Corrective Action Plans

Finding 560651 (2023-010)

Material Weakness 2023

IN

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

FINDING 2023-010 Finding Subject: Education Stabilization Fund – Allowable Cost/Cost Principles Summary of Finding: To receive reimbursement for ESSER expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Director of Curriculum reviewed it. The documentation at...

FINDING 2023-010 Finding Subject: Education Stabilization Fund – Allowable Cost/Cost Principles Summary of Finding: To receive reimbursement for ESSER expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Director of Curriculum reviewed it. The documentation attached to the reimbursement request; however, did not include the following items: 􀁸 For one teacher, the School Corporation did not provide a Board approved contract or Salary Ordinance showing the approval of this teacher's position as a part-time tutor at $50 per hour. There was only an offer letter to the teacher from the Director of Curriculum. 􀁸 For the purchase of equipment in the amount of $318,922, the School Corporation did not provide a contract instead only a PO with a quote and a letter with the School Board’s approval to purchase. Additionally, there was no indication in the board minutes that this purchase had been put out to bid to the suppliers. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the Business Manager and Director of Curriculum review the reimbursement form each month, an additional check for contracts of all employees paid will be added. All procurement documentation, including contracts, will be added to the archived documentation for purchase orders. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560646 (2023-009)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Non-Profit School Food Service Accounts Summary of Finding: Receipts for the grant were posted to the ledger by one individual without an oversight or review process in place to ensure the remitter, amount, fund, and receipt classification ...

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Non-Profit School Food Service Accounts Summary of Finding: Receipts for the grant were posted to the ledger by one individual without an oversight or review process in place to ensure the remitter, amount, fund, and receipt classification were accurate. Additionally, the same individual received the ACH notifications when monies from monthly meal reimbursements were credited to the School Corporation's bank account and performed the bank reconciliations. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Food Service Director and Business Manager hold a monthly financial meeting to review the food service finances. A report listing all receipts for the previous month to the food service fund will be reviewed at this meeting. This item will be added to the agenda. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560645 (2023-008)

Material Weakness 2023

Shenandoah School Corporation

IN

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

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compl...

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compliance in which the procedures performed at the School Corporation and the resulting supporting documentation provided were insufficient to verify the student's eligibility status of one of three students which were verified during the audit period. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The verification process will be performed by Pam Frost and reviewed by the Business Manager. Anticipated Completion Date: December 31, 2024

View Audit 356534

Finding 560640 (2023-007)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement cla...

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement claim. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will calculate the monthly claims to be submitted to the DOE/CNP and email this information to the Business Manager for review before submittal. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560635 (2023-006)

Material Weakness 2023

Shenandoah School Corporation

IN

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

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension and Debarment Summary of Finding: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative m...

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension and Debarment Summary of Finding: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. INDIANA STATE BOARD OF ACCOUNTS 41 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation could not provide supporting documentation that an adequate number of price or rate quotations was obtained to ensure full and open competition for two vendors procured under the small purchase threshold. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The procurement method used to purchase equipment costing over $10,000 will be documented and archived with the purchase order. Anticipated Completion Date: July 31, 2024

View Audit 356534

Finding 560633 (2023-005)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Eligibility Cash Management § 200.303

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not b...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not being reviewed by an individual other than the individual making the initial determination. As a result, three of forty sampled students received the incorrect eligibility status in the system software when compared to supporting documentation (Direct Certifications and/or income-based applications). Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently all income based applications for free/reduced lunch status are processed by Pam Frost and then reviewed by the Business Manager. Beginning in the 2024-2025 school year Direct Certification students will also be reviewed by the Business Manager. Anticipated Completion Date: August 31, 2024

View Audit 356534

Finding 560628 (2023-004)

Material Weakness 2023

Shenandoah School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403 § 200.430

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the det...

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The School Corporation paid $23,682 of administrative salaries that were allocated to the School Lunch fund based on fixed percentages. There was no supporting documentation to indicate how the percentages were determined or time records indicating time spent on the program by the applicable administrators. INDIANA STATE BOARD OF ACCOUNTS 40 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently 50% of Pam Frost’s salary is paid from the Lunch Fund. A new internal control will be created to document that 50% of her time is spent on food service work and 50% of her time is spent as the ECA treasurer for the elementary school. Anticipated Completion Date: August 31, 2024

View Audit 356534 Questioned Costs: $1

Finding 560623 (2023-003)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the det...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Business Manager and Food Service Director hold a monthly financial meeting to review the status of finances for the Food Service. A review of the payroll distribution reports for the previous month will be added to the agenda of this meeting. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560586 (2023-001)

None 2023

Town of Hammond

NY

Reporting § 200.512

The auditor recommends that the Town ensure compliance with the 9 month requirements and have the audits and single audit reporting package submitted by the end of September each year. The Town plans on submitting all the outstanding years of audits upon completion of its December 31, 2023 audit, w...

