Corrective Action Plans

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2024-002. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 Condition: Subpart E, 2 CFR §20...
2024-002. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee's compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or the equivalent is the most effective way to comply with this requirement. The Organization did not prepare PARs or equivalent documentation. Recommendation: The Organization should maintain PARs or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Corrective Action: The Organization will modify procedures to have time records reflect actual time worked by employees on PAR equivalent documentation, which will serve as support for personnel expenses funded by federal awards. Responsible Contact Person(s): Louis Bamonte, Director of Finance Brighter Tomorrows, Inc., - P.O. Box 706 – Shirley, New York 11967 Anticipated Completion Date: December 31, 2025.
2024-001. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 Condition: The Organization did...
2024-001. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 Condition: The Organization did not have written policies referencing the Uniform Guidance requirements. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Corrective Action: The Organization will update the written policies and procedures to comply with the Uniform Guidance requirements. Responsible Contact Person(s): Louis Bamonte, Director of Finance Brighter Tomorrows, Inc., - P.O. Box 706 – Shirley, New York 11967 Anticipated Completion Date: December 31, 2025.
An error was identified in the Excel spreadsheet (Model) used to allocate technology costs to projects where Coleridge is obligated to provide Administrative Data Research Facility (ADRF) services. The effect of this error was costs were under-allocated to projects. Corrective Action Plan: 1. The er...
An error was identified in the Excel spreadsheet (Model) used to allocate technology costs to projects where Coleridge is obligated to provide Administrative Data Research Facility (ADRF) services. The effect of this error was costs were under-allocated to projects. Corrective Action Plan: 1. The error in the Model has been corrected. 2. Control checks will be built into the Model to highlight when calculations are not working, or outputs fall outside expected ranges. 3. On a monthly basis, the Controller will review the Model and sign off in writing that the allocations are correct. No invoices will be released until the review and sign-off has been completed. 4. On an annual basis, an internal audit will be performed on the Model to validate that calculations are working as intended. The audit will be conducted by a member of the Finance department who is not a user of the Model. Any issues identified during the audit will be documented. The Controller will take action to remediate all issues and certify in writing when this work has been completed. No invoices will be released until the certification has been completed.
View Audit 369626 Questioned Costs: $1
Finding 2024-001: Written Uniform Guidance Policies Responsible Individuals: Autumn Gregory, Executive Director Corrective Action Plan: The Organization developed and approved written Uniform Guidance policies as of January 2025. Anticipated Completion Date: December 31, 2025
Finding 2024-001: Written Uniform Guidance Policies Responsible Individuals: Autumn Gregory, Executive Director Corrective Action Plan: The Organization developed and approved written Uniform Guidance policies as of January 2025. Anticipated Completion Date: December 31, 2025
Audit Finding: During the 2024 audit, it was noted that there was a miscalculation in the facility use expenses charged to grants. While the error was not material, it highlights a need for improved oversight to prevent future errors. Root Cause: The spreadsheet used to calculate facility use expens...
Audit Finding: During the 2024 audit, it was noted that there was a miscalculation in the facility use expenses charged to grants. While the error was not material, it highlights a need for improved oversight to prevent future errors. Root Cause: The spreadsheet used to calculate facility use expenses was not reviewed or verified by a second party prior to posting, which led to a calculation error. Corrective Action: Beginning in Quarter 4 of 2025, the facility use expense calculation spreadsheet will be reviewed and verified by a second staff member prior to submission or charging to grants. The reviewer will sign off (physically or electronically) to confirm accuracy of the calculation and grant allocation. Responsible Parties: Allison Hrestak, COO Tina Fornstrom, Business Manager Implementation Date: October 1, 2025 (start of Q4 2025) Ongoing Monitoring: The COO will conduct periodic spot checks (quarterly) to ensure the review and sign-off process is consistently followed. The Business Manager will conduct monthly reviews on the SALBENT AX workbook and facility use workbook for accuracy. Expected Outcome: This added level of review is expected to prevent future calculation errors, ensure accurate cost allocations to grants, and strengthen internal controls related to expense tracking.
Finding 2024-002 – Material Weakness – Inadequate Documentation Condition We selected a sample of both payroll and nonpayroll related expenditures for controls and compliance. During our testing of payroll expenditures, there were five instances out of 11 in which a timesheet or other documentation ...
