Corrective Action Plans

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Corrective Action Plan Seattle Jobs Initiative Report Period: YE 2023 Date: 09/30/2024 Auditor Findings: A significant deficiency was identified in internal controls related to the allocation of indirect costs for federal awards. Specifically, the timely documentation and review of indirect cost all...
Corrective Action Plan Seattle Jobs Initiative Report Period: YE 2023 Date: 09/30/2024 Auditor Findings: A significant deficiency was identified in internal controls related to the allocation of indirect costs for federal awards. Specifically, the timely documentation and review of indirect cost allocation methods were not adequately maintained. Corrective Action Plan: 1. Finding: o Description: A deficiency related to internal controls over the allocation of indirect costs for federal awards. The review process for the documentation of indirect costs was not timely, leading to potential discrepancies in allocation. 2. Cause: o Lack of timely documentation and review of indirect cost allocation methods. 3. Corrective Action: o Enhance Internal Control Procedures: Seattle Jobs Initiative will revise the internal control procedures surrounding the allocation of indirect costs. This will involve:  Establishing a structured timeline for regular and timely documentation of indirect cost allocations.  Implementing a quarterly review process by a designated financial manager to ensure compliance and accuracy in cost allocation.  Providing training to finance staff on the updated procedures and documentation requirements to ensure clarity and consistency in the process. o Documentation Improvements: All indirect cost allocation documentation will be maintained in a centralized system to ensure that all records are up to date, easily accessible, and subject to regular review. o Review and Approval: A secondary review process will be implemented, where the VP of Finance or another designated individual reviews and approves the allocation methodology before submission to external stakeholders or auditors. 4. Responsible Personnel: o VP of Finance: Karthik Mohan o Accounts Receivable Accountant: Oka Kencanawati 5. Implementation Timeline: o November 1, 2024: Initial training for finance staff on revised internal controls and allocation methods. o November 15, 2024: Completion of the first quarterly review of indirect cost allocations under the new control procedures. o December 1, 2024: Full implementation of the updated documentation and review system for ongoing compliance. 6. Monitoring and Reporting: o The Finance team will monitor the effectiveness of the corrective actions through quarterly internal audits, ensuring the controls are being followed and addressing any further issues promptly. The findings from these audits will be reported to the executive team for review. Conclusion: Seattle Jobs Initiative is committed to resolving this significant deficiency and enhancing our internal control processes to prevent future occurrences. We expect full resolution of the issue by the end of 2024, with no further noncompliance anticipated moving forward. ________________________________________ Submitted by: Karthik Mohan VP of Finance Seattle Jobs Initiative 09/30/2024
We will implement procedures to ensure that our policies and procedures requiring the maintenance of documentation to support expenditures claimed under federal awards be followed consistently for all claimed expenditures in October 2024.
We will implement procedures to ensure that our policies and procedures requiring the maintenance of documentation to support expenditures claimed under federal awards be followed consistently for all claimed expenditures in October 2024.
View Audit 323260 Questioned Costs: $1
We will implement procedures to maintain accurate timecards or time studies for employees who have payroll claimed under the federal programs beginning in October 2024. This is a repeat finding from last year’s audit. We did not receive the corrective action plan for this audit until February of 2...
We will implement procedures to maintain accurate timecards or time studies for employees who have payroll claimed under the federal programs beginning in October 2024. This is a repeat finding from last year’s audit. We did not receive the corrective action plan for this audit until February of 2024 to know to implement changes. In pulling these items, the same findings would be noted due to not knowing those changes needed to be made during 2023.
View Audit 323260 Questioned Costs: $1
Finding Reference Number: 2023-001 Identification of the Federal Program: Grantor: United States Department of Agriculture Program Name: Special Supplemental Nutrition Program for Women, Infant, and Children Assistance Listing No.: 10.557 Name of responsible official: James Geraghty Vice Presi...
Finding Reference Number: 2023-001 Identification of the Federal Program: Grantor: United States Department of Agriculture Program Name: Special Supplemental Nutrition Program for Women, Infant, and Children Assistance Listing No.: 10.557 Name of responsible official: James Geraghty Vice President, Faculty Practice Group Phone: (718) 430-3255 Email: james.geraghty@einsteinmed.edu Projected completion date: September 12, 2024 Condition In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Management was unable to provide evidence of a control being consistently performed to address the risk that the Health System may seek reimbursement for expenditures that are either out of contract period or are for non-permissible costs under the applicable contracts. Status Management concurred with the audit finding and has implemented a standardized review and approval process that will be performed prior to monthly vouchers being submitted for reimbursement, including verification of allowability of expenditures, and that all expenditures were incurred in the proper period. Evidence of the monthly review and approval will be retained.
