Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-001 U.S. Department of Health and Human Services Assistance Listing Number 93.600 ? Head Start Cluster Non-compliance with Reporting Repeat Findings: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of Head Start funds from the Department of Health and Human Services. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 N/A N/A N/A Dollar amount of tested transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,607,236 $4,607,236 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: The County agrees with the finding and will incorporate the auditors? recommendation. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.
Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.