FAC Explorer

Audit 318354

FY End
2023-08-31
Total Expended
$4.55M
Findings
16
Programs
9
Organization: Northwest Community Action, Inc. (MN)
Year: 2023 Accepted: 2024-09-03
Auditor: Brady Martz & Associates PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
485574 2023-002 Significant Deficiency Yes L
485575 2023-002 Significant Deficiency Yes L
485576 2023-002 Significant Deficiency Yes L
485577 2023-002 Significant Deficiency - L
485578 2023-002 Significant Deficiency - L
485579 2023-003 Significant Deficiency - L
485580 2023-003 Significant Deficiency - L
485581 2023-003 Significant Deficiency - L
1062016 2023-002 Significant Deficiency Yes L
1062017 2023-002 Significant Deficiency Yes L
1062018 2023-002 Significant Deficiency Yes L
1062019 2023-002 Significant Deficiency - L
1062020 2023-002 Significant Deficiency - L
1062021 2023-003 Significant Deficiency - L
1062022 2023-003 Significant Deficiency - L
1062023 2023-003 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
93.600 Head Start $2.32M Yes 2
93.568 Low-Income Home Energy Assistance $1.11M Yes 1
93.276 Drug-Free Communities Support Program Grants $122,648 - 0
81.042 Weatherization Assistance for Low-Income Persons $80,394 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $73,878 - 0
93.569 Community Services Block Grant $57,798 - 0
97.024 Emergency Food and Shelter National Board Program $15,056 - 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $15,003 - 0
10.558 Child and Adult Care Food Program $1,684 - 0

Contacts

Name Title Type
E6ASZKQGTZP4 Sharon Millner Auditee
2185283258 Ashley Engel Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the 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. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reports as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Agency and Subsidiary has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Northwest Community Action, Inc. and Subsidiary under programs of the federal government for the year ended August 31, 2023. The information in this schedule is presented in accordance with the 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 Northwest Community Action, Inc. and Subsidiary, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Northwest Community Action, Inc. and Subsidiary.
Title: CONTRIBUTED SERVICES Accounting Policies: Expenditures reported on the Schedule are reported on the 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. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reports as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Agency and Subsidiary has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Northwest Community Action Inc received significant amounts of services donated by colunteers carrying out the program objectives. No amounts have been reflected in the financial statements for these donated services because the contributed services do not meet the criteria for recognition.
Title: AGENCY OR PASS-THROUGH NUMBER Accounting Policies: Expenditures reported on the Schedule are reported on the 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. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reports as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Agency and Subsidiary has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Pass-through entity identifying numbers are presented where available.
Title: ELIGIBILITY DETERMINATIONS Accounting Policies: Expenditures reported on the Schedule are reported on the 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. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reports as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Agency and Subsidiary has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The Organization assists the State of Minnesota with eligibility determinations for the Low-Income Home Energy Assistance and Low-Income Household Water Assistance programs. Client benefits for Low-Income Home Energy Assistance and Low-Income Household Water Assistance participants are subsequently paid directly the State of Minnesota. For the year ended August 31, 2023, client benefits are in the amount of $931,032 were paid by the state. These amounts are considered federal awards to the Organization and are included in the schedule of expenditures of federal awards but are not included in the statement of activities.

Finding Details

Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-002
2023-002 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600 and Low-Income Home Energy Assistance Program, AL No. 93.568) Criteria – 2 CFR § 200.512(a)(1) states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition – The Agency’s August 31, 2023 audited consolidated financial statements and data collection form were not filed with the Federal Audit Clearinghouse within nine months of the Agency’s fiscal year-end. Questioned Costs – None Context – Northwest Community Action, Inc. and Subsidiary’s August 31, 2023 audited financial statements was not completed as of the due date, therefore the data collection form was not filed timely. Cause – Significant staff turnover causing a delay in the start of the audit. Effect – The Agency is not in compliance with Uniform Guidance requirements. Repeat Finding - This is a repeat finding. Recommendation – We recommend that Northwest Community Action, Inc. and Subsidiary ensure records are reconciled and available for audit within a timely manner at year-end. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.
Finding 2023-003
2023-003 Reporting – Significant Deficiency Federal Program – Department of Health and Human Services (Project Head Start and Early Head Start, AL No. 93.600). Criteria – Head Start requirements state that by the 30th calendar day following the end of each semi-annual period, each grantee must submit a SF-425, Federal Financial Report. The requirements also state that an annual SF-425 Federal Financial Report be submitted no later than 120 calendar days after the end of the project period. Condition – The Agency did not file their semi-annual SF-425, Federal Financial Reports dated January 31, 2023 and July 31, 2023 timely. The Agency also did not file their annual SF-425, Federal Financial Report dated July 31, 2023 timely. Questioned Costs – None Context – This program requires semi-annual SF-425 reports to be submitted within 30 days after the end of the semi-annual period. This program also requires an annual SF-425 report to be submitted within 120 days after the end of the project period. We selected all three SF-425 reports to test and noted that none had been filed by the due date. Cause – The Agency does not have a system in place to ensure all reports are filed timely. Effect – The Agency is not in compliance with reporting for Head Start. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that internal controls over submission of the SF-425 report be implemented to ensure timely reporting. Views of Responsible Officials and Planned Corrective Actions - See corrective action plan for response.