Corrective Action Plans

Finding 498796 (2023-002)

Material Weakness 2023

IN

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

Management, with the inclusion of Butler CPA firm, will incorporate financial reporting internal controls to detect material adjustments, prevent materially misstated financial statements and increase the accuracy of the interim financial reports used by management. The Organization has implemented ...

Management, with the inclusion of Butler CPA firm, will incorporate financial reporting internal controls to detect material adjustments, prevent materially misstated financial statements and increase the accuracy of the interim financial reports used by management. The Organization has implemented Administration Responsibilities January 1, 2024, to alleviate all material adjustments and lack of documentation.

View Audit 321507

Finding 498782 (2023-101)

None 2023

Covenant Health, Inc.

MA

Questioned Costs Cash Management Allowable Costs / Cost Principles

Condition: During compliance testing, it was identified that an employee's wages were being charged to the grant after the employee was terminated. Corrective Action Taken or Planned: Management noted there was turnover in fiscal year 2023 which led to lack of some reviews. Controls have been pu...

Condition: During compliance testing, it was identified that an employee's wages were being charged to the grant after the employee was terminated. Corrective Action Taken or Planned: Management noted there was turnover in fiscal year 2023 which led to lack of some reviews. Controls have been put in place to ensure all worksheets are viewed for accuracy by the CFO prior to requesting drawdown amount. Name(s) of Contact Person(s) Responsible for Corrective Action Coleen Elias, Chief Executive Officer, Community Clinical Services. Anticipated Completion Date: Controls have been implemented as of the date of the audit report.

View Audit 321492 Questioned Costs: $1

Finding 498776 (2023-001)

Significant Deficiency 2023

Center for Applied Research Solutions, Inc.

CA

Allowable Costs / Cost Principles § 200.430 § 200.431

Finding 2023-001 Finding: Significant deficiency in Internal Control over Compliance (Allowable Costs) Corrective Action Plan: CARS management has reviewed the audit findings related to unallowable severance costs, as well as the governance of the estimated and applied fringe rate across all proj...

Finding 2023-001 Finding: Significant deficiency in Internal Control over Compliance (Allowable Costs) Corrective Action Plan: CARS management has reviewed the audit findings related to unallowable severance costs, as well as the governance of the estimated and applied fringe rate across all projects. It is the opinion of the auditor that projects were overburdened by severance costs that were unallowable due to being in excess of the company’s established policy for calculating severance. However, per guidance at 2 CFR 200.431, as identified in the criteria section of the report verbiage, severance pay is allowable when required by one, or more, of the following: 1. law, 2. employment agreement, 3. established policy that constitutes an implied agreement, and/or 4. circumstances of the particular employment. It is the opinion of CARS management that claimed severance costs are allowable based on two of the four criteria: 1. Circumstances of employment, and 2. An established policy that was, in effect, an agreement with the employees. Our organization had a written severance policy at the time these costs were incurred. Although all claimed severance costs were based on CARS’ current policy, we have accepted the terms of the audit results for the sole purpose of concluding the audit process. CARS does concur that the current written accounting policy needs to be updated to more accurately reflect and summarize the procedures in place. We are continuing to update written policy verbiage to ensure its alignment with the implied policy that had developed as a result of hiring practices across California’s protected classes. As a result of this audit report, CARS will continue to monitor and assess the need for additional procedures and incorporate changes into the indirect rate reporting processes and written policy as necessary. Anticipated Completion Date: CARS will have its severance policy updated by the end of the fourth quarter of 2024. CARS has updated its procedures to review and monitor the fringe rate and ensure all costs allocated to the final projects are allocable, reasonable in amount, and allowable per policy, contract terms, and regulations to include the documentation of the fringe rate review beginning in October 2024. CARS Contact Person Responsible for Corrective Action: Kerrilyn Nakai

View Audit 321473

Finding 498767 (2023-001)