Management agrees with the finding. Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will provide a new updated Federal Awards ...
Management agrees with the finding. Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will provide a new updated Federal Awards and Accounting Manual to all management of Federal Awards.
View Audit 323241 Questioned Costs: $1
2023-009- Significant Deficiency in Internal Control and Non-material Noncompliance - Supporting Documentation for Expenses Incurred during the Year WPHW understands this finding and has already taken steps to ensure this issue does not come back up for FY24. WPHW keeps an extensive filing system wh...
2023-009- Significant Deficiency in Internal Control and Non-material Noncompliance - Supporting Documentation for Expenses Incurred during the Year WPHW understands this finding and has already taken steps to ensure this issue does not come back up for FY24. WPHW keeps an extensive filing system which is mostly paper and not electronic. Our initial plan was utilized in NetSuite program as part of the electronic filing keeping system. After the transition away from NetSuite, we recognized the need for electronic filing keeping. In FY24 we did transition utilizing our share file to keep electronic copies of everything that we have paper copy. This includes AP items, AR items along with journal entries, bank reconciliations anything else deemed necessary. We understand the importance of having all documentation readily at hand for our monthly review’s yearly reviews and especially for the audit. Our process includes the following: 1) As items are entered into the vendor center of our accounting software, they are then scanned into the following system labeled by the individual in which it's entering the information into the system. 2) Invoices are prepared within the accounting software printed and then scanned with all supporting documentation into this electronic filing system. 3) Journal entries once prepared are printed attached with supporting documentation and then scan it to the electronic filing system. 4) Other items in which we keep electronic documentation following similar process these include bank reconciliations, contracts, and other pertinent files. All documentation is also kept within a filing system here within our department. Each group of documented items are labeled and filed chronologically in a centralized location. As we move through FY24 into FY25 we will continue to review and improve this internal process.
Planned Corrective Action: We will implement a process to monitor cost cash match including obtaining, reviewing, and retaining support for reported cost match amounts. This will be completed with each drawdown that is request where a cost match is reported. Name of Contact Person: Lisa Daniels, Pro...
Planned Corrective Action: We will implement a process to monitor cost cash match including obtaining, reviewing, and retaining support for reported cost match amounts. This will be completed with each drawdown that is request where a cost match is reported. Name of Contact Person: Lisa Daniels, Program Director & Rhonda Conn, Program Director Anticipated Completion Date: October 1, 2024
Planned Corrective Action: Executive Director will be tracking their time spent on specific grants on a weekly basis. The Board of Directors will review and approve the time summary at least quarterly. Executive Director non‐payroll reimbursements will also be reviewed and approved by at least one b...
Planned Corrective Action: Executive Director will be tracking their time spent on specific grants on a weekly basis. The Board of Directors will review and approve the time summary at least quarterly. Executive Director non‐payroll reimbursements will also be reviewed and approved by at least one board member. The Program Director will provide oversight of these two newly established processes. Name of Contact Person: Rhonda Conn, Program Director Anticipated Completion Date: October 1, 2024
Contact Person Michelle Erickson Corrective Action Plan The Abused Adult Resource Center’s payroll allocations for grants will be documented on timesheets and the hard copies will be filed or scanned onto a local drive kept by the Center. Completion Date Fiscal Year 2024
Contact Person Michelle Erickson Corrective Action Plan The Abused Adult Resource Center’s payroll allocations for grants will be documented on timesheets and the hard copies will be filed or scanned onto a local drive kept by the Center. Completion Date Fiscal Year 2024
View Audit 323201 Questioned Costs: $1
Finding 500426 (2023-004)
Significant Deficiency 2023
REPORTING Recommendation: The County should design procedures and controls to ensure all reports are formally reviewed, all deadlines are met, and supporting documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in ...
REPORTING Recommendation: The County should design procedures and controls to ensure all reports are formally reviewed, all deadlines are met, and supporting documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will review procedures and implement changes as needed to ensure reports are formally reviewed, submitted timely, and proper documentation is retained. Name of the contact person responsible for corrective action: Charlene Dale, Human Services Supervisor Planned completion date for corrective action plan: December 31, 2024
Material Weakness, Internal Control Over Compliance and Compliance, Allowable Costs and Activities, Reporting Personnel Responsible for Corrective Action: Samantha Martin, County Administrator Anticipated Completion Date: 12/31/2024 Corrective Action Plan: The County agrees with the auditor’s rec...
