Corrective Action Plans

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Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staf...
Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staff members during each phase of the grants management lifecycle, as well as implementing procedures and tools to ensure compliance with subrecipient monitoring requirements. These steps involve multiple levels of review for accurate and consistent application of indirect cost rates. Finance will continue implementing the corrective actions necessary to achieve effective controls over compliance with indirect cost rate requirements. Policy and procedures on allowable and allocable costs will be drafted to clearly document how direct and indirect costs will be billed to federal awards. Training will be provided to relevant staff members to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date remains June 30, 2026.
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across dep...
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across departments and teams. Finance will continue implementing the corrective actions necessary to establish an effective and compliant time and effort reporting system, including providing training for employees and regularly monitoring for effective system utilization. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date remains June 30, 2027.
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Dr. Derek Etheridge, Executive Director of Business Services Anticipated Completion Date: March 1, 2026 Planned Corrective Action: Reimbursements for federal...
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Dr. Derek Etheridge, Executive Director of Business Services Anticipated Completion Date: March 1, 2026 Planned Corrective Action: Reimbursements for federal grant expenditures will be verified and signed by two individuals, including the person responsible for the reimbursement request and a member of the management team.
2025-004: Internal Control over Activities Allowed/Allowable Costs – COVID-19: Education Stabilization Fund Corrective Action: The District acknowledges this finding. Invoices are reviewed by the Administration and Board of Education monthly. Additional reviews by administration will be put into pla...
2025-004: Internal Control over Activities Allowed/Allowable Costs – COVID-19: Education Stabilization Fund Corrective Action: The District acknowledges this finding. Invoices are reviewed by the Administration and Board of Education monthly. Additional reviews by administration will be put into place. The Board of Education shall approve the pay rates annually and appropriate documentation kept. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing
2025-003: Internal Control over Eligibility – Child Nutrition Cluster Corrective Action: Acknowledging the lack of controls within the Child Nutrition program's eligibility process, the District has determined that hiring additional staff to resolve this internal control deficiency is not a cost-eff...
2025-003: Internal Control over Eligibility – Child Nutrition Cluster Corrective Action: Acknowledging the lack of controls within the Child Nutrition program's eligibility process, the District has determined that hiring additional staff to resolve this internal control deficiency is not a cost-effective solution. Consequently, the Food Service Director and the Finance Director share the responsibility of reviewing student eligibility forms. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing
Corrective Action Plan Single Audit Finding 2025-001: Internal Controls over Allowable Costs/Activities Plan: The IFA acknowledges the importance of internal controls and appropriate segregation of duties ensuring the review and approval process for Authority financial transactions (i.e., expenditur...
Corrective Action Plan Single Audit Finding 2025-001: Internal Controls over Allowable Costs/Activities Plan: The IFA acknowledges the importance of internal controls and appropriate segregation of duties ensuring the review and approval process for Authority financial transactions (i.e., expenditures applied to corresponding grants are allowable; month-end financial entries; etc.). With recent staff additions, IFA has enhanced its internal control environment by implementing a review/authorization process to ensure the preparation and approval of journal entries (i.e., month-end, etc.) occurs in accordance of established internal controls and appropriate segregation of duties (e.g., month-end journal entries prepared by the IFA SVP-FA are reviewed and approved by the IFA Chief Operating Officer, or appropriate designee). Since manual or adjusting journal entries are information processing activities that carry higher risk, a review of journal entries after posting serve as acceptable verification control in accordance with the United States Government Accountability Office Standards for Internal Control in the Federal Government that helps ensure transactions are appropriate. These post-entry reviews represent an acceptable form of management oversight (Principle 16) and serve as an acceptable validation check (Principle 10) to confirm that entries align with supporting documentation, reconcile with expectations, and aligned with organizational directives. Month Implemented: November 2025 IFA Contact: Ms. Ximena Granda SVP – Finance & Administration xgranda@il-fa.com Office (312) 651-1362
Finding 2025-002: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that key control documentation is retained on file. The payroll file will be approved by either the Superintendent or th...
Finding 2025-002: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that key control documentation is retained on file. The payroll file will be approved by either the Superintendent or the CFO prior to payment, and proof of prior approval will be maintained in the School’s files. The new process began in January 2026. Responsible Party: Kemlyn Williams, Superintendent Dynamic Support Solutions, Contract CFO
Finding 2025-001: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that invoices are approved prior to being paid. Expenses are reviewed and approved through the PO process within the Asc...