Material Weakness 2023

Housing Authority of Asotin County

WA

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Housing Authority of Asotin County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Housing Authority is planning to take for findings included in this report in accordance with Title 2 U.S...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Housing Authority of Asotin County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Housing Authority is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with Housing Quality Standards enforcement requirements of its Housing Voucher Cluster program. Name, address, and telephone of Housing Authority contact person: KayLee Rosgen, Manager, Business and Finance 1212 Fair St., Clarkston, WA 99403 (509) 758-5751 ext. 4 Corrective action the auditee plans to take in response to the finding: The Housing Authority does concur with the State Auditor’s Office finding that the Housing Quality Standards (HQS) requirements are to follow up with the landlord if any life-threatening deficiencies are identified during an inspection. The requirement states that “If a deficiency is life-threatening, the owner (landlord) must correct the deficiency within 24 hours of notification” (24 CFR 982.404(a)(3)). The Housing Authority’s corrective action plan moving forward includes the following: • Reviewing HQS/NSPIRE standards with current staff assigned to performing and processing Section 8 inspections during a monthly meeting • Implement internal controls that ensure all life-threatening deficiencies are identified and all required notifications are made • Review all parts of the Code of Federal Regulations (CFR) and PIH notices distributed by HUD monthly that pertain to HQS/NSPIRE inspection standards • All pertinent staff will take the next NSPIRE Inspection Standards training (all inspectors and Section 8 Occupancy Specialist) • Updating our process to include the use of a new inspection checklist that separately identifies life-threatening deficiencies, as well as using a new form to document attempts to contact the landlord and the date the deficiency is resolved The Housing Authority acknowledges that we lacked the appropriate internal controls to identify and notify the landlords of any life-threatening deficiencies that must be corrected within 24 hours. With this corrective action plan in place as of September 9, 2024, the Housing Authority feels that we are on track to comply with the requirements set forth by HUD and any relevant CFRs. Anticipated date to complete the corrective action: September 9, 2024 (immediately and on-going)

View Audit 321448

Finding 498752 (2023-001)

Material Weakness 2023

Thurston County

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Thurston County January 1, 2023 through December 31, 2023 This schedule presents the corrective action planned by the County for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Thurston County January 1, 2023 through December 31, 2023 This schedule presents the corrective action planned by the County for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The County had inadequate internal controls for ensuring compliance with federal reporting requirements. Name, address, and telephone of County contact person: Darren Bennett, Financial Services Manager, (360) 867-2253 2000 Lakeridge Dr. SW Olympia, WA 98502-6090 Corrective action the auditee plans to take in response to the finding: The County values the opportunity to collaborate with the State Auditor’s Office in enhancing our financial reporting processes. In 2022, we faced notable turnover in the positions responsible for FFATA reporting due to the Public Health Emergency. Furthermore, as we transitioned out of this emergency in 2023, ongoing staffing challenges contributed to a loss of historical knowledge and established practices. In response to the recommendation, the County has taken and plans to take the following actions: • Update procedures for FFATA reporting, including staff responsibilities and timelines (implemented 8/2/2024). • Ensure management oversight to ensure timely and accurate reporting. • Provide training to all staff involved in the FFATA reporting process on their responsibilities (occurred 8/1/2024) We appreciate the opportunity to work with the State Auditor’s Office staff to improve the accuracy of our FFATA reporting requirements. Anticipated date to complete the corrective action: August 2, 2024

View Audit 321441

Finding 498750 (2023-001)

Material Weakness 2023

San Antonio Community Hospital

CA

Allowable Costs / Cost Principles Period of Performance Matching / Level of Effort / Earmarking

Finding 2023-001 Internal Control Deficiency over Allowable Costs Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036 Award Period of Performance: January 1, 2020 – July 1, 2022 Summary of Finding: Management did not consistently retain documentation evid...

Finding 2023-001 Internal Control Deficiency over Allowable Costs Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036 Award Period of Performance: January 1, 2020 – July 1, 2022 Summary of Finding: Management did not consistently retain documentation evidencing the performance of internal controls in place to review and approve FEMA expenditures submitted to the FEMA Portal. Corrective Action Plan: Management will ensure documentation is retained to evidence the controls were performed. Responsible Party: Wah-chung Hsu, Chief Financial Officer Anticipated Completion Date: December 31, 2024

View Audit 321440

Finding 498736 (2023-001)

Significant Deficiency 2023

Converge, Inc.

MS

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

Management agrees with the finding and has already implemented approval processes prior to purchasing. We have also implemented itemized receipts required for all purchase in our expense management software.

View Audit 321411 Questioned Costs: $1

Finding 498706 (2023-002)

Material Weakness 2023

Maine Afl-Cio

ME

Allowable Costs / Cost Principles

All invoices and expenditures follow procedures outlined in the ME AFL-CIO Financial Management Policies and receive approval prior to payment being issued. All amounts charged to the award reflect amounts in budgets approved in the contract. The Organization is now requesting stipend recipients t...