The auditor recommends that the Town ensure compliance with the 9 month requirements and have the audits and single audit reporting package submitted by the end of September each year. The Town plans on submitting all the outstanding years of audits upon completion of its December 31, 2023 audit, with submission to the FAC by May 15, 2025.

View Audit 356504

Finding 560569 (2023-005)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-005 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding For one of two reports tested related to fiscal year 2023, the report was not submitted within 30 days of the end of the quarter. Statement of Concurrence or Nonconcurrence Managemen...

Finding 2023-005 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding For one of two reports tested related to fiscal year 2023, the report was not submitted within 30 days of the end of the quarter. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action This late submission was the result of significant turnover in the Town’s Finance Department. All subsequent reports have been filed and will continue to be filed in a timely manner. Name of Contact Person Robert J. Civetti, CPA, Finance Director Projected Completion Date Completed and all reports timely filed since June 30, 2023

View Audit 356492

Finding 560566 (2023-004)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.213 § 200.303

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are ...

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town and School Department will review the district’s suspension and debarment policy and make sure that it is following the criteria as set out in the 2 CFR section 180 of the Uniform Guidance. The policy will then be updated and communicated to all personnel involved in the procurementprocess. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

View Audit 356492

Finding 560563 (2023-003)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Procurement, Suspension & Debarment § 200.1 § 200.303 § 200.318 § 200.319 § 200.320

Finding 2023-003 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within...

Finding 2023-003 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town of Coventry and the Coventry Public Schools will review the current purchasing policies and update them to make sure that the Town and School Department is following the criteria as set out in the 2 CFR sections 200.303 and 200.318 through 200.326. The policy will then be updated and communicated to all personnel involved in the procurement process. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

View Audit 356492

Finding 560562 (2023-003)

Material Weakness 2023

Town of Bellingham, Massachusetts

MA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.326

Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operatin...

Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2023, the Town did not comply with the required procurement policies and procedures in place as it related to one of the expenses charged to the major program. As the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: The Town of Bellingham should address noncompliance and material weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Responsible for Corrective Plan: CFO Estimated Completion Date: January 2025 Action Taken: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

View Audit 356487 Questioned Costs: $1

Finding 560560 (2023-004)

Significant Deficiency 2023

Town of Bellingham, Massachusetts

MA

Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-004 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criter...

Finding 2023-004 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major program (Education Stabilization Fund) it was noted that the time and effort certification for employees tested were not completed. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: Time and Effort Certifications were issued semi-annually. However, in some circumstances staff had terminated employment and letters were not issued outside of the school setting. Identification as a Repeat Finding: 2022-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Responsible for Corrective Plan: Director of Finance, Schools Estimated Completion Date: December 2024 Action Taken: We have amended our process for issuing Time and Effort Certifications. We are now emailing them and if they are returned, we will re-issue to their home address with a self-addressed stamped envelope. In some circumstances such as committee work, we will have the staff sign an acknowledgement at the time of the meeting(s).

View Audit 356487

Finding 560557 (2023-002)

None 2023

Town of Bellingham, Massachusetts

MA

Reporting Internal Control / Segregation of Duties

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Programs Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Trea...

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Programs Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required quarterly reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Responsible for Corrective Plan: Grants Administrator and CFO Estimated Completion Date: January 2024 Action Taken: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

View Audit 356487

Finding 560556 (2023-001)

Significant Deficiency 2023

Town of Bellingham, Massachusetts

MA

Allowable Costs / Cost Principles Significant Deficiency

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteri...

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Responsible for Corrective Plan: Director of Finance, Schools Estimated Completion Date: December 2024 Action Taken: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

View Audit 356487

Finding 560546 (2023-002)

Material Weakness 2023

Mountain State Centers for Independent Living, Inc.

WV

Internal Control / Segregation of Duties

Our organization has established accounting policies and procedures that ensure an indirect cost proposal is filed to U.S. Department of Health and Human Services within six months after the close of each fiscal year, prepared by the organization's Staff Accountant with oversight by the President/ C...

Our organization has established accounting policies and procedures that ensure an indirect cost proposal is filed to U.S. Department of Health and Human Services within six months after the close of each fiscal year, prepared by the organization's Staff Accountant with oversight by the President/ CEO. We are working diligently to complete the indirect cost proposal and submit within 6 months of the financial closing of the accounting records beginning in fiscal year 2024 audited financial statement.

View Audit 356461

Finding 560539 (2023-003)

Material Weakness 2023

Elverado Community Unit School District

CO

Internal Control / Segregation of Duties

The District will segregate duties to the best of its ability and ensure proper oversight by management.

View Audit 356444

Finding 560538 (2023-002)

Material Weakness 2023

Elverado Community Unit School District

CO

Internal Control / Segregation of Duties

The District will implement internal controls procedures and consider hiring a trained individual to ensure complete and accurate financial statements.

View Audit 356444

Finding 560537 (2023-001)

Material Weakness 2023

Elverado Community Unit School District

CO

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

The District will establish policies and procedures to be followed to ensure proper review, approval and recording of federal expenditures.

