Audit 24860

FY End
2022-06-30
Total Expended
$7.46M
Findings
10
Programs
21
Year: 2022 Accepted: 2022-12-06

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
35343 2022-001 Material Weakness - M
35344 2022-001 Material Weakness - M
35345 2022-001 Material Weakness - M
35346 2022-001 Material Weakness - M
35347 2022-001 Material Weakness - M
611785 2022-001 Material Weakness - M
611786 2022-001 Material Weakness - M
611787 2022-001 Material Weakness - M
611788 2022-001 Material Weakness - M
611789 2022-001 Material Weakness - M

Programs

ALN Program Spent Major Findings
11.307 Economic Adjustment Assistance $1.25M - 0
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $969,104 Yes 0
93.778 Medical Assistance Program $490,670 - 0
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $435,339 Yes 1
17.259 Wia Youth Activities $429,601 - 0
17.258 Wia Adult Program $400,441 - 0
93.791 Money Follows the Person Rebalancing Demonstration $280,059 - 0
11.302 Economic Development_support for Planning Organizations $260,384 - 0
93.053 Nutrition Services Incentive Program $253,767 Yes 1
93.667 Social Services Block Grant $243,330 - 0
12.610 Community Economic Adjustment Assistance for Compatible Use and Joint Land Use Studies $193,485 - 0
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $176,124 - 0
17.278 Wia Dislocated Worker Formula Grants $92,772 - 0
12.611 Community Economic Adjustment Assistance for Reductions in Defense Industry Employment $55,149 - 0
20.516 Job Access and Reverse Commute Program $48,000 - 0
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $30,997 Yes 1
20.205 Highway Planning and Construction $25,042 - 0
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $19,626 - 0
12.617 Economic Adjustment Assistance for State Governments $17,999 - 0
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $4,396 - 0
93.052 National Family Caregiver Support, Title Iii, Part E $2,445 - 0

Contacts

Name Title Type
TC2DMR3JKZ14 Matt Garvin Auditee
4787516160 Pat Muse Auditor
No contacts on file

Notes to SEFA

Title: Loan Program Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the Commission under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, And Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the Commission, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Commission. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Commission received funds from the U.S. Department of Commerce to capitalize the COVID-19 Cares Act Revolving Loan. The expenditure of Federal awards is computed in accordance with the OMB Compliance Supplement for Assistance Listing Number (ALN) 11.307. The amount reported as Federal expenditures for the program is as follows: Balance of loans outstanding at the end of the recipient's fiscal year - $1,169,474Cash and investment balances in the loan program at the end of the recipient's fiscal year - $82,699 Administrative expenses paid out of the loan program during the recipient's fiscal year - $-Total expenditures of the loan program - $1,252,173Multiply by the Federal Share of the loan program - 100%Expenditures of Federal Award, ALN #11.307 - $1,252,173

Finding Details

2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.