All invoices and expenditures follow procedures outlined in the ME AFL-CIO Financial Management Policies and receive approval prior to payment being issued. All amounts charged to the award reflect amounts in budgets approved in the contract. The Organization is now requesting stipend recipients to sign receipts. Regarding the six out of 20 disbursements lacking adequate support for expenses charged to the Registered Apprenticeship contract, five of these six were individual pre-apprentice participants who were prohibited from completing our financial need pre-screening form and signing it. As an alternative process we interviewed these five individuals and interviewed their pre-release supervisors and confirmed financial need in all five cases. Management will research compliance with CFDA numbers at the beginning of the grant. All grant related expenses match approved expenses in accordance with the contracts and grant guidance. Moving forward, we will implement tracking by class in Quickbooks, more aggressively track time charged to awards, and again review the OMB Compliance Supplements for each award.

View Audit 321405

Finding 498678 (2023-002)

Material Weakness 2023

Topeka Housing Authority

KS

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs § 200.403 § 200.405

The Authority will limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only. The Authority’s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2024.

View Audit 321393 Questioned Costs: $1

Finding 498668 (2023-002)

Material Weakness 2023

Mahnomen County

MN

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Contact Person – Bruce Starkey, County Administrator Corrective Action Plan – The County will review procedures to ensure expenditures charged to federal programs are supported with actual expenditures. Reports will undergo a review prior to submission. Completion Date – 9/30/2024

View Audit 321383 Questioned Costs: $1

Finding 498608 (2023-003)

Material Weakness 2023

City of Olympia

WA

Subrecipient Monitoring Special Tests & Provisions Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Olympia January 1, 2023 through December 31, 2023 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 2...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Olympia January 1, 2023 through December 31, 2023 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). ref number: 2023-003 Finding caption: The City did not have adequate internal controls in place for ensuring compliance with federal special reporting and rehabilitation requirements. Name, address, and telephone of City contact person: Darian Lightfoot, Director of Housing and Homeless Response 601 4th Ave E, Olympia, WA 98501 (360)753-8033 Corrective action the auditee plans to take in response to the finding: The City takes seriously the use of federal funds, and the compliance requirements associated with them. The Housing and Homelessness Response team is committed to ensuring there are no further instances of noncompliance by updating our processes to meet these requirements. The inspections of rehabilitation projects were being performed remotely by reviewing contractor invoices and payments as evidence of work completion. Though each individual project site was not visited, the team did perform on-site monitoring visits at subrecipients’ locations and reviewed subrecipients’ documentation of project files. This process was a holdover from COVID, when we were unable to physically go on site to every project site. As COVID restrictions have lifted, we understand that a physical inspection at each site is now necessary. Moving forward, we have implemented requirements to inspect all sites receiving CDBG rehabilitation funding as a part of project close-out. Staff will also continue to review subrecipient records during monitoring to ensure subrecipients have adequate recordkeeping of completed rehabilitation projects. The department was unaware of the requirements of the FFATA filing and will be scheduling trainings to learn more about grant requirements. We thank the auditors for bringing the requirements to our attention. Anticipated date to complete the corrective action: 12/31/2024

View Audit 321336

Finding 498591 (2023-002)

Material Weakness 2023

Baltimore Corps, INC

DC

Allowable Costs / Cost Principles § 200.430 § 200.514

Schedule of Corrective Action Plan For the Year Ended June 30, 2023 Finding 2023-002: Material Weakness over Activities Allowed or Unallowed and Allowable Cost/Cost Principle (Payroll) Responsible Official’s Response and Corrective Action Plan We concur with the finding related to deficiencies in ou...

Schedule of Corrective Action Plan For the Year Ended June 30, 2023 Finding 2023-002: Material Weakness over Activities Allowed or Unallowed and Allowable Cost/Cost Principle (Payroll) Responsible Official’s Response and Corrective Action Plan We concur with the finding related to deficiencies in our time tracking Process. We have implemented a time tracking system using QuickBooks Time starting in the fourth quarter of fiscal year 2024. This system is designed to accurately capture, and record employees’ hours worked by project/grant. Comprehensive training sessions have been conducted for all affected employees to ensure they are proficient in using the new time tracking system. Supervisors have received additional training on monitoring and verifying time entries. Planned Implementation Date of Corrective Action Plan April 1, 2024 Person Responsible for Corrective Action Plan Caryn York, Executive Director

View Audit 321331

Finding 498543 (2023-003)

Material Weakness 2023

Town of Arcadia

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Project and Expenditure (P&E) report covering April 1, 2022, to March 31, 2023, was submitted without a review or oversight process in place to prevent or detect and cor...

