Corrective Action Plans

Finding 1155633 (2023-003)

Material Weakness 2023

Philadelphia Area Labor Management Committee

PA

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.302

2023-3 Allowable costs-credit cards – Assistance Listing Number 11.307 Recommendation: We recommend that management implement a more robust internal control system to ensure all federal expenditures are supported by proper documentation. Explanation of disagreement with audit finding: We believe the...

2023-3 Allowable costs-credit cards – Assistance Listing Number 11.307 Recommendation: We recommend that management implement a more robust internal control system to ensure all federal expenditures are supported by proper documentation. Explanation of disagreement with audit finding: We believe the costs referred to were indeed for allowable expenses under the federal program. We will however start to maintain all original source documentation. Action taken in response to finding: Management has required all original source documentation be maintained regardless of dollar amount. Name of contact person responsible for corrective action: Anthony Wigglesworth, Executive Director Corrective action plan has been implemented in 2025.

View Audit 367886 Questioned Costs: $1

Finding 1155632 (2023-002)

Material Weakness 2023

Philadelphia Area Labor Management Committee

PA

Questioned Costs Allowable Costs / Cost Principles § 200.430

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-2 Direct Labor Costs – Assistance Listing Number 11.307 Recommendation: We recommend that the PALM utilize a time management software which integrates with their payroll processing, to easily identify direct labor costs related to the federa...

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-2 Direct Labor Costs – Assistance Listing Number 11.307 Recommendation: We recommend that the PALM utilize a time management software which integrates with their payroll processing, to easily identify direct labor costs related to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a new time management software in 2025 to track and manage direct labor costs relating to the administration of federal programs.

View Audit 367886 Questioned Costs: $1

Finding 1155631 (2023-001)

Material Weakness 2023

Philadelphia Area Labor Management Committee

PA

Reporting Internal Control / Segregation of Duties § 200.512

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-1 Timely submission of Data Collection Form – Assistance Listing Number 11.307 Recommendation: We recommend PALM engage a certified public accountant to conduct a Single Audit as long as the PALM meets the Single Audit criteria Explanation o...

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-1 Timely submission of Data Collection Form – Assistance Listing Number 11.307 Recommendation: We recommend PALM engage a certified public accountant to conduct a Single Audit as long as the PALM meets the Single Audit criteria Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has engaged a certified public accountant to complete a Single Audit and assist in the submission of the data collection form. Name of contact person responsible for corrective action: Anthony Wigglesworth, Executive Director. Corrective action plan has been implemented prior to the due date of the December 31, 2024 data collection form.

View Audit 367886

Finding 1155489 (2023-004)

Material Weakness 2023

Oak Hill United School Corporation

IN

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

FINDING 2023-004 Finding Subject: COVID-19-Education Stabilization Fund - Special Tests and Provisions – Wage Rate Requirements Summary of Finding: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the p...

FINDING 2023-004 Finding Subject: COVID-19-Education Stabilization Fund - Special Tests and Provisions – Wage Rate Requirements Summary of Finding: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling$149,995, was paid for with COVID-19 – Education Stabilization Fund grant funds during the audit period. The contract did not include the required prevailing wage rate clause, nor were the certified payrolls submitted by the contractor. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has no plans nor approved budget for any remaining ESSER funds to be used a manner which would relate to the prevailing wage rate clause. Should the district amend the use of ESSER funding to include such activity the prevailing wage clause requirements will be completed in full. Anticipated Completion Date: Immediately.

View Audit 367782

Finding 1155487 (2023-003)

Material Weakness 2023

Oak Hill United School Corporation

IN

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

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not lim...

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer. Due to the lack of effective internal controls one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation’s ledger had total expenses for the award, for that time period, of $784,638. The lack of controls and noncompliance were isolated to the ESSER III, Year 2 report. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As the finding and error occurred in one entry of one report the district will continue the practice of having a second party review financial system data against report entries. The error in this instance was a misunderstanding of the entry. A secondary review of reporting guidelines and entries will take place prior to submission of any ESSER Data Reporting. Anticipated Completion Date: Upon the next submission of ESSER Data reporting.

View Audit 367782

Finding 1155485 (2023-002)

Material Weakness 2023

Oak Hill United School Corporation

IN

School Nutrition Programs Eligibility § 200.303

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: For one of 40 students receiving free or reduced priced lunches, the eligibility determination was incorrect. The student was classified as reduced; however, the student should have been a regular paying stud...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: For one of 40 students receiving free or reduced priced lunches, the eligibility determination was incorrect. The student was classified as reduced; however, the student should have been a regular paying student. The error was due to an incorrect family size being reported, which caused the classification to be incorrect. The lack of controls and noncompliance was isolated to the one student. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will continue to review eligibility of students for the free and reduced meal program through the state level system. The district will have a secondary individual from the food service department review the eligibility determination following the initial review by the director. Both the director and the secondary individual will sign off on the determination paperwork. Entry into the state system for eligibility calculations will be reviewed for any entry errors. Anticipated Completion Date: All new determinations in the 2024-2025 school year.