Finding 2024-002 – Material Weakness – Inadequate Documentation Condition We selected a sample of both payroll and nonpayroll related expenditures for controls and compliance. During our testing of payroll expenditures, there were five instances out of 11 in which a timesheet or other documentation could not be located to support a payment made to an employee. During our testing of nonpayroll related expenditures, there were three instances out of 18 in which an invoice for the selected expenditure lacked proper documented approvals. Recommendation All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and internal control policies. Management should check to ensure all federal grant expenditures are properly approved and have supporting documentation. Management’s Corrective Action Plan The Corporation has experienced staff turnover which resulted in process challenges. Nevertheless, the Corporation will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Corporation resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. Contact Person: Richonda Pelzer, Chief Financial Officer Anticipated Completion Date: March 31, 2026
View Audit 369593 Questioned Costs: $1
Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to en...
Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to ensure timely calculation. Contact Person Responsible for Correction Action: Stanley Kihara, Controller Completion Date:
Internal Control over Compliance and Other Matters Recommendation: We recommend that the Organization implement adequate controls to ensure the timely submission of the required granter reports. If delays, with the submission of a report, occur, we recommend that the Organization notifies its grante...
Internal Control over Compliance and Other Matters Recommendation: We recommend that the Organization implement adequate controls to ensure the timely submission of the required granter reports. If delays, with the submission of a report, occur, we recommend that the Organization notifies its granter and obtains an extension of the report due date. There is no disagreement with the audit finding. Action planned in response to finding: Essex-Newark Legal Services Project, Inc agrees that it will timely advise granters when a delay in the timely submission of a report is anticipated. Name of the contact person responsible for corrective action: Felipe Chavana, Executive Director Planned completion date for corrective action plan: Effectively Immediately.
CONDITION: During my review of the Borough of Ellwood City’s internal controls over federal awards, I noted that the Borough does not have formal written policies and procedures surrounding the management of their federal award funds. Although not all-inclusive, an example of some of the required po...
CONDITION: During my review of the Borough of Ellwood City’s internal controls over federal awards, I noted that the Borough does not have formal written policies and procedures surrounding the management of their federal award funds. Although not all-inclusive, an example of some of the required polices would include written procedures for procurement, conflict of interest, and allowable costs. This is a repeat finding (2023-001) from the prior year.CRITERIA: Section 2 CFR 200.303 of the Uniform Guidance requires non-federal entities such as the Borough of Ellwood City to maintain effective internal controls over federal awards. In addition, the Uniform Guidance also recommends these internal controls follow guidance in Standards for Internal Control in the Federal Government (the Green Book), issued by the Comptroller General of the United States.RECOMMENDATION: I recommend that the Borough of Ellwood City adopt the required written policies and procedures surrounding the management of federal award funds as prescribed by Section 2 CFR 200.303 of the Uniform Guidance. The focus of these policies and procedures should be to ensure that the Borough officials who are responsible for carrying out the objectives of the federal financial award understand 1) the federal statutes, regulations, and terms and conditions of the award, 2) how to evaluate and properly monitor compliance, and 3) the steps to take if noncompliance is identified.MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the Borough will begin the process of reviewing Section 2 CFR 200.303 of the Uniform Guidance with the objective of understanding what specific policies and procedures surrounding the management of their federal award funds are required. As recommended, the focus of these policies and procedures will be to ensure that the Borough officials who are responsible for carrying out the objectives of the federal financial award understand 1) the federal statutes, regulations, and terms and conditions of the award, 2) how to evaluate and properly monitor compliance, and 3) the steps to take if noncompliance is identified. The timeframe for researching the required written policies and procedures of the Uniform Guidance, and the development and implementation of these written policies and procedures will cover the period including the last quarter of calendar year 2025 through and including the 2nd quarter of calendar year 2026.Borough Officials responsible for the implementation of the Corrective Action Plan:Kevin Swogger, Borough Manager.
Management will enforce a standardized reimbursement packet review checklist, requiring documented approval prior to submission. All reimbursement packets will be stored electronically in a central repository. Training will be provided to all accounting staff on documentation standards. Periodic sup...
