Corrective Action Plans

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We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability and safeguarding of assets.
We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability and safeguarding of assets.
We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with state and federal purchasing requirements.
We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with state and federal purchasing requirements.
Description of Finding: Payroll charges for grants were based on a percentage of time reported by employees. The percentage was based on management’s decision and set when budgeting and not based on actual hours worked. There was not sufficient documentation to provide the basis for an appropriate a...
Description of Finding: Payroll charges for grants were based on a percentage of time reported by employees. The percentage was based on management’s decision and set when budgeting and not based on actual hours worked. There was not sufficient documentation to provide the basis for an appropriate allocation of payroll charges to the federal program. Planned Corrective Action: To ensure accurate payroll allocation to federal programs, YWCA New Hampshire will implement the following: 1. Time and Effort Reporting: Implement a time and effort reporting system by August 31, 2025, requiring employees to track actual hours worked on grant-funded activities weekly. 2. Policy Update: Revise the Payroll Allocation Policy to mandate that payroll charges to grants be based on actual hours worked, supported by time and effort reports. 3. Training: Train all grant-funded employees and supervisors on the time and effort reporting system by September 15, 2025. 4. Certification Process: Require employees and supervisors to certify time and effort reports monthly, with certifications retained for audit purposes. 36 5. Monitoring: The Finance Manager will review time and effort reports quarterly to ensure accurate allocation, with findings reported to the Executive Director. Responsible Party: Finance Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: September 30, 2025
View Audit 361880 Questioned Costs: $1
Finding 570915 (2023-002)
Significant Deficiency 2023
Description of Finding: Payroll documentation was found to be inadequate, as there were missing approved pay rates, lack of supporting documentation for stipends and differentials paid, and timecards submitted which were not approved, mathematically incorrect, and/or which did not agree to the payro...
Description of Finding: Payroll documentation was found to be inadequate, as there were missing approved pay rates, lack of supporting documentation for stipends and differentials paid, and timecards submitted which were not approved, mathematically incorrect, and/or which did not agree to the payroll paid. Planned Corrective Action: To strengthen internal controls over payroll, YWCA New Hampshire will implement the following: 1. Payroll Policy Revision: Update the Payroll Policy to require documented approval of pay rates, stipends, and differentials, with all documentation retained in employee files. 34 2. Timecard Approval Process: Implement an electronic timekeeping system by July 31, 2025, requiring supervisor approval of timecards before payroll processing. The system will flag mathematical errors and discrepancies. 3. Training: Provide training for supervisors and payroll staff on the new timekeeping system and documentation requirements by August 15, 2025. 4. Reconciliation Process: The Payroll Coordinator will perform a monthly reconciliation of timecards against payroll records, with discrepancies investigated and resolved before finalizing payroll. 5. Audit Checks: The CFO will conduct quarterly audits of payroll records to ensure compliance with the updated policy, with results reported to the Executive Director. Responsible Party: Payroll Coordinator and Finance Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: August 15, 2025
View Audit 361880 Questioned Costs: $1
Finding 570914 (2023-001)
Significant Deficiency 2023
Description of Finding: A disbursement made to a vendor was not supported with adequate documentation to support the payment that was made. Planned Corrective Action: To address the lack of adequate documentation for vendor disbursements, YWCA New Hampshire will implement the following measures: 1. ...
Description of Finding: A disbursement made to a vendor was not supported with adequate documentation to support the payment that was made. Planned Corrective Action: To address the lack of adequate documentation for vendor disbursements, YWCA New Hampshire will implement the following measures: 1. Policy Update: Revise the Financial Management Policy to mandate that all disbursements require supporting documentation, including invoices, purchase orders, and approval signatures, before processing. 2. Training: Conduct mandatory training for all staff involved in procurement and payment processes on proper documentation requirements by June 30, 2025. 3. Internal Review Process: Establish a pre-payment review checklist to be completed by the Finance Manager to ensure all required documentation is present. 4. Document Retention: Implement a digital filing system, through Bill.com, to store and organize all disbursement-related documents, ensuring easy retrieval for audits. 5. Monitoring: The CFO will conduct monthly reviews of a sample of disbursements to verify compliance, with findings reported to the Executive Director. Responsible Party: Finance Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: July 31, 2025
View Audit 361880 Questioned Costs: $1
The Alliance documented the ARPA designated hours per employee and made adjustments where needed to allocate money away f rom ARPA funds when those were not reported. This process will be documented and all data and calculations supporting the allocations will be retained.