View Audit 367782

Finding 1155459 (2023-003)

Material Weakness 2023

Claremont Learning Partnership

NH

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.313 § 200.317 § 200.431

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the...

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: RiverView amended the policy on June 17, 2025, CLP amended the policy on July 3, 2025. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

View Audit 367741

Finding 1155458 (2023-002)

Material Weakness 2023

Claremont Learning Partnership

NH

Procurement, Suspension & Debarment § 200.320

Finding 2023-002: Procurement standards must be followed Plan: The Executive Director received guidance from an additional attorney familiar with school RSAs and now understands that sub-contractors under the direct contractor must also follow the three bid rule. This has been vetted and approved by...

Finding 2023-002: Procurement standards must be followed Plan: The Executive Director received guidance from an additional attorney familiar with school RSAs and now understands that sub-contractors under the direct contractor must also follow the three bid rule. This has been vetted and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all future purchases comply with 2 CFR. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: This was corrected approximately October 2023. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

View Audit 367741

Finding 1155441 (2023-001)

Material Weakness 2023

Promedica Health System and Subsidiaries

OH

Reporting Material Weakness § 200.502 § 200.508 § 200.510

Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Management fully understands the importance of internal controls to ensure the schedule of federal expenditures is complete and accurate. The Grants Dep...

Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Management fully understands the importance of internal controls to ensure the schedule of federal expenditures is complete and accurate. The Grants Department will amend its current written processes regarding award establishment to include requiring documentation indicating an award is federal funds prior to establishing the project in Infor CloudSuite Financials & Supply Management (Accounting software). Additionally, the Grants Department will routinely audit the database the department utilizes to record awards to ensure the field to note federal awards is properly updated. Furthermore, the SEFA will be reviewed with documented sign-off by each member of the Grants Team prior to submission. Contact person responsible for corrective action: Stephanie Cihon Anticipated Completion Date: October 31, 2025

View Audit 367737

Finding 1155440 (2023-002)

Material Weakness 2023

Promedica Health System and Subsidiaries

OH

Procurement, Suspension & Debarment Significant Deficiency § 200.318 § 200.319 § 200.320

Condition: Controls in place were not adequate to ensure the policy included appropriate procurement thresholds and methods. Planned Corrective Action: Management understands the importance of adhering to procurement thresholds and methods. Procurement policies and grant policies will be updated to ...

Condition: Controls in place were not adequate to ensure the policy included appropriate procurement thresholds and methods. Planned Corrective Action: Management understands the importance of adhering to procurement thresholds and methods. Procurement policies and grant policies will be updated to include federal thresholds and methods to reflect federal Uniform Guidance. Contact person responsible for corrective action: Stephanie Cihon and Andy Vollmar Anticipated Completion Date: October 31,2025

View Audit 367737

Finding 1155375 (2023-004)

Material Weakness 2023

Vigo County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment The County had not performed procedures to ensure the vendors were not suspended or debarred or otherwise excluded or disqualified from participation in federal assistance progra...

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment The County had not performed procedures to ensure the vendors were not suspended or debarred or otherwise excluded or disqualified from participation in federal assistance programs or activities during the audit period on all of the 3 vendors determined to have covered transactions, totaling $141,131, that were paid with SLFRF funds. Contact Person Responsible for Corrective Action: Larry Hutchings Larry.hutchings@vigocounty.in.gov 812-462-3361 Views of Responsible Officials: We concur with the findings Description of The Corrective Action Plan: The Auditors Office has created a Policy for Suspension and Debarment within the Subrecipient Ploicy. A clause or condition must also be included in the covered transaction with that entity to require reporting of any debarment or suspension occurring during the subgrant period; and, Maintain documentation to support the verification was done before or at the time of contract execution. Anticipated Completion Date – 08/13/2025

View Audit 367621

Finding 1155374 (2023-003)

Material Weakness 2023

Vigo County

IN

Subrecipient Monitoring § 200.303

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring The County received an allocation of the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Department of the Treasury to support its response and recovery fro...