Finding 2025-001: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that invoices are approved prior to being paid. Expenses are reviewed and approved through the PO process within the Ascender System. Each request is evaluated for accurate account coding, appropriateness, and compliance with Federal Grant allowable costs (when necessary). Spending and allowable costs are closely monitored on an ongoing basis. Once orders have been placed, products have been received/services rendered, and invoices received, the accounting clerk will prepare documents for the check run. A “check payments” report is provided which lists all transactions for the check run. The “check payments” document clearly displays the vendor, account code, and amount of each transaction. The “check payments” report is approved by Superintendent. Once “check payment” report is approved by Superintendent, the check run will be initiated. Documentation of prior approval will be kept on file. The new process began in March 2025. Responsible Party: Kemlyn Williams, Superintendent Dynamic Support Solutions, Contract CFO
The Office of Financial Aid has implemented a formal annual review process to determine whether Golden Gate University should request a waiver of the Federal Work-Study (FWS) expenditure requirement for the upcoming waiver period. Each February, the Associate Director of Financial Aid and the Senior...
The Office of Financial Aid has implemented a formal annual review process to determine whether Golden Gate University should request a waiver of the Federal Work-Study (FWS) expenditure requirement for the upcoming waiver period. Each February, the Associate Director of Financial Aid and the Senior Director of Student Financial Services will evaluate projected spending and decide if a waiver is necessary. If a waiver is required, it will be submitted within the designated deadline, which typically falls between March and April each year.
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management is responsible for preparing and invoicing for all Federal awards. Completed i...
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management is responsible for preparing and invoicing for all Federal awards. Completed invoices will be circulated back to key project staff for review prior to final management review, signature, and submission to awarding agency. Training tools on timekeeping will be improved to ensure all staff employed on a Federal award adequately comply with cost principles. Anticipated completion date: 05/01/2026
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management will complete a two-step review process to ensure expenses are being validated...
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management will complete a two-step review process to ensure expenses are being validated correctly. Additionally, a selective self-audit program will be developed to verify that recordkeeping is complete and effective. Anticipated completion date: 05/01/2026
During the period under review, the organization experienced turnover in the accounting position, which impacted continuity in grant reporting processes. In addition, VOCA grant funding administered through JCS (the grantor) transitioned from an advance payment method to a reimbursement-based paymen...
During the period under review, the organization experienced turnover in the accounting position, which impacted continuity in grant reporting processes. In addition, VOCA grant funding administered through JCS (the grantor) transitioned from an advance payment method to a reimbursement-based payment structure. This change significantly affected the timing and presentation of expenditures reported on monthly financial reports. Management would like to clarify that the revisions made to all 12 reports were not the result of unallowable or unsupported costs. As noted in the audit, there were no questioned costs. The grantor adjusted the reports primarily due to the shift in payment methodology and reconciliation of prior-year unexpended funds. In several instances, JCS modified invoice amounts after submission to align with its updated reimbursement process and internal grant tracking. These post-submission adjustments were administrative in nature and not attributable to improper expenditure classification or misuse of grant funds by the organization. We recognize, however, that stronger internal review controls could have reduced the need for grantor-initiated revisions. To address this matter and strengthen compliance EPEC, has instituted a double check procedure on invoices.
AUDITEE’S CORRECTIVE ACTION PLAN As required by 2 CFR 200.511, the Rankin County School District has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questioned Costs for the year ended June 30, 2025: Finding Correction Action...
AUDITEE’S CORRECTIVE ACTION PLAN As required by 2 CFR 200.511, the Rankin County School District has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questioned Costs for the year ended June 30, 2025: Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Lisa Worthy – Chief Financial Officer b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with all federal grant requirements. c. Anticipated Completion Date: Immediately.
Finding Number 2025-002 Condition: The District could not provide supporting documentation for one (1) invoice charged to the program. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retenti...
Finding Number 2025-002 Condition: The District could not provide supporting documentation for one (1) invoice charged to the program. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin
Finding Number 2025-001 Condition: The District was unable to provide documentation for three invoices charged to the program. The District was also unable to provide supporting documentation for one employee time card. Management Response/Plan: The District acknowledges the finding and has strength...
Finding Number 2025-001 Condition: The District was unable to provide documentation for three invoices charged to the program. The District was also unable to provide supporting documentation for one employee time card. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin
Corrective Actions Taken or Planned: MARTA recognizes the importance of ensuring all expenses are approved before they are incurred. To address this finding, MARTA is updating its internal procurement rules to clearly state that a purchase order must be signed prior to ordering any items or initiati...
