Corrective Action Plans

Finding 512254 (2023-001)

Material Weakness 2023

Center on Halsted

IL

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective Actions Taken or Planned: ▪ Taken: This finding was a result of staff turnover and Center on Halsted has put in place an established relationship with an external accounting firm (Sikich), that will help create stability and support in all financial processes including grant reconciliatio...

Corrective Actions Taken or Planned: ▪ Taken: This finding was a result of staff turnover and Center on Halsted has put in place an established relationship with an external accounting firm (Sikich), that will help create stability and support in all financial processes including grant reconciliation. This updated contractual agreement & relationship occurred on March 1, 2024. ▪ Taken: Documentation has already begun to be gathered for allowable expenses and approval of certain expenses per grant, via written email documentation. This is currently being operationalized and will be fully implemented by our Senior Accountant Jeong Shin and our Senior Director of Finance Reginald Walker. Anticipated completion date: August 15th, 2024. ▪ Planned: Ensure adequate documentation for approval and alignment of expenses to specific grants. This is currently being operationalized and will be fully implemented by our Senior Accountant Jeong Shin and our Senior Director of Finance Reginald Walker. Anticipated completion date: August 15th, 2024. ▪ Planned: Verification of allowable expenses with grant management and finance leadership with monthly check-ins with program directors. This will be facilitated by our Director of Grants Brenna Quinn, our Senior Accountant Jeong Shin, and led by our Senior Director of Finance Reginald Walker. Anticipated completion date: September 1st, 2024. ▪ Planned: New Senior Director of Finance Reginald Walker has been hired and a priority of their job function is to create stronger internal controls with sufficient checks and balances. Anticipated completion date: September 1st, 2024.

View Audit 330028 Questioned Costs: $1

Finding 512237 (2023-002)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corre...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

View Audit 330027 Questioned Costs: $1

Finding 512236 (2023-004)

Significant Deficiency 2023

City of Clarksville

TX

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

City of Clarksville, TX accounting department and Mayor will develop a process in which the audit will be completed in a timely manner to submit it to the FAC by hiring an auditor earlier in the year and submitting it to the Clearing house within 30 days of the audit report or nine months after the ...

City of Clarksville, TX accounting department and Mayor will develop a process in which the audit will be completed in a timely manner to submit it to the FAC by hiring an auditor earlier in the year and submitting it to the Clearing house within 30 days of the audit report or nine months after the Organization’s year end

View Audit 330016

Finding 512166 (2023-005)

None 2023

Detroit Health Care for the Homeless Dba Advantage Health Centers

MI

Allowable Costs / Cost Principles Reporting Special Tests & Provisions

Due to administrative issues, the Organization was unable to submit the reporrs in a timely manner. We will ensure that all the reports are timely submitted as per the grant requirements.

View Audit 329922

Finding 512148 (2023-005)

Significant Deficiency 2023

Lutheran Services in Iowa, Inc.

IA

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties § 200.303

Assistance Listing No. 93.567 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all disbursements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and u...

Assistance Listing No. 93.567 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all disbursements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and update existing controls. Document approvals throughout the process. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: 12/31/2024

View Audit 329880

Finding 512143 (2023-004)

Significant Deficiency 2023

Lutheran Services in Iowa, Inc.

IA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Assistance Listing No. 93.576 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and update ...

Assistance Listing No. 93.576 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and update existing controls. Document approvals throughout the process. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: 12/31/2024

View Audit 329880

Finding 512141 (2023-003)

Material Weakness 2023

Lutheran Services in Iowa, Inc.

IA

Cash Management Allowable Costs / Cost Principles Material Weakness § 200.303

Assistance Listing No. 93.659 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review a...

Assistance Listing No. 93.659 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and update existing controls. Document approvals throughout the process. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: 12/31/2024

View Audit 329880

Finding 512136 (2023-002)

Material Weakness 2023

Lutheran Services in Iowa, Inc.

IA

Cash Management Allowable Costs / Cost Principles Material Weakness § 200.303

Assistance Listing No. 93.576 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review a...

Assistance Listing No. 93.576 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review and update existing controls. Document approvals throughout the process. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: 12/31/2024

View Audit 329880

Finding 512082 (2023-002)

Material Weakness 2023

Aliquippa School District

PA

Allowable Costs / Cost Principles Reporting § 200.403

CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant progr...

CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. MANAGEMENT’S CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of accounting records and preparation of all required financial reports related to PDE federal grant programs in a timely manner, and to ensure that the information reported to PDE is supported by the underlying documentation contained in the District’s general ledger. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program reports are prepared accurately and agree with the financial management system and supported by all underlying documentation.

View Audit 329826

Finding 512051 (2023-002)

Significant Deficiency 2023

Catholic Charities of Shiawassee and Genesee Counties

MI

Questioned Costs Allowable Costs / Cost Principles

The corporation Board of Directors adopted and implemented the required policies to ensure documentation supporting the allocation of personnel costs to federal and state grant programs be maintained for a minimum of five years.The actual administrative and case management costs charged to the grant...

The corporation Board of Directors adopted and implemented the required policies to ensure documentation supporting the allocation of personnel costs to federal and state grant programs be maintained for a minimum of five years.The actual administrative and case management costs charged to the grant were within the allowed budget. To ensure an accurate reflection of the true cost of theprogram, time studies and allocations will be reexamined at least biannually.

View Audit 329778 Questioned Costs: $1

Finding 512011 (2023-004)

Significant Deficiency 2023

Town of Enfield, Connecticut

CT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles School Nutrition Programs § 200.318 § 200.326

The Town and Board of Education have implemented a written policy for purchases using federal funds. This policy includes verifying that vendors have not been debarred.

View Audit 329761

Finding 512010 (2023-003)

Significant Deficiency 2023

Town of Enfield, Connecticut

CT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles School Nutrition Programs § 200.318 § 200.326

The Town and the Board of Education have prepared and implemented a written policy for purchases using federal funds.

View Audit 329761

Finding 511987 (2023-002)

Material Weakness 2023

Capital Area Community Services, Inc.

MI

Allowable Costs / Cost Principles Material Weakness Reporting

Finding 2023-002 - Material Weakness Recommendation: We recommend the Organization put procedures and controls in place to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. ...

Finding 2023-002 - Material Weakness Recommendation: We recommend the Organization put procedures and controls in place to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. Actions to be taken: The Organization concurs with the facts of this finding and are in the process of implementing procedures to ensure timely submission of the data collection form and reporting package.

View Audit 329750

Finding 511975 (2023-004)

Material Weakness 2023

Fredericksburg Area Health and Support Services, Inc.

VA

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.430

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net...

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net amount of $1,336, which when projected onto the remaining payroll and related costs that were not tested, amounted to $28,521. Corrective Action Taken or Planned: The Organization will review audit findings and ensure accurate future reimbursements, develop a comprehensive process for verifying time sheets against service delivery, and implement a paper timesheet system in which supervisors must enter time based on timesheets, ensuring 1:1 reimbursement. Name of Contact Person: Jacob Ducey, Grants Manager Phone Number of Contact Person: (540) 907-4555 Projected Completion Date: October 31, 2024

View Audit 329739 Questioned Costs: $1

Finding 509795 (2023-003)

Material Weakness 2023

Lead the Way Learning Academy

OH

Allowable Costs / Cost Principles

Views of Responsible Officials and Planned Corrective Actions:

View Audit 329526

Finding 509795 (2023-003)

Material Weakness 2023

Lead the Way Learning Academy

OH

Allowable Costs / Cost Principles

We agree that the allocation of indirect costs during the year ended December 31, 2023 were based on management estimates and not a supporting calculation.

View Audit 329526

Finding 509795 (2023-003)

Material Weakness 2023

Lead the Way Learning Academy

OH

Allowable Costs / Cost Principles

We will perform our indirect cost allocations based on time studies to have supporting data behind indirect costs to all functions, including individual federal awards, and to help ensure a more appropriate and equitable allocation. In addition, we will update our policy to reflect our actual alloca...

We will perform our indirect cost allocations based on time studies to have supporting data behind indirect costs to all functions, including individual federal awards, and to help ensure a more appropriate and equitable allocation. In addition, we will update our policy to reflect our actual allocation practices.

View Audit 329526

Finding 509788 (2023-005)

Material Weakness 2023

Boys & Girls Clubs of Central Georgia, Inc.

GA

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Official...

Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to ensure that terms and conditions of state and/or federal grant awards are reviewed by the CFAO and FM to identify unallowable activities. Identification of unallowable activities will be conveyed to all relevant parties. BGCCG management will also work closely with the CFAO and FM to implement procedures for pre-reviewing and pre-approval of all recommended purchases/costs to be charged to state and/or federal grant programs. Acknowledged, Phillip Bryant President & CEO

View Audit 329517

Finding 509771 (2023-004)

Material Weakness 2023

People Trust

AR

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.430

CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: We recommend management develop procedures requiring employees to track their time and effort by grant. Another individual should periodically review and approve these time and effort records before the funding request is s...

CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: We recommend management develop procedures requiring employees to track their time and effort by grant. Another individual should periodically review and approve these time and effort records before the funding request is sent to the federal agency or charged to the federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Each employee will track their time spent on the grant through Paychex. Timesheets will be approved by Arlo Washington, President, each payroll period. Name(s) of the contact person(s) responsible for corrective action: Arlo Washington Planned completion date for corrective action plan: January 1, 2025

View Audit 329488

Finding 509757 (2023-002)

None 2023

American Indian Community Housing Organization

MN

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.302 § 200.305 § 200.317 § 200.326

Contact Person LeAnn Littlewolf, Executive Director Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2024

View Audit 329421

Finding 509686 (2023-012)

None 2023

City of Philadelphia

PA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.344 § 200.403

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of ...

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of longstanding issues with over-allocations and the need to catch up on processing a backlog of documents. We appreciate you bringing this to our attention, as it provides an opportunity to refine our procedures and put in place measures to prevent these issues from recurring in the future. This feedback will be valuable as we work to improve our processes and enhance our ability to manage workloads more effectively. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

View Audit 329338 Questioned Costs: $1

Finding 509684 (2023-010)

Significant Deficiency 2023

City of Philadelphia

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Assistance Listing 14.267 Continuum of Care Program ...

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS acknowledges the finding and agrees with the need to develop a corrective action plan. Given that this will require collaboration across multiple units, we are unable to provide a specific timeline for a comprehensive and accurate response at this moment. However, I will take immediate steps to initiate the necessary discussions. It is important to note that the prevailing, though incorrect, understanding within our team was that when a match involves cash, the primary source of verification occurs during the filing of the Annual Performance Report (APR). Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

View Audit 329338

Finding 509675 (2023-002)

Significant Deficiency 2023

Impact Services Corporation

PA

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.326

Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance. training, incorporat...

Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact 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. These improvements will be in place by March 31, 2025. I, Timothy Jung, Interim Chief Financial Officer, will be responsible for resolving this deficiency by March 31, 2024.

View Audit 329334 Questioned Costs: $1

Finding 509650 (2023-001)

Significant Deficiency 2023

The Just One Project

NV

Allowable Costs / Cost Principles Eligibility Significant Deficiency

Management has implemented a filing system to ensure current client information is collected and recertified regularly. CSFP/SNW staff have maintained a system organizing all clients by month and year of registration, site of service, and then alphabetized by client name to aid in certification & re...

Management has implemented a filing system to ensure current client information is collected and recertified regularly. CSFP/SNW staff have maintained a system organizing all clients by month and year of registration, site of service, and then alphabetized by client name to aid in certification & recertification. Certification and recertification are occurring at CSFP/SNW distribution sites during service, and CSFP/SNW staff randomly audit files of active clients as they are being served to confirm their certification. CSFP/SNW staff also leverage a tracking system in our TJOP Salesforce Software System to reinforce client certification and recertification status. We will implement an internal audit at lease once annually to ensure participant files have all required documents and certifications.

View Audit 329285

Finding 509628 (2023-003)

Material Weakness 2023

Allen County

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.329

Reporting Errors for the Coronavirus State and Local Recovery Funds were discovered. Reporting errors were unintentional and were a result of not more closely following the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The employee who was responsible for entering...

Reporting Errors for the Coronavirus State and Local Recovery Funds were discovered. Reporting errors were unintentional and were a result of not more closely following the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The employee who was responsible for entering the information into the portal is no longer with Allen County. New responsible staff will be trained appropriately according to the most currently released guidance and every effort will be made to ensure accuracy and complete reporting.

View Audit 329231

Corrective Action Plans

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