Material Weakness, Internal Control Over Compliance and Compliance, Allowable Costs and Activities, Reporting Personnel Responsible for Corrective Action: Samantha Martin, County Administrator Anticipated Completion Date: 12/31/2024 Corrective Action Plan: The County agrees with the auditor’s recommendation to improve its internal controls related to federal grant allowable costs and activities determinations and reporting requirements and will implement a process that ensures federal expenditure accounting and reports are prepared and then reviewed and approved by a separate employee prior to submission.
Finding No. 2023-005 -Allowable Costs/Cost Principles; Significant Deficiency (#14.896 - Family Self Sufficiency Program) Auditee's Response and Planned Corrective Action The Milton Housing Authority will review FSS program guidelines and reimbursable activities to ensure that it is properly disburs...
Finding No. 2023-005 -Allowable Costs/Cost Principles; Significant Deficiency (#14.896 - Family Self Sufficiency Program) Auditee's Response and Planned Corrective Action The Milton Housing Authority will review FSS program guidelines and reimbursable activities to ensure that it is properly disbursing FSS Funds. To that end, MHA is working closely with HUD officials. Person Responsible for Corrective Action: Earl Fay, Executive Director (617) 698-2169
Finding 500362 (2023-001)
Significant Deficiency 2023
Finding 2023-001 Significant deficiency regarding Allowable Costs/Cost Principles and lack of documentation supporting management’s review control Information on the federal program: Grantor: Department of Agriculture Pass Through Entity: NYS Department of Health Program Name: WIC Special Supplement...
Finding 2023-001 Significant deficiency regarding Allowable Costs/Cost Principles and lack of documentation supporting management’s review control Information on the federal program: Grantor: Department of Agriculture Pass Through Entity: NYS Department of Health Program Name: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing No.: 10.557 Views of responsible officials and planned corrective actions: Management concurs with the audit finding and has implemented a standardized review and approval process that will be performed prior to monthly vouchers being submitted for reimbursement, including verification of allowability of expenditures and appropriate indirect cost and fringe benefit expense rates. Evidence of the monthly review and approval will be retained. Name of responsible official: Bill Dibitetto VP of Finance Projected completion date: October 31, 2024
Finding 500333 (2023-002)
Significant Deficiency 2023
Management’s Corrective Action Plan For the Year Ended December 31, 2023 Contact Person(s): Sophia Hernandez, Chief Operations Officer Sophia.Hernandez@youthcare.org Amber Aman, Deputy Operations Office - Finance Amber.Aman@youthcare.org Finding Number: 2023 - 002 Explanation and specific reasons f...
Management’s Corrective Action Plan For the Year Ended December 31, 2023 Contact Person(s): Sophia Hernandez, Chief Operations Officer Sophia.Hernandez@youthcare.org Amber Aman, Deputy Operations Office - Finance Amber.Aman@youthcare.org Finding Number: 2023 - 002 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement. Corrective action taken: • Develop a contract expenditure compliance review process created with final review and approval by Deputy Operations Officers. To be established by September 30th, 2024, and implemented in 2025 annual operating plan Anticipated completion date: In Process
View Audit 323098 Questioned Costs: $1
Person responsible for corrective action plan: Anthony Madera, CFO Lummi Indian Business Council 2665 Kwina Road Bellingham, WA 98226 (360) 384-7181 Condition: During transactional testing, 11 of 16 individually important items (IIIs) were journal entries with no documented review and approval pro...
Person responsible for corrective action plan: Anthony Madera, CFO Lummi Indian Business Council 2665 Kwina Road Bellingham, WA 98226 (360) 384-7181 Condition: During transactional testing, 11 of 16 individually important items (IIIs) were journal entries with no documented review and approval process. Solution: With the guidance and authority outlined in the Department’s internal policies and in accordance with 2 CFR, Part 200, Subpart E, §200.405 Allocable costs, manual adjustments will be defined as reasonable and allocable as defined within existing governing statues, regulations, or terms and conditions of the award. Levels of delegation of staff administering these regulatory activities will utilize the appropriate credentials request cost adjustments and use prudent judgment to determine those costs are necessary and do not deviate from the Department’s established practices and policies. Final review of cost adjustment requests will be reviewed by Department’s OMB and once approved a signature of review and approval will be documented. Corrective action plan will be in accordance with c CFR, Part 200, Subpart F, §200.511 Audit findings follow-up. The Department entered into a professional agreement with Financial Service Advisors, LLC to assess current policies to update standards of management by identifying credentials and experience of senior finance staff who will oversee these activities. Revisions to the policies will provide the Department’s government an extensive manual that will be developed into a fiscal management training. Training will include but not be limited to reviewing procurement methods, fiscal review of ledger activity, and audit responsibility on a quarterly basis and reporting to tribal council. Responsible: Anthony Madera, Chief Financial Officer, Lummi Indian Business Council Anticipated completion date: 06/30/2025
Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in respon...
Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will undertake a thorough review and subsequent update of our documented policies and procedures related to federal awards. This review aims to ascertain whether any adjustments are necessary to guarantee that subawarded federal funds are utilized exclusively for their designated purposes. We are dedicated to enhancing our internal controls to adhere to federal regulations concerning the monitoring of our subrecipients. We plan to engage a consultant to help us develop policies and procedures for subrecipient monitoring, as well as to propose an organizational framework for fiscal monitoring that will strengthen our internal controls. We anticipate having the finalized policies, procedures, and training implemented by 12/31/2024. We will develop and implement a risk assessment program for subrecipients, enabling management to monitor the outcomes and demonstrate compliance with federal requirements. Records will be maintained to show that risk assessments were performed. We are dedicated to offering annual training sessions aimed at reinforcing the single audit requirements to our subrecipients. We will establish a subrecipient monitoring/compliance workgroup to define roles and responsibilities for assessing and updating policies and procedures related to subrecipient monitoring and to strengthen internal controls. Name(s) of the contact person(s) responsible for corrective action: Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO), Sharon Brown (CEO). Planned completion date for corrective action plan: 12/31/2024
Recommendation: We recommend that the Organization’s procurement policy is followed and that procurement procedures are documented, reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will...
Recommendation: We recommend that the Organization’s procurement policy is followed and that procurement procedures are documented, reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will review our current policies and procedures in these areas to determine if any changes should be implemented. We will ensure staff responsible for procurement of goods and services are familiar with applicable federal and state laws and policies for awarding and executing contracts. We are deeply committed to the continuous improvement of our purchasing policies and procedures to uphold the highest standards of transparency and accountability. In this regard, procurement policy will be updated to comply with the Uniform Guidance for federal awards. Furthermore, to strengthen our oversight of sole-source contracts awarded with program and non-program funds, we will introduce stringent measures requiring thorough documentation of the vendor’s or contractor’s qualifications. Name(s) of the contact person(s) responsible for corrective action: Department Head, Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO), Sharon Brown (CEO). Planned completion date for corrective action plan: 12/31/2024
Recommendation: We recommend that the Organization implements policies and procedures to properly calculate and allocate payroll benefits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will develop and imp...
Recommendation: We recommend that the Organization implements policies and procedures to properly calculate and allocate payroll benefits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will develop and implement an allocation plan for payroll benefits. We will develop process and procedures where charging of payroll benefits expenses to federal grants includes the written recommendation from compliance team and written approval of the CFO/CEO prior to payroll benefits being charged to federal grants. We will consult with the grantor to discuss whether the questioned costs identified in the audit should be repaid. Name(s) of the contact person(s) responsible for corrective action: Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO), Sharon Brown (CEO) Planned completion date for corrective action plan: 12/31/2024
View Audit 323092 Questioned Costs: $1
Recommendation: We recommend management implement procedures to ensure that unallowable costs are not charged to federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will provide supplementary tra...
Recommendation: We recommend management implement procedures to ensure that unallowable costs are not charged to federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will provide supplementary training focused on the accurate allocation of costs to federal awards, as well as the identification and separation of unallowable costs from allowable costs. We will develop and implement detailed processes and procedures to ensure effective oversight and control of disbursements. These processes will require initial approval from the department head for all disbursements. Subsequently, the compliance team will conduct a secondary review and approval. Finally, all disbursements will necessitate final approval from the CFO/CEO before being processed for payment. This multi-step approval process is designed to ensure proper allocation of costs to federal grants. Name(s) of the contact person(s) responsible for corrective action: Department Head, Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO), Sharon Brown (CEO). Planned completion date for corrective action plan: December 31, 2024
We agree in part to this finding. The deficiency exists with approval of transactional funds that are utilized for the transportation and food voucher programs. Historically, authorization to purchase has been deemed as approval and this year some of those documentation processes were not consiste...