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring The County received an allocation of the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Department of the Treasury to support its response and recovery from the novel coronavirus. A portion of the County's allocation was then used to subaward funds to another entity (i.e., the subrecipient) to carry out an eligible use. The County did not have policies and procedures in place to perform monitoring procedures of the subrecipients. Contact Person Responsible for Corrective Action: Larry Hutchings larry.hutchings@vigocounty.in.gov 812-462-3361 Views of Responsible Officials: We concur with this finding : Description of The Corrective Action Plan: The Auditors Office has created a subrecipient policy The Auditor’s Office requires all departments who contract with subrecipients to complete a Subrecipient Contractor Checklist on a fiscal year basis. Anticipated Completion Date – 08/13/2025

View Audit 367621

Finding 1155312 (2023-018)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring Special Tests & Provisions

The Department will continue to explore ways to streamline the process. Furthermore, the Department is no longer responsible for ESG pass-through funds.

View Audit 367551

Finding 1155311 (2023-017)

Material Weakness 2023

The City of Frederick, Maryland

MD

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payro...

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payroll for allocation to appropriate grant funds. The PAR will be retained by Payroll as backup.

View Audit 367551

Finding 1155310 (2023-016)

Material Weakness 2023

The City of Frederick, Maryland

MD

Reporting Material Weakness

A standardized reconciliation process has been recated by our grant accountant to ensure all project and expenditure reports are aligned.

View Audit 367551

Finding 1155309 (2023-015)

Material Weakness 2023

The City of Frederick, Maryland

MD

Questioned Costs Subrecipient Monitoring Eligibility

All expenditures will be verified prior to disbursement to ensure they are paid within the defined grant period.

View Audit 367551 Questioned Costs: $1

Finding 1155308 (2023-014)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring Eligibility Reporting

The Maryland Departments of Human Services (DHS) and Housing and Community Development (DHCD) are the direct recipient of the federal funds for OHEP and WAP, respectively. Because of this, all verification occurs on the state level and HHS does not have access to all pertinent information. As the re...

The Maryland Departments of Human Services (DHS) and Housing and Community Development (DHCD) are the direct recipient of the federal funds for OHEP and WAP, respectively. Because of this, all verification occurs on the state level and HHS does not have access to all pertinent information. As the recipient of these funds, HHS is informed by DHS or DHCD when a Crisis Client is to be served by HHS. HHS is not responsible for the verification of Crisis Client eligibility for either program.

View Audit 367551

Finding 1155307 (2023-013)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring Reporting Significant Deficiency

SharePoint is being utilized to track reporting requirements to ensure timely filings. The Department will continue to explore ways to streamline the process. However, final numbers for the prior month are typically not available until the second week after the close of the month. This is complicate...

SharePoint is being utilized to track reporting requirements to ensure timely filings. The Department will continue to explore ways to streamline the process. However, final numbers for the prior month are typically not available until the second week after the close of the month. This is complicated by the need for controls in place to ensure the final numbers are correct.

View Audit 367551

Finding 1155306 (2023-012)

Material Weakness 2023

The City of Frederick, Maryland

MD

Cash Management

The City is no longer receiving advance funds. Therefore, no interest is being earned.

View Audit 367551

Finding 1155305 (2023-011)

Material Weakness 2023

The City of Frederick, Maryland

MD

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payro...

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payroll for allocation to appropriate grant funds. The PAR will be retained by Payroll as backup.

View Audit 367551

Finding 1155304 (2023-010)

Material Weakness 2023

The City of Frederick, Maryland

MD

Reporting

The Department has instituted a policy to maintain electronic back-ups of all documentation utilized to submit all federal reports. The electronic copies are backed up on a SharePoint service. Additionally, the Finance Staff will review the FFR prior to submission.

View Audit 367551

Finding 1155303 (2023-009)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring

The Department will include language in all grant agreements notifying subrecipients that entities with federal funds in excess of $750,000 are subject to Single Audit requirements. Subrecipients will also be required to provide copies of their most recent Single Audit as a condition of award and wi...

The Department will include language in all grant agreements notifying subrecipients that entities with federal funds in excess of $750,000 are subject to Single Audit requirements. Subrecipients will also be required to provide copies of their most recent Single Audit as a condition of award and will be verified in the Federal Audit Clearinghouse.

View Audit 367551

Finding 1155302 (2023-008)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring

All subaward grant agreements are now required to contain a provision outlining all federal conditions of the funds, including relevant regulations with 2 CFR Part 200, otherwise known as Uniform Guidance.

View Audit 367551

Finding 1155301 (2023-007)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring

The Department will outline the selection process within the Notice of Funding Availability. Furthermore, a monitoring schedule will be created, and program staff are required to review all reports submitted by the subrecipient.

View Audit 367551

Finding 1155300 (2023-006)

Material Weakness 2023

The City of Frederick, Maryland

MD

Reporting Subrecipient Monitoring Significant Deficiency

The Department has instituted a policy that FFRs must be submitted within 30 days of the end of the quarter. This will allow for any unforeseen circumstances that may delay submission.

View Audit 367551

Corrective Action Plans

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