The Alliance documented the ARPA designated hours per employee and made adjustments where needed to allocate money away f rom ARPA funds when those were not reported. This process will be documented and all data and calculations supporting the allocations will be retained.
Views of responsible officials and planned corrective actions: Management acknowledges the oversight in not utilizing timecards for salaried employees whose compensation is charged to federal contracts. To strengthen internal controls and ensure compliance with applicable federal regulations, manage...
Views of responsible officials and planned corrective actions: Management acknowledges the oversight in not utilizing timecards for salaried employees whose compensation is charged to federal contracts. To strengthen internal controls and ensure compliance with applicable federal regulations, management is committed to implementing corrective measures. As part of this effort, management will update existing policies and procedures, and will identify and provide targeted training for accounting personnel responsible for allocating salary charges to federal contracts.
View Audit 361731 Questioned Costs: $1
The Organization acknowledges this repeat finding and will take steps to address the deficiencies noted. Since the prior year's audit, management will implement updated procedures to strengthen internal controls around documentation of allowable costs charged to federal awards. These measures includ...
The Organization acknowledges this repeat finding and will take steps to address the deficiencies noted. Since the prior year's audit, management will implement updated procedures to strengthen internal controls around documentation of allowable costs charged to federal awards. These measures include the development of a formal time and effort reporting system, which requires all grant-funded employees to submit periodic certifications that reflect actual hours worked and funding source allocation. Supervisors are now required to review and approve these certifications to ensure alignment with actual program activities. Additionally, the Organization will reinforce its invoice documentation and review process. All expenditures charged to the Block Grant and Opioid STR programs must now be supported by detailed invoices and documentation that clearly demonstrate allocability, allowability, and consistency with the approved grant budget and period of performance. These requirements are monitored through monthly reviews by the finance department. The Organization has also adopted a document retention policy aligned with 2 CFR §200.334, and relevant staff have received training on documentation and compliance requirements for federal awards. These corrective actions are being actively monitored by the Director of Finance to ensure full implementation and ongoing compliance. Organization Contact Person Responsible for Corrective Action: Joseph Koehler, Director of Finance Anticipated Completion Date: June 30, 2025
View Audit 361679 Questioned Costs: $1
AUDIT FINDINGS Currently, IIW is concluding an outside objective review of grants/contracts, since August 2022, to confirm the audit findings for 2022 and combined with the 2023 regular audit IIW should be able to determine the exact amounts, any payback through adjustments made by the state for sub...
AUDIT FINDINGS Currently, IIW is concluding an outside objective review of grants/contracts, since August 2022, to confirm the audit findings for 2022 and combined with the 2023 regular audit IIW should be able to determine the exact amounts, any payback through adjustments made by the state for subsequent payments after errors were made, and the nature of the over allocation of FTE’s. The reason for the need to combine the 2022 with 2023 audits is that the state and federal fiscal year beginning and ending overlap IIW’s fiscal year period. IIW does not dispute findings from the 2022 & 2023 audits. Corrective Actions: • Participating in close financial monitoring with granting agencies • IIW Audit Manual created and ratified by IIW Board • Improved Segregation of Financial Roles • Implemented new financial system to facilitate improvements in GAAP • Implemented new chart of accounts to facilitate improved reporting, reconciliation, and billing • Improved reconciliation for both bank and programs • Improved financial controls for banking and investment management • Began reimbursement of identified funds that are required to be paid back to granting agencies Sincerely yours, Paul F. Trebian, Ed.D., MBA/TM, MA, BS President & CEO International Institute of Wisconsin ptrebian@iiwisconsin.org 414-403-9735 Cell CST
View Audit 361224 Questioned Costs: $1
THE ORGANIZATION WILL IMPLEMENT A PROCESS TO ENHANCE INTERNAL CONTROLS ASSOCIATED WITH THE REVIEW OF REVENUES AND EXPENDITURES TIMELY TO ENSURE ACCURATE AND COMPLETE REPORTING OF THE FINANCIAL STATEMENTS. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. THE ORGANIZATION WIL...
