Corrective Action Plans

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The senior accountant will review all expenses before posting to the general ledger.
The senior accountant will review all expenses before posting to the general ledger.
Condition: The Organization has policies and procedures in place that require a Change of Status (COS) form to be completed and approved when an employee's job changes, the allocation of their time between various projects changes, and other payroll modifications. However, the auditors noted multipl...
Condition: The Organization has policies and procedures in place that require a Change of Status (COS) form to be completed and approved when an employee's job changes, the allocation of their time between various projects changes, and other payroll modifications. However, the auditors noted multiple instances where these forms are not completed and provided to the payroll department timely. As a result, the labor distribution reports generated from the payroll system did not have accurate information. The grants were not overbilled, and the allocations used for billing were reflective of the time spent on the program due to the biller detecting the error in the labor distribution reports in their review; however, having incorrect or untimely COS forms creates additional risks in the grant billing and financial reporting. Response: The Organization concurs with the finding. Corrective Action Plan: The Organization agrees with the findings and has implemented procedures to ensure timely receipt of the change of status form by the payroll department. A tracking log of all requested COS’s is maintained by the payroll department to ensure all changes have been entered into the payroll system in the proper period Responsible Official: Gloria Meridew, Director of Finance Anticipated Completion Date: End of FY 2026
Recommendation: CLA recommends the Agency follow established policies to maintain supporting documentation for expenses incurred including their review and approval. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: We ha...
Recommendation: CLA recommends the Agency follow established policies to maintain supporting documentation for expenses incurred including their review and approval. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: We have established a policy to maintain our supporting documentation in our expense management software. We lost our access to Concur when we terminated the contract in March 2025. This finding is related to the Concur system, which we have no access to. Going forward we have the Ramp expense management software that retains all the relevant supporting documentation. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Completed as of January 1, 2025 for all future transactions, implemented via Ramp Software.
The NSWSD Board will include motions and votes pertaining to the approval of federal funding requests in their Meeting Minutes to ensure all Uniform Guidance regulations, relating to allowability, accuracy, and proper authorization of federal expenditure requests, are performed in accordance with fe...
The NSWSD Board will include motions and votes pertaining to the approval of federal funding requests in their Meeting Minutes to ensure all Uniform Guidance regulations, relating to allowability, accuracy, and proper authorization of federal expenditure requests, are performed in accordance with federal regulations.
The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2025-2026 fiscal year.
The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2025-2026 fiscal year.
The grant employee that was hired in this last fiscal year resigned and there was a period that it was handled by the county manager. The county has since contracted with an outside agency to handle the grants far Catron County.
The grant employee that was hired in this last fiscal year resigned and there was a period that it was handled by the county manager. The county has since contracted with an outside agency to handle the grants far Catron County.
The University concurs that costs charged to federal awards must be incurred within the approved period of performance in accordance with Uniform Guidance and the OMB Compliance Supplement. The instances identified during the audit were attributable to personnel turnover within Research and Sponsore...
The University concurs that costs charged to federal awards must be incurred within the approved period of performance in accordance with Uniform Guidance and the OMB Compliance Supplement. The instances identified during the audit were attributable to personnel turnover within Research and Sponsored Programs (RSP), which resulted in isolated lapses in the consistent application of existing period of performance review procedures during the period under audit. Upon identification of these items, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP to address the questioned costs. RSP initiated the process to remove the costs from the affected grants and, where applicable, to consult with the sponsor and refund the disallowed amounts. As part of the corrective action plan, RSP will reinforce existing period of performance controls through targeted communication and training with responsible personnel involved in grant administration and expenditure processing. RSP will continue to perform pre- and post-expenditure reviews to ensure that costs charged to federal awards are incurred within the approved budget period and are appropriately documented. These actions are focused on reinforcing the timing review of expenditures charged to federal awards and are intended to ensure ongoing compliance with Uniform Guidance requirements and to prevent recurrence of the condition.