Management will enforce a standardized reimbursement packet review checklist, requiring documented approval prior to submission. All reimbursement packets will be stored electronically in a central repository. Training will be provided to all accounting staff on documentation standards. Periodic supervisory reviews will be performed to confirm compliance.
We agree with the above mentioned finding. All vendors were checked and none of the vendors paid with federal funds were suspended or disbarred but no documentation was maintained. For the subrecipient monitoring calls were made and inquiry on an ongoing basis but no documentation was maintained the...
We agree with the above mentioned finding. All vendors were checked and none of the vendors paid with federal funds were suspended or disbarred but no documentation was maintained. For the subrecipient monitoring calls were made and inquiry on an ongoing basis but no documentation was maintained there as well. Policies have been put into place for suspension and debarment to be included in all contracts and those vendors with no contracts a search for suspension and debarment will take place before any purchases. Policies have also been put into place to have a uniform spreadsheet to document the monitoring of all subrecipients.
The Just One Project's CSFP team will maintain a filing system organized by service site, alphabetical client name, and month and year of registration. The team will also utilize the Salesforce system to track registered clients, recertification dates, and services provided each day. Effective immed...
The Just One Project's CSFP team will maintain a filing system organized by service site, alphabetical client name, and month and year of registration. The team will also utilize the Salesforce system to track registered clients, recertification dates, and services provided each day. Effective immediately, designated CSFP staff will visit all active distribution sites each business day to collect new registration and recertification forms, cross-check them and previously filed forms against the day's Salesforce distribution list, and file new forms in the designated system. This will ensure every client record is complete and current. In addition, the team will conduct an internal audit at least annually to confirm that all participant files contain required documents and certifications, promptly address any deficiencies, and document corrective steps. Staff will also receive periodic refresher training to reinforce record-keeping standards and sustain compliance.
Individual(s) Responsible: Enrique Martinez, Grant Manager and Program Director Action: Management will implement a process to ensure all expenditures are properly documented and reviewed for allowability before being charged to the Program. Staff will be trained on documentation and compliance requ...
Individual(s) Responsible: Enrique Martinez, Grant Manager and Program Director Action: Management will implement a process to ensure all expenditures are properly documented and reviewed for allowability before being charged to the Program. Staff will be trained on documentation and compliance requirements. Internal controls will be strengthened to prevent unallowable costs. Anticipated Completion Date: December 31, 2025
View Audit 369484 Questioned Costs: $1
The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. To correct this, TRAC has implemented a Position Control Update process: any change to an employee’s grant allocation must be documented on a Position Control Upd...
The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. To correct this, TRAC has implemented a Position Control Update process: any change to an employee’s grant allocation must be documented on a Position Control Update form, signed by the Finance Director, and entered into the payroll system within 5 business days of the change. Additionally, the Finance team performs monthly reconciliations between timecards, payroll registers, and the general ledger to ensure that payroll charges are accurate and properly supported before being billed to grants. Completion Date: October 1, 2025. Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations
At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervi...
At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervisor approvals of timecards within the time keeping system. Additionally, the organization has and will continue to implement a thorough review process that will include the following:  Employee acknowledgement of their individual grant allocation  Employee approval of their timecard  Manager acknowledgment of their individual grant allocation as well as the allocation of each employee they supervise  Manager approval of each employee’s timecard  The finance team will review each timecard individually prior to charging salary costs to grants. This process ensures that time and effort documentation is complete, approved, and compliant with federal and state requirements. Compliance with this policy will be monitored monthly by the Finance Director to ensure continued adherence.Completion Date: October 1, 2025.Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporti...
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporti...
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative guidelines, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.
View Audit 369464 Questioned Costs: $1
All five (5) properties were SOLD
All five (5) properties were SOLD
View Audit 369463 Questioned Costs: $1
To ensure compliance with grant requirements and address the issue with employee timecards and vouchers submitted, the following steps will be implemented: 1. Time Tracking: Employees will continue to be required to record their time every two weeks (through HourTimeSheet), ensuring that the hours w...