View Audit 356444

Finding 560487 (2023-001)

Significant Deficiency 2023

Town of Sturbridge, Massachusetts

MA

Questioned Costs Allowable Costs / Cost Principles

Department of Education Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of ...

Department of Education Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that an employee’s payroll charged to the Education Stabilization Fund – ESSER III major program was for services that was not included as part of the grant application/budget. Criteria: Costs charged to the major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of the payroll charged to the major program it was noted that one of the employees charged to the grant was for stipend pay for work as a ELL Coordinator that was charged to the Salaries budget of the grant, which does not support the services charged. Thus the payroll expense would be unallowable. Effect: Town of Sturbridge was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $862.50 Cause: The stipend for the ELL Coordinator was considered salary by the school department. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Sturbridge follow procedures to ensure that payroll expenditures charged to the grant is allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Business and Finance Estimated Completion Date: October 2024 Action Taken: Moving forward the school department bookkeepers will work to ensure expenditures are properly established, funded and within allowable cost guidelines.

View Audit 356376 Questioned Costs: $1

Finding 560486 (2023-002)

Material Weakness 2023

Town of Sturbridge, Massachusetts

MA

Material Weakness Internal Control / Segregation of Duties

Finding 2022-002 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Wh...

Finding 2022-002 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the school department provided time and effort certifications that did not agree to the payroll records, and were not dated at the time of approval. Questioned Costs: Unknown Context: During our test of payroll transactions of the ESSER II and ESSER III grants it was noted that the time and effort certifications did not agree to the payroll records and were not dated. Effect: The Town of Sturbridge was not in compliance with the time and effort certification requirements. Cause: Due to staffing changes, time and effort documents were not completed in a timely manner. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Sturbridge follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and agree with the payroll records, and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Responsible for Corrective Plan: Director of Business and Finance Estimated Completion Date: October 2024 Action Taken: Moving forward the school department bookkeepers will work to ensure time and effort certifications are completely in a timely fashion.

View Audit 356376

Finding 560441 (2023-001)

Material Weakness 2023

Okanogan County Public Heath

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jill Gates Fiscal Coordinator 1234 2nd Ave South Okanogan, WA 98840 (509) 422-7140 Corrective ac...

Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jill Gates Fiscal Coordinator 1234 2nd Ave South Okanogan, WA 98840 (509) 422-7140 Corrective action the auditee plans to take in response to the finding: The District has a Board of Health approved Procurement Policy in place and has followed it since the release of the 2022 Audit Report which was issued September 20, 2023. The District added a suspension and debarment provision to all agreements that include a federal funding component, while still checking the status on Sam.gov. The District also went back and reviewed previous agreements to ensure the entities providing services to the District were not suspended or debarred (none were suspended or debarred). These changes went into effect immediately following the finding issued to the District in September 2023 (resulting from the 2022 Audit Finding). From January 2023-September 2023 the District was unaware of the corrective action necessary due to the timing of the 2022 Audit Report. Therefore, during 2023, this finding was partially corrected and has since been fully corrected. Anticipated date to complete the corrective action: 12/2024

View Audit 356347

Finding 560439 (2023-002)

Significant Deficiency 2023

Kentucky Refugee Ministries, Inc.

KY

Significant Deficiency

Recommendation: KRM should have future audits completed timely and filed timely with the Federal Audit Clearinghouse. Action Taken: KRM continues to take steps to increase the staffing to help with the increased number of refugees served as well as implementing new software changes to streamline ...

Recommendation: KRM should have future audits completed timely and filed timely with the Federal Audit Clearinghouse. Action Taken: KRM continues to take steps to increase the staffing to help with the increased number of refugees served as well as implementing new software changes to streamline processes for more efficient operations.

View Audit 356342

Finding 560432 (2023-002)

Material Weakness 2023

The Center for Black Women's Wellness, Inc.

GA

Procurement, Suspension & Debarment § 200.303

Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement and suspension and debarment is adequately documented for that goods and services purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization shoul...

Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement and suspension and debarment is adequately documented for that goods and services purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization should verify that all vendors under covered transactions are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor’s file. Grantee Response and Corrective Action Plan 2023-002: In response to the audit finding under 2 CFR part 180 regarding the necessity to verify suspension or debarment status in compliance with the excluded parties list system, it is acknowledged that while the Center for Black Women’s Wellness did not previously have a formal policy specifically addressing suspension and debarment, our practices have nonetheless complied with the requirements. Recognizing the importance of formalizing these practices into policy, we are committed to developing and implementing a comprehensive policy that explicitly addresses these checks. This initiative will be integrated with our existing compliance frameworks to ensure consistent adherence across all procurement activities. In line with our recent enhancements in internal controls, including the engagement of a Contractual CFO in 2024, this policy will reinforce our ongoing efforts to uphold the highest standards of compliance and accountability in all our operations. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

View Audit 356331

Corrective Action Plans

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