Context and Cause – During the year ended June 30, 2025, a severance payment was issued to an employee that worked on more than one federal program. The payment was an allowable cost, but was not allocated across the other federal programs based on time and effort per their policy. While internal co...
Context and Cause – During the year ended June 30, 2025, a severance payment was issued to an employee that worked on more than one federal program. The payment was an allowable cost, but was not allocated across the other federal programs based on time and effort per their policy. While internal controls and procedures have been established for payroll expenses, the procedures were bypassed when processing the severance payment. It should be noted that the employee spent the majority of their time on the program the severance was allocated to, and the transaction was isolated. Recommendation – The Organization should follow establish written policies and procedures for allocation of costs. Allocation spreadsheets currently used for the allocation of payroll should be used for all payroll related costs. Action Taken: OMEP will utilize standard allocation procedures for all payroll related payments going forward. Responsible parties: Controller. Anticipated completion date: June 30, 2026.
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a s...
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” We have not adjusted the student’s loan awards given the identification of the overaward took place after the end of the loan period for each student. As the University has closed after August 15, 2025, no additional actions are considered necessary. Completion Date: August 2025 Contact Person: Ann Spall, Chief Financial Officer
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Condition and context: Of the sample of 25 payroll transactions tested (pay amount for an employee for a pay period) for the Special Education Cluster (IDEA), seven transactions were under-charged to the grant as compared to the tim...
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Condition and context: Of the sample of 25 payroll transactions tested (pay amount for an employee for a pay period) for the Special Education Cluster (IDEA), seven transactions were under-charged to the grant as compared to the timesheet, for a total of $1,001, and two transactions were over-charged for a total of $1,559. The net amount over-charged to the grant of the sample tested was $558. Recommendation: SWWF should establish written policies and procedures and provide training to its employees on the policies and procedures for allocating salaries in accordance with Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430. Planned corrective action: Policy and procedures for the allocation of payroll costs to the appropriate program in accordance with Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 will be drafted within the next 15 days. Training of all employees affected will be completed within 15 days of that. Monthly monitoring will be conducted by the Associate Superintendent of Federal Programs, and quarterly by the Chief Financial Officer, to ensure the plan is effective. The Director of Human Resources will ensure all parties are notified of new hires. Our corrective action plan includes: 1) Coverage Plan: We currently have a policy and procedure in place, and have the Associate Superintendent of Federal Grants and the HR Director overseeing the submission of required documents. PARs are submitted semiannually by single-funded personnel and monthly by multi-funded personnel. Once the Associate Superintendent of Federal Programs reviews PARs, WebSmart should be notified, via the ticketing system, if there is a need to update allocations. Note: During the final months of the fiscal year, the Director of the SE Co-op resigned, resulting in a brief lapse in review while training was underway. During the fiscal year, we had a Desk Review where the allocations did not necessarily match what was paid out. The auditor said that so long as the program did not overcharge the federal fund (which it did not), we could allocate to the other non-federal fund. The issue was not to overcharge the federal fund, which we did not. 2) Process Improvement: The notification to Websmart to update allocations will be added to the SWWF procedures. Training is completed within 10 days of the procedure updates. Training will occur before their first payroll, for new employees, by the Associate Superintendent of Federal Programs. 3) Monitoring & Review: In addition to the Associate Superintendent of Federal Programs’ monthly review, the Chief Financial Officer will review allocations quarterly to ensure accuracy. 4) Communication Plan: All employees involved in Time and Effort reporting will be provided with the updated procedures by the Associate Superintendent of Federal Programs. The Director of Human Resources will ensure all appropriate personnel are notified when a new employee begins. Responsible officer: Judyjane Witte, Chief Financial Officer. Estimated completion date: January 31, 2026.
FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity...
FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs - Cost Principles Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs - Cost Principles compliance requirements. Context: During testing payroll disbursements charged to CNC grants, we noted: One selection in a sample of 40 for which the employee was paid above their contracted hourly rate. One selection in a sample of 40 for which the contract sheet for fiscal year 2025 did not include an accurate breakdown for cafeteria employees employed for less than one year and employees employed more than one year. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure controls surrounding salary/hour rate schedules are implemented/enhanced and that rate changes are properly reviewed when instituted. Responsible Party and Timeline for Completion: Betty Huddleston, July 1, 2026
Because of turnover, the School lacked sufficient oversight to ensure that allocations of Title I Part A funding by campus was in compliance with rank-and-serve methodologies. The Director of Special Revenue will work with the finance team to ensure that allocations by campus as in compliance and re...
Because of turnover, the School lacked sufficient oversight to ensure that allocations of Title I Part A funding by campus was in compliance with rank-and-serve methodologies. The Director of Special Revenue will work with the finance team to ensure that allocations by campus as in compliance and review those regularly. Responsible Official: Director of Special Revenue Anticipated Completion Date: February 27, 2026
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the a...
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our earmarking for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to track time and effort logs for individuals servicing our non-public students with disabilities. These are housed in the special education office located at Pierce Middle School. Since staff are performing special education duties only, reports are logged semiannually. NISEC has reported that for the 2023-2024 school year the corrective action plan was implemented fully. Anticipated Completion Date: This was completed fully as of July 1, 2024.
Management agrees with the findings and recommendations, will ensure payroll is allocated correctly going forward. Funds have been transferred.
Management agrees with the findings and recommendations, will ensure payroll is allocated correctly going forward. Funds have been transferred.
Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the U...
Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Actio...
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Action: Management will incorporate written procedures for determining the allowability of costs into the City's Financial Plan document, which already includes a section for City-wide policies related to grant administration. The Finance Director and City Manager are responsible for updating the Financial Plan, and the policy updates will be incorporated along with the adoption of the City's fiscal year 2026-2027 budget prior to June 30, 2026.
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and...
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process wil...
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process will be clearly marked as “void,” and removed from the official support file. Payroll and grant personnel will be instructed on this updated procedure to ensure compliance with 2 CFR 200 documentation standards. FH will perform periodic reviews to confirm consistent application of the revised process. Responsible: GSC Grants Finance Officer Due Date: 02/28/2026
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagre...
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Senior Accountant or Director of Grants and Compliance will conduct the initial review to ensure that match costs are allowable, properly supported, and accurately calculated. The Chief Financial Officer will perform a secondary review and approval to validate completion of the initial review and confirm that reported match amounts reconcile to supporting documentation. Evidence of review will be documented through dated signatures or electronic approval within the grant billing file. Name of the contact person responsible for corrective action: Ashley Freivogel Planned completion date for corrective action plan: September 30, 2026
2025-003 The District will implement procedures to ensure all expenditures are for allowable purposes prior to disbursement. 6/30/2026 Holly Skulich, Treasurer
2025-003 The District will implement procedures to ensure all expenditures are for allowable purposes prior to disbursement. 6/30/2026 Holly Skulich, Treasurer
Finding No. 2025-002 – Documented Review and Approval of Grant Expenditures Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to e...
Finding No. 2025-002 – Documented Review and Approval of Grant Expenditures Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to ensure management documents the review and approval of grant expenditures. Anticipated Completion Date – Completed for fiscal year end June 30, 2026
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are los...
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediatel...
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediately, January 30, 2026.
Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was...
Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.
FINDING SYNOPSIS - During the testing of payroll charged to the Title I program, it was noted that time and effort certifications were not completed or did not contain the proper approvals. ACTION STEPS - The District agrees with the findings and will implement procedures to make sure time and effor...
FINDING SYNOPSIS - During the testing of payroll charged to the Title I program, it was noted that time and effort certifications were not completed or did not contain the proper approvals. ACTION STEPS - The District agrees with the findings and will implement procedures to make sure time and effort documentation is properly documented. CONTACT PERSON - Larry Lovel, Superintendent ANTICIPATED COMPLETION DATE - December 31, 2025
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