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Project and Expenditure (P&E) report covering April 1, 2022, to March 31, 2023, was submitted without a review or oversight process in place to prevent or detect and correct errors. As a result, errors in reporting were identified. Contact Person Responsible for Corrective Action: Jennifer Pickett Contact Person Phone Number: 317-984-3512 jennifer.pickett@arcadia.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the Clerk-Treasurer goes to do the Project and Expenditure report next, she will have the Grant Administrator set with her to complete the form. After the form is completed and has no errors the Clerk Treasurer will print the report off and allow her Deputy Clerk Treasurer to review it. Anticipated Completion Date: This will be corrected in 2025 when the report must be submitted again.

View Audit 321300

Finding 498531 (2023-001)

Material Weakness 2023

Howard County

IN

Allowable Costs / Cost Principles Material Weakness Period of Performance § 200.1 § 200.303

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The Deputy Auditor prepared the quarterly reports and the Auditor reviewed the reports; however, the control was not effective and did not detect and allow correction of mat...

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The Deputy Auditor prepared the quarterly reports and the Auditor reviewed the reports; however, the control was not effective and did not detect and allow correction of material misstatements prior to submission. Two of the four quarterly reports submitted during the audit period were selected for testing. For the two reports tested, all activity for the reporting period was not included, information submitted was not supported by the County's records, and the reports were not fairly presented Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number and Email Address: 765-456-2804 Jessica.secrease@howardcountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will follow the internal controls established, including policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E Report in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Chief Deputy will continue to work with the Projects Manager to ensure the reporting is accurate and all obligations and expenditures are reported correctly before sending the information to a third-party vendor. The Auditor will review and approve any reporting prior to submission. Initialed reports will be kept within the grant file. Anticipated Completion Date: September 2024

View Audit 321268

Finding 498509 (2023-004)

Material Weakness 2023

Traverse County

MN

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

Finding Number: 2023-004 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Shelly Staebler Corrective Action Planned: Traverse County Social Services Fiscal departmen...

Finding Number: 2023-004 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Shelly Staebler Corrective Action Planned: Traverse County Social Services Fiscal department will work on identifying allowable and unallowable expenditures that are submitted on these reports, so only allowable expenditures are submitted going forward. Anticipated Completion Date: Completed, September 7, 2024

View Audit 321238

Finding 498502 (2023-002)

Significant Deficiency 2023

Metropolitan Public Defender Services, Inc.

OR

Allowable Costs / Cost Principles

Finding no.: 2023-002 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactio...

Finding no.: 2023-002 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactions with a subaccount code that segregates them from overhead allocations. Costs related to facilities – rent, equipment leases, office insurance, shared supplies, depreciation, etc. – are now allocated to departments based on the square footage occupancy of each department, calculated using the guidance referenced in 2 CFR 200. Administrative costs that serve the entire organization such as Human Resources, Accounting, outsourced IT support, etc., are allocated to each department based on headcount, as we consider the number of personnel per department to be the best estimate of supporting services required by each team. The Payroll Specialist generates a current employee roster by department at the end of each month, which is used to update the administrative allocation. Once all costs have been allocated to the department level, both facilities and administrative costs are allocated down to individual grants based on the proportion of total wage costs assigned to each grant within the department for that month. Anticipated completion date: April 1, 2023

View Audit 321233

Finding 498501 (2023-001)

Material Weakness 2023

Metropolitan Public Defender Services, Inc.

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.420 § 200.476

Finding no.: 2023-001 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 15, 2023, a new timecard system was implemented and charges to grants are supported by actual timecard entries. Timecards are approved by the employee and reviewed by a supervisor prior to...

Finding no.: 2023-001 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 15, 2023, a new timecard system was implemented and charges to grants are supported by actual timecard entries. Timecards are approved by the employee and reviewed by a supervisor prior to payroll processing. Anticipated completion date: April 15, 2023

View Audit 321233

Finding 498487 (2023-002)

Significant Deficiency 2023

Enterprisekc

KS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Corrective Action Plan 2023-002: EnterpriseKC has conducted the suspension and debarment checks and has included those checks in the contract files for all covered transactions and has also updated its procedures to ensure those checks are conducted and added to the contract file at or before the co...

Corrective Action Plan 2023-002: EnterpriseKC has conducted the suspension and debarment checks and has included those checks in the contract files for all covered transactions and has also updated its procedures to ensure those checks are conducted and added to the contract file at or before the contract effective date. Completion Date: August 2024 Contact Person: Jay Konomos, Pillar Leader

View Audit 321192

Finding 498486 (2023-001)

Significant Deficiency 2023

Enterprisekc

KS

Questioned Costs Allowable Costs / Cost Principles § 200.413 § 200.430

Corrective Action Plan 2023-001: Management will implement a comprehensive time tracking review process that also extends to reviewing time for employees that choose to work remotely and will ensure that time not allocated to the grant is not included in the costs allocated to the grant. Management ...