THE ORGANIZATION WILL IMPLEMENT A PROCESS TO ENHANCE INTERNAL CONTROLS ASSOCIATED WITH THE REVIEW OF REVENUES AND EXPENDITURES TIMELY TO ENSURE ACCURATE AND COMPLETE REPORTING OF THE FINANCIAL STATEMENTS. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT EXPENDITURES SUBMITTED FOR REIMBURSEMENT OF FEDERAL AWARD PROGRAMS. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION WILL TERMINATE THE CURRENT AGREEMENT WITH THE CPA AND MOVE TO ANOTHER CPA FIRM TO MEET THE NEEDS OF THE ORGANIZATION IN A PROFESSIONAL, QUALIFIED AND TIMELY MANNER. MOVE TO ANOTHER CPA FIRM BY NO LATER THAN SEPTEMBER 1, 2025. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE MEMBERS ON JUNE 25, 2025.
View Audit 361194 Questioned Costs: $1
THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT BASE EXPENDITURES FOR THE PERIOD. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION THROUGH ITS BOARD...
THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT BASE EXPENDITURES FOR THE PERIOD. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE ON JUNE 25, 2025.
View Audit 361194 Questioned Costs: $1
THE ORGANIZATION WILL USE ACTUAL PAYROLL COSTS TAKEN FROM PAYROLL REPORTS TO SUPPORT PAYROLL EXPENSES APPLIED TO THE PROGRAM. IMMEDIATELY, THE PROCESS BEGAN IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE IDAHO IMMUNIZATION COALITION WILL TERMI...
THE ORGANIZATION WILL USE ACTUAL PAYROLL COSTS TAKEN FROM PAYROLL REPORTS TO SUPPORT PAYROLL EXPENSES APPLIED TO THE PROGRAM. IMMEDIATELY, THE PROCESS BEGAN IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE IDAHO IMMUNIZATION COALITION WILL TERMINATE THE CURRENT AGREEMENT WITH THE CPA AND MOVE TO ANOTHER CPA FIRM TO MEET THE NEEDS OF THE ORGANIZATION IN A PROFESSIONAL, QUALIFIED AND TIMELY MANNER. MOVE TO ANOTHER CPA FIRM BY NO LATER THAN SEPTEMBER 1, 2025. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE ON JUNE 25, 2025.
View Audit 361194 Questioned Costs: $1
Federal Agency Name: Department of Treasury Assistance Listing Number: 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not have internal controls to ensure proper review and approval (segregation of duties) between the preparer and reviewer ...
Federal Agency Name: Department of Treasury Assistance Listing Number: 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not have internal controls to ensure proper review and approval (segregation of duties) between the preparer and reviewer of the quarterly financial reports. Corrective Action Plan: Previous reports were compiled by the Foundation’s vendors and submitted by the prior CFO. Future reports will be prepared by the Accountant and reviewed by the CFO prior to submission. Responsible Individuals: Alisha Kinnison, Accountant and Matt Lazar, CFO Anticipated Completion Date: July 2025
Reporting Significant Deficiency in Internal Control over Compliance Department of Treasury Federal Assistance Listing #21.027 Coronavirus State and Loan Fiscal Recovery Funds Finding Summary: Lack of documentation of a secondary review on expense reports required to be submitted. Responsible Indivi...
Reporting Significant Deficiency in Internal Control over Compliance Department of Treasury Federal Assistance Listing #21.027 Coronavirus State and Loan Fiscal Recovery Funds Finding Summary: Lack of documentation of a secondary review on expense reports required to be submitted. Responsible Individuals: Eric Price, CFO Corrective Action Plan: Management has enhanced internal control policies and processes to ensure that a secondary review of expense report is taking place prior to submission and that those reviews are formally documented. Anticipated Completion Date: Ongoing
1. Improvement of Data Entry and Documentation Management: *The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submi...
