal Control / Segregation of Duties Reporting Special Tests & Provisions

Recommendation: To correct these deficiencies, management would need to hire personnel with adequate accounting experience to perform these functions. The Town would need to weigh the costs of these corrections verse the benefit.

View Audit 343825

Finding 524469 (2024-002)

Significant Deficiency 2024

Baldwin-Whitehall School District

PA

Internal Control / Segregation of Duties HUD Housing Programs School Nutrition Programs

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 1...

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 15009 Audit period: June 30, 2024 The findings for the year ended June 30, 2024 schedule of findings are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section B – Financial Statement Findings 2024-1 Best Practices Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. Recommendation: We recommend that the District strongly encourage the tax collectors to obtain a SOC report in order to ensure proper controls are in place. Management’s Response: The School District understands the importance of obtaining SOC reports from service organizations and will continue to inquire of the appropriate entities to ensure they obtain the proper reports. In discussion with the Delinquent Tax Collector, they notified the District that it is extremely cost prohibitive for them to go through a review that would end with the issuance of a SOC report. Section C – Major Federal Award Findings 2024-2 Segregation of Duties – Child Nutrition, Title I, ESSER Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. If you have questions about this report or need additional financial information, please contact Mark Cherpak, Business Manager at: 4900 Curry Road Pittsburgh, PA 15236 412-884-6300

View Audit 343824

Finding 524468 (2024-001)

Significant Deficiency 2024

The Colleges of Law

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343821

Finding 524467 (2024-001)

Significant Deficiency 2024

Realife Cooperative of Phalen Village

MN

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 343816

Finding 524461 (2024-005)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Subrecipient Monitoring Material Weakness Reporting

Beginning March 2025, the City's Finance department will review and sign off on any annual financial reports submitted to the U.S. Department of Treasury. The City will provide training to appropriate staff that Finance Departmental review is required.

View Audit 343795

Finding 524460 (2024-004)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Procurement, Suspension & Debarment § 200.303

Beginning March 2025, prior to entering into a covered transaction, the City will verify that its vendors are not suspended or debarred or otherwise excluded from participating in the transaction, when utilizing federal grant dollars. The City will accomplish this by by checking the System for Awar...

Beginning March 2025, prior to entering into a covered transaction, the City will verify that its vendors are not suspended or debarred or otherwise excluded from participating in the transaction, when utilizing federal grant dollars. The City will accomplish this by by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov. The City will provide training to appropriate staff of this requirement.

View Audit 343795

Finding 524459 (2024-001)

Significant Deficiency 2024

Planned Parenthood of St. Louis Region and Southwest Missouri

MO

Allowable Costs / Cost Principles

- Planned Parenthood of the St. Louis Region and Southwest Missouri is implementing a monthly after-the-fact review process and control to ensure that the salary expense charged to the grant is reasonable based on actual time and effort of the employees performing procedures for the grant program

View Audit 343776

Finding 524448 (2024-002)

Significant Deficiency 2024

Big Beaver Falls Area School District

PA

Internal Control / Segregation of Duties HUD Housing Programs School Nutrition Programs

CORRECTIVE ACTION PLAN

View Audit 343773

Finding 524447 (2024-001)

Significant Deficiency 2024

National 4-H Council

DC

Questioned Costs Subrecipient Monitoring § 200.1 § 200.211 § 200.303 § 200.332

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial managemen...

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

View Audit 343772 Questioned Costs: $1

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524440 (2024-002)

Material Weakness 2024

The Housing Authority of the City of Warner Robins

GA

HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2025.

View Audit 343759

Finding 524439 (2024-001)

None 2024

The Housing Authority of the City of Warner Robins

GA

HUD Housing Programs Eligibility Reporting

The Authority has responded to HUD’s Review Report Findings with specific corrective actions including opening and utilizing additional bank accounts to limit inter-program activity and provide additional clarity and transparency to transactions. The Authority will continue executing its corrective...

The Authority has responded to HUD’s Review Report Findings with specific corrective actions including opening and utilizing additional bank accounts to limit inter-program activity and provide additional clarity and transparency to transactions. The Authority will continue executing its corrective actions. Additionally, the Authority will continue working with HUD’s Quality Assurance Team (QAT) to implement any additional recommendations HUD may have. The Authority’s Executive Director, Africa Porter has assumed the responsibility of executing the corrective actions and any additional recommendations HUD may have and anticipates resolution as of June 30, 2025.

View Audit 343759

Finding 524438 (2024-001)

Significant Deficiency 2024

Equitas Health, Inc. and Subsidiaries

OH

Reporting Program Income § 200.307 § 200.328

The Organization will review the terms and conditions of all federal awards to determine if program income is applicable to the federal program. For such federal programs, the Organization will ascertain the requirements for determining or assessing the amount of program income, and the requirements...

The Organization will review the terms and conditions of all federal awards to determine if program income is applicable to the federal program. For such federal programs, the Organization will ascertain the requirements for determining or assessing the amount of program income, and the requirements for recording and using program income. If required in accordance with the program, the Organization will implement a process for tracking and reporting the program income generated and used during the fiscal year. Further, the Organization will add another level of review of financial reports to ensure that program income is properly reported in accordance with the terms and conditions of the award. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Jeffery McNeal, Chief Financial Officer

View Audit 343757

Finding 524437 (2024-002)

Significant Deficiency 2024

City of Riverside

CA

The City has corrected the reporting in its subsequent report. On December 5, 2024, City staff held a meeting with the U.S. Department of the Treasury to clarify reporting requirements and to address the correction of the revenue replacement category. Since the Treasury portal does not allow for adj...

The City has corrected the reporting in its subsequent report. On December 5, 2024, City staff held a meeting with the U.S. Department of the Treasury to clarify reporting requirements and to address the correction of the revenue replacement category. Since the Treasury portal does not allow for adjustments to prior periods, all projects under the revenue replacement category were included in the 4th quarter project and expenditure report (October–December 2024). This report includes all required details, such as current period obligations and expenditures, as well as cumulative obligations and expenditures.

View Audit 343752

Finding 524434 (2024-003)

Significant Deficiency 2024

Payne Theological Seminary

OH

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: April 2025

View Audit 343723

Corrective Action Plans

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