We agree in part to this finding. The deficiency exists with approval of transactional funds that are utilized for the transportation and food voucher programs. Historically, authorization to purchase has been deemed as approval and this year some of those documentation processes were not consistently followed, as mentioned being done verbally or during other discussions that were not documented. We did not make any food voucher purchases without discussion prior to purchasing. That being said, we can formalize an approval process that is documented. Additionally, we will review our transportation program policies to ensure that a proper approval process is in place and continues to be supported by the processes we have in place.
Finding 2023-002: Internal Controls over Allowable Costs The auditors noted the following areas for improvement: ● Time & Effort Certifications (T&E) were missing from 18 out of 40 tested contractor invoices. ● All payroll for W-2 employees was billed to grants based on a percentage of time spent ve...
Finding 2023-002: Internal Controls over Allowable Costs The auditors noted the following areas for improvement: ● Time & Effort Certifications (T&E) were missing from 18 out of 40 tested contractor invoices. ● All payroll for W-2 employees was billed to grants based on a percentage of time spent versus actual time spent. ● From a list of 244 clients, 21 client intake forms (used to determine eligibility for services) for Business Growth Services clients were unable to be produced. The auditors recommend the following: 1. Management to implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supported with documentation in accordance with federal regulations. SDA Response The SDA accepts the above findings and would like to add the following information for context: ● The requirement to collect T&E forms wasn’t initially established until the completion of the 2022 audit and after the departure of some personnel. Management attempted to collect T&E forms from prior contractors, but was not successful in securing the specific forms identified by the auditors. ● The SDA created a payroll classification document during 2023 which outlined T&E for all W-2 employees at a set rate for the year. This document, however, was not accepted by the auditors as evidence of actual hours expended on each grant, resulting in this finding. ● The SDA onboarded a new Director of Business Growth Services (BGS) in 2023, which led to changes in both the operational structure and the nature of the data collected for BGS activities. During this period, a data migration took place to a newer version of Salesforce that was built specifically for the SDA. Unfortunately, some data was either lost or unmapped during the migration process, leading to discrepancies in the completeness of historical records. SDA Corrective Actions Management is committed to continue training for personnel to ensure timely completion and compliance of hiring as well as time and effort documentation going forward. The SDA is implementing a new checklist tool to bolster compliance. This checklist will help the Director of Finance and Administration identify and correct any missing compliance well in advance of the next audit. In addition, Management is implementing a new quarterly review process to assess both compliance and financial accounts. The new quarterly review process will ensure documentation is maintained and accounted for each transaction, particularly for restricted grants, to minimize any post-close adjustments. The combination of both the new checklist tool and review process will support continued timeliness and eliminate this finding in future audits.
View Audit 323067 Questioned Costs: $1
Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.
Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.
LSNYC will ensure that the proper accounting period is selected for all subsidiary ledger entries, as well as all journal entries, before posting is approved into the general ledger. We will also train relevant staff on the importance of recording transactions in the correct period in order to minim...
LSNYC will ensure that the proper accounting period is selected for all subsidiary ledger entries, as well as all journal entries, before posting is approved into the general ledger. We will also train relevant staff on the importance of recording transactions in the correct period in order to minimize the likelihood of mistakes.
View Audit 323047 Questioned Costs: $1
This expense was reallocated to LSC in accordance with LSNYC's Cost Allocation Plan, which was developed to comply with LSC regulations on cost allocations and situations where funders will not cover certain costs. In this situation, the initial funder did not allow capital expenses, which is why th...
This expense was reallocated to LSC in accordance with LSNYC's Cost Allocation Plan, which was developed to comply with LSC regulations on cost allocations and situations where funders will not cover certain costs. In this situation, the initial funder did not allow capital expenses, which is why the expense was then allocated to LSC. In the future, we will get advance approval for expenses that we know will get allocated to LSC before they are purchased.
View Audit 323047 Questioned Costs: $1
Finding No. 2023-001: Fraudulent Payroll Activities Resulting in Theft (Material Weakness) Person Responsible: Reginal Barner Date of Completion: 12/31/2024 Corrective Action Plan: Our fee accountant and payroll consultant will access the payroll process and implement corrective actions, including a...
Finding No. 2023-001: Fraudulent Payroll Activities Resulting in Theft (Material Weakness) Person Responsible: Reginal Barner Date of Completion: 12/31/2024 Corrective Action Plan: Our fee accountant and payroll consultant will access the payroll process and implement corrective actions, including adding internal controls and training.
View Audit 323042 Questioned Costs: $1
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