Corrective Actions Taken or Planned: MARTA recognizes the importance of ensuring all expenses are approved before they are incurred. To address this finding, MARTA is updating its internal procurement rules to clearly state that a purchase order must be signed prior to ordering any items or initiating any services. This measure will prevent the receipt of invoices for costs that have not been officially authorized. Additionally, MARTA is creating a formal backup approval plan. Under this plan, if the General Manager is unavailable, another designated leader will have the documented authority to approve purchases immediately, eliminating the need to wait for the General Manager’s return to complete the necessary paperwork. Finally, MARTA’s finance team will implement a new check-and-balance step in the payment process. Moving forward, the team will verify that the date on the approved purchase order comes before the date on the vendor's invoice. If the dates are out of sequence, the payment will be flagged for review. In addition, MARTA will conduct a training session for all department heads to reinforce that verbal orders are not permitted and that written authorization must always be obtained first. This plan is designed to ensure full compliance with federal grant requirements and prevent any future delays in the approval process. Personnel responsible: Sandra Benson, General Manager Anticipated completion date: October 2026
Contact Person Tonya Hunskor Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2026.
Contact Person Tonya Hunskor Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2026.
Management Response: Management acknowledges that funding percentages in the accounting system did not match the cost allocation plan for several transactions, resulting in a nominal overcharge to the grants. To prevent this in the future, management will institute a mandatory verification step wher...
Management Response: Management acknowledges that funding percentages in the accounting system did not match the cost allocation plan for several transactions, resulting in a nominal overcharge to the grants. To prevent this in the future, management will institute a mandatory verification step where funding percentages entered into the accounting system are cross-referenced directly against the approved cost allocation plan. We will ensure that the amounts charged to grants agree strictly with the approved percentages. Any discrepancies or rounding issues will be addressed by allocating differences to the organization's operating expense class rather than a government grant, ensuring federal awards are not overcharged. Parties Responsible and Timeline The Executive Director and Accountant will conduct a review of current system percentages against the cost allocation plan immediately. Updates to the internal review process for cost allocations will be approved by TXAEYC’s Finance Committee and Governing Board by April 30, 2026.
Management Response: TXAEYC acknowledges that during testing, certain samples did not include documented approval of invoices prior to allocation to grant activities. We recognize the need for robust internal controls to reduce the risk of noncompliance. To remedy this, the organization will impleme...
Management Response: TXAEYC acknowledges that during testing, certain samples did not include documented approval of invoices prior to allocation to grant activities. We recognize the need for robust internal controls to reduce the risk of noncompliance. To remedy this, the organization will implement a strict prior approval process for all grant expenditures. We will update our standard operating procedures to ensure that every invoice is reviewed and approved by authorized personnel before being allocated to the grant. Furthermore, all support for these approvals will be documented and kept on file to ensure a clear audit trail. Parties Responsible and Timeline Updates to the expenditure approval procedures in the Accounting Manual will be drafted by the Executive Director and Accountant and submitted to the Finance Committee and Governing Board for approval by April 30, 2026. Implementation of the prior approval documentation process will begin immediately upon Board approval.
2025-003 Salaries and wages are charged to federal awards through separate manual tracking worksheets for each award. Additionally, although salaries and wages are allocated to grants in the Organization’s accounting system, the allocation only occurs at a summary level, moving all costs from admini...
2025-003 Salaries and wages are charged to federal awards through separate manual tracking worksheets for each award. Additionally, although salaries and wages are allocated to grants in the Organization’s accounting system, the allocation only occurs at a summary level, moving all costs from administrative rather than where they were recorded. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: January 2026 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes to ensure no double dipping occurs. The new CFO along with the newer members of the Finance Department have developed better controls and processes to ensure grant expenditures, including payroll expenses and allocations, are properly accounted for in the accounting system with adequate backup of grant draw downs. With the implementation of a new payroll system and a new accounting system in 2026, these issues should resolve themselves with oversight provided by the CFO. The Organization’s CEO, a former CFO of the organization, will continue to provide oversight for the Finance Department to ensure controls and processes are implemented.
While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that...
While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely pr...
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications. Identification of repeat finding: N/A Resolution: The Time and Effort Reporting form was updated on February 6, 2026, to more accurately reflect the semesters covered by the form submitted by the respective program. The Grants Accounting Office will obtain the completed forms within 90 days of the last day of the performance period. The forms will be completed on a biannual basis and collected from each respective program within 90 days following the end date of the most recent semester.
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporti...
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators
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