1. Improvement of Data Entry and Documentation Management: *The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submission. *Employees involved in handling sliding fee applications and supporting documents will be provided with training on the importance of accurate documentation and the procedures for proper filing, both physically and electronically. 2. Implement Regular Monitoring and Auditing: *A regular internal review and audit process will be revisited to ensure that backup, storage, and retention practices are being followed. These audits will focus on verifying that all sliding fee applications and related documents are stored correctly and are retrievable as needed. *Any discrepancies or issues identified during audits will be addressed promptly, and corrective actions will be taken to ensure compliance with the established procedures. 3. Staff Training and Awareness: *Training sessions will be conducted for all relevant staff on the updated backup, storage, and retention procedures for sliding fee applications and income documentation. This training will emphasize the importance of maintaining accurate and accessible records to comply with regulatory and organizational standards. *Refresher training will be provided quarterly to ensure ongoing compliance and awareness.
1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax fi...
1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax filings, and third-party payroll contracts. *A secure, organized system will be implemented for storing payroll-related documents, whether physical or digital. This will include utilizing secure cloud storage or an enterprise document management system with restricted access controls. *We will conduct a quarterly review to ensure that documents are being retained for the appropriate time frame and securely disposed of when no longer required. 2. Implement Stronger Controls During Payroll Provider Transitions: *We will formalize and document the process for changing third-party payroll providers. This process will include detailed steps for due diligence, transition planning, data transfer procedures, and ensuring continuous payroll processing during the transition period. *A project team will be assigned for every payroll provider change to ensure proper planning, including backup and contingency plans, data verification, and communication with both internal and external stakeholders. *A comprehensive review of the transition will be conducted after each change, including a reconciliation of payroll records to ensure that all data is accurately transferred, and all systems are functioning properly. 3. Vendor Oversight and Service Level Agreements (SLAs): *We will ensure that future contracts with third-party payroll providers include clear Service Level Agreements (SLAs) outlining the provider's responsibilities in terms of document retention, data security, and transition procedures. This will ensure that providers maintain the necessary standards and practices for managing payroll-related documents.
View Audit 360384 Questioned Costs: $1
Management stated they will purchase a professional time tracking software program to help all employees track their work hours and activities.
Management stated they will purchase a professional time tracking software program to help all employees track their work hours and activities.
View Audit 360261 Questioned Costs: $1
COMPLIANCE REQUIREMENTS WILL BE PRACTICED BY THE DIRECTOR OF FINANCE AND FEDERAL PROGRAM DIRECTOR.
COMPLIANCE REQUIREMENTS WILL BE PRACTICED BY THE DIRECTOR OF FINANCE AND FEDERAL PROGRAM DIRECTOR.
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2025. Planned ...
Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2025. Planned Implementation Date: December 2025 Responsible Person(s): City Manager
Finding 2023-103 - Allocation of Payroll Costs Determination - Material Weakness in Internal Controls over Compliance Responsible Party: Ervin Reed, Director of Finance Anticipated Completion Date: July 1, 2025 Planned Action: Engage in active and regular conversations with program leadership to e...
Finding 2023-103 - Allocation of Payroll Costs Determination - Material Weakness in Internal Controls over Compliance Responsible Party: Ervin Reed, Director of Finance Anticipated Completion Date: July 1, 2025 Planned Action: Engage in active and regular conversations with program leadership to ensure that staff are appropriately budgeted to programs based on a pre-determined expectation. Actual time spent will be allocated during the program year, compared to the budget, and adjusted if needed. If administrative staff are budgeted to a program, a time study will be undertaken to determine appropriate portions of time charged.
Planned Corrective Action: Review and Update: Accoutning and Personnel Policies and Procedures and update to follow OMB's Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (UG). Planned Implementation Date of Corrective Action: 07/01/2025. Person Res...
Planned Corrective Action: Review and Update: Accoutning and Personnel Policies and Procedures and update to follow OMB's Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (UG). Planned Implementation Date of Corrective Action: 07/01/2025. Person Responsible for Corrective Action: Jane Bizeur, Business Manager; Dawn Reams, Executive Director
FINDING #2023-004 OVERPAYMENT OF PAYROLL EXPENSES Recommendation: We recommend that the management agent reimburse the entity for the overpayment of payroll expenses and implement additional controls to ensure that these fees are properly calculated in the future. Views of Responsible Officials a...