To ensure compliance with grant requirements and address the issue with employee timecards and vouchers submitted, the following steps will be implemented: 1. Time Tracking: Employees will continue to be required to record their time every two weeks (through HourTimeSheet), ensuring that the hours worked align with the percentage of time allocated to the grant for those two weeks. 2. Clear Communication: The Project Director will clarify the importance of matching monthly hours with the percentage allocated to all staff participating in the grant. This will help prevent misunderstandings regarding time reporting. 3. Reviews: The Project Director will continue to conduct monthly reviews of timecards to verify that reported hours correspond with the grant’s allocation requirements before submitting vouchers. By implementing these measures, we aim to ensure that timecards accurately reflect the allocation of employee-related costs on a monthly basis, promoting compliance with grant requirements moving forward.
2024-001 Allowability Manufacturing Extension Partnership – Assistance Listing No. 11.611 Recommendation: We recommend that the Organization update the cost allocation plan for shared administrative expenses. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
2024-001 Allowability Manufacturing Extension Partnership – Assistance Listing No. 11.611 Recommendation: We recommend that the Organization update the cost allocation plan for shared administrative expenses. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. CORRECTIVE ACTION PLAN Action taken in response to finding: Maryland MEP will update the cost allocation process to include a review of the allocation of all costs, including payroll processing fees. Through this update, Maryland MEP will ensure all costs are allowable and that all shared administrative expenses are allocated and attributed to all of Maryland MEP’s programs in a manner consistent with the organizational policy. In addition to updating the cost allocation process, Maryland MEP will ensure effective controls are in place to review the allocation performed on a regular basis. Name of the contact person responsible for corrective action: Michael Kelleher Planned completion date for corrective action plan: 10/31/2025
View of Responsible Officials and Planned Corrective Action: The Club has reviewed the findings and acknowledges the importance of documented controls over federal expenditures. The expenses noted were submitted for payment by the appropriate approver via Email, however, the emails were not maintain...
View of Responsible Officials and Planned Corrective Action: The Club has reviewed the findings and acknowledges the importance of documented controls over federal expenditures. The expenses noted were submitted for payment by the appropriate approver via Email, however, the emails were not maintained due to staff turnover. To address this finding, all grant expenditures are documented with approval and scanned prior payment.
Management Response #2024-005: Due to staff turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine an updated indirect cost rate. Also, the current indirect cost rate allocations is based on historical assumptions. Cor...
Management Response #2024-005: Due to staff turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine an updated indirect cost rate. Also, the current indirect cost rate allocations is based on historical assumptions. Corrective Action Plan: The Finance Team will develop overall operational costs reports to calculate and support a new rate. The proposed rate will be submitted to HRSA for approval. This will allow us to ensure the calculation for indirect costs and documentation supporting the indirect cost pool conform to the current regulations. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO
Management Response #2024-002: Due to the financial system and time keeping infrastructure, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Also, the current fringe cost rate and allocations is based on historical assumptions. Corrective Action Plan: • The f...
Management Response #2024-002: Due to the financial system and time keeping infrastructure, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Also, the current fringe cost rate and allocations is based on historical assumptions. Corrective Action Plan: • The finance team will work to ensure fringe costs are entered into the financial system based on actual costs paid by the Corporation for each employee. • The grants finance department will also create actual to budget reports in accordance with HRSA guidelines for fringe costs • The Finance Team will develop fringe costs reports to calculate, monitor and support the current rate. This will allow us to ensure the fringe cost allocation conform to the current regulations. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO
Management Response #2024-001: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations. Due to the influx of grants and staffing resources the Corporation was...
Management Response #2024-001: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations. Due to the influx of grants and staffing resources the Corporation was unable to maintain this process. Corrective Action Plan: Finance Management, Human Resources, and Payroll will collaborate to integrate time-tracking functionality into the current timekeeping system, enabling real-time tracking of time worked on grants for FY25. The rollout of this new process is expected to begin in Q4 of FY25. Responsible Party: Tamara Barnes, CFO
We have hired an outside independent company, Infinity File Compliance, LLC to work with us on updating and maintaining all HUD documentation requirements. We are working on applying all the new policies and procedures and will be implementing trainings to ensure future compliance.
We have hired an outside independent company, Infinity File Compliance, LLC to work with us on updating and maintaining all HUD documentation requirements. We are working on applying all the new policies and procedures and will be implementing trainings to ensure future compliance.
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