FINDING #2023-004 OVERPAYMENT OF PAYROLL EXPENSES Recommendation: We recommend that the management agent reimburse the entity for the overpayment of payroll expenses and implement additional controls to ensure that these fees are properly calculated in the future. Views of Responsible Officials and Planned Corrective Action: The management agent reimbursed the entity the $1,620. They have also contracted with an outside payroll organization to administer payroll.
View of Responsible Official Currently, the Organization’s CEO and the bookkeeper will review each grant’s funding details prior to the grant’s fiscal year to determine how each employee’s salary percentages should be allocated according to the grant contract. Throughout the fiscal year, the CEO and...
View of Responsible Official Currently, the Organization’s CEO and the bookkeeper will review each grant’s funding details prior to the grant’s fiscal year to determine how each employee’s salary percentages should be allocated according to the grant contract. Throughout the fiscal year, the CEO and bookkeeper will meet regularly to review and incorporate any new hires to determine how their salary is expected to be allocated. Additionally, the outsourced accountant will review the allocations periodically throughout the year to ensure that it is being done properly. Over the next year, as considered efficient, the Organization will implement a daily timesheet record, which requires each program service employee to classify their daily time between federal grant programs. At the end of each week, staff members will submit their timesheet to their supervisor. The supervisor will review each week’s daily timesheet to confirm the staff are recognizing their activities properly. At the end of each month, the Organization’s outsourced accountant, will review these timesheets and determine the proper allocation needed to record each employee’s payroll activities in the accounting software by appropriate federal program. This process will allow for the allocation of actuals to each federal program by the end of the month.
View of Responsible Official Currently, based on the capacity of the Organization’s staffing pool, the most efficient and effective means of review and reconciliation of cash disbursements and payroll is the Organization’s Board Chair and CEO reviewing the cash disbursements and payroll every two we...
View of Responsible Official Currently, based on the capacity of the Organization’s staffing pool, the most efficient and effective means of review and reconciliation of cash disbursements and payroll is the Organization’s Board Chair and CEO reviewing the cash disbursements and payroll every two weeks, prior to payments being made. The Organization’s bookkeeper forwards the Board Chair and CEO a listing of cash disbursements and payroll due with the suggested payments. The Board Chair and CEO each will ask questions and formally “approve” or “disapprove” each transaction, prior to any payments. Once reviewed, the CEO will contact the bookkeeper with the amounts to pay. Also, the Organization’s outsourced accountant will review and approve each monthly bank reconciliation and bank statement for all Organization accounts, as well as the monthly credit card statements. The outsourced accountant does not have the ability to access the monthly bank statements and make purchases. Going forward, the Organization’s Director of Communications will retain the Board Chair’s check stamp. The Director of Communication will only be allowed to use the Board Chair’s check stamp once the Board Chair and CEO approved payment.
Finding 2023-002: Eligibility Documentation Management’s Response Mid Michigan CAA acknowledges the audit finding regarding the documentation of diaper distribution to income-eligible participants under the Temporary Assistance for Needy Families (TANF) program. We appreciate the opportunity to pro...
Finding 2023-002: Eligibility Documentation Management’s Response Mid Michigan CAA acknowledges the audit finding regarding the documentation of diaper distribution to income-eligible participants under the Temporary Assistance for Needy Families (TANF) program. We appreciate the opportunity to provide clarification and outline corrective actions. The Diaper Bank Program operated under the oversight of the Michigan Department of Health and Human Services (MDHHS), which conducted regular monitoring and did not identify any concerns related to eligibility or distribution practices during their reviews. In accordance with program requirements, all participating diaper banks were pre-existing programs with access to alternative funding sources. These sources were explicitly intended to support the distribution of diapers to households that did not meet TANF income eligibility criteria. While Mid Michigan CAA did not maintain centralized documentation of the specific funding source used for each distribution, it was understood and communicated to partner entities that TANF-funded diapers were to be reserved for eligible households only. To strengthen internal controls and ensure full compliance with TANF requirements, Mid Michigan CAA has implemented the following measures: 1. Development of a standardized tracking system to document only diapers distributed to each household using TANF funds. 2. Training for all partner entities on eligibility verification procedures and documentation requirements. 3. Periodic internal audits to verify compliance and ensure accurate recordkeeping. Contact Person Responsible for Corrective Action: Eva Rohlman, Outreach & Opportunities Director Anticipated Completion Date: 10/1/2024
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