Corrective Action Plan 2023-001: Management will implement a comprehensive time tracking review process that also extends to reviewing time for employees that choose to work remotely and will ensure that time not allocated to the grant is not included in the costs allocated to the grant. Management will revise the fringe benefit rate that gets charged to the hourly rates to ensure that none of the costs included in the fringe benefits are also direct expenses billed to the grant. The unallowable costs will be redirected to other allowable grant costs in 2024. Anticipated Completion Date: September 2024 Contact Person: Jay Konomos, Pillar Leader

View Audit 321192 Questioned Costs: $1

Finding 498466 (2023-001)

None 2023

Medical Debt Resolution, Inc.

NY

Questioned Costs Allowable Costs / Cost Principles

Finding Number: 2023-001 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Programs: United States Department of the Treasury ALN Number: 21.019 ALN Name: Coronavirus Relief Fund Contract Periods: August 9, 2022 – December 31, 2024 (County of Cook, Illinois); J...

Finding Number: 2023-001 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Programs: United States Department of the Treasury ALN Number: 21.019 ALN Name: Coronavirus Relief Fund Contract Periods: August 9, 2022 – December 31, 2024 (County of Cook, Illinois); June 16, 2023 – June 16, 2024 (City of New Orleans, Louisiana) Planned Corrective Action: In order to ensure that retroactive personnel costs are allocated to grants appropriately, the following measures are being implemented: 1. Effective October 1, 2024, Medical Debt Resolution, Inc. (the Organization) is transitioning to a common-date annual review including a common annual salary adjustment date for all personnel. This will ensure a timely administration of personnel compensation adjustments, thus eliminating the need for retroactive pay. 2. In the unlikely event of a retrospective pay need in the future, the Organization will develop and implement a new standard operating procedure for Allocation of Retrospective Pay which will provide guidelines for how to appropriately allocate the cost across funds if multiple periods are involved. 3. The Organization is thoroughly reviewing all retrospective payments made in 2023 and 2024 YTD and will be issuing an adjustment to all grants, as applicable, by October 31, 2024. Person Responsible: Vice President, Finance & Administration Expected Completion Date: October 31, 2024

View Audit 321164 Questioned Costs: $1

Finding 498463 (2023-010)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Allowable Costs / Cost Principles

Management’s response and corrective action is as follows: To improve the accuracy of ITA tracking, a revised ITA tracking system will be implemented. This will include data entry fields to capture all necessary information for each ITA payment, minimizing errors and omissions. Reconciliation wi...

Management’s response and corrective action is as follows: To improve the accuracy of ITA tracking, a revised ITA tracking system will be implemented. This will include data entry fields to capture all necessary information for each ITA payment, minimizing errors and omissions. Reconciliation with MUNIS on a monthly basis to identify any discrepancies. Additionally, mandatory training on the revised ITA Tracking system will be conducted for relevant staff members to ensure continuity. Expected Implementation Date: July 202 Contact person: Amanda Stanley, Chief WIOA Administrator, EmployBR

View Audit 321162

Finding 498460 (2023-009)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Allowable Costs / Cost Principles § 200.430

Management’s response and corrective action is as follows: To improve the accuracy and timeliness of payroll processing, a revised payroll procedures manual will be developed and disseminated to all staff responsible for time approval. Additionally, mandatory training on the ExecuTime system will ...

Management’s response and corrective action is as follows: To improve the accuracy and timeliness of payroll processing, a revised payroll procedures manual will be developed and disseminated to all staff responsible for time approval. Additionally, mandatory training on the ExecuTime system will be conducted for these staff members to ensure they have the necessary skills for proper and timely time sheet approvals. Expected Implementation Date: June 2024 Contact person: Amanda Stanley, Chief WIOA Administrator, EmployBR

View Audit 321162

Finding 498457 (2023-006)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Management’s response and corrective action is as follows: Architect certification is not required by the Department of Housing and Urban Development nor our policies and procedures. It is listed in our contracts as one of the many different types of reimbursement documentation our office will acc...

Management’s response and corrective action is as follows: Architect certification is not required by the Department of Housing and Urban Development nor our policies and procedures. It is listed in our contracts as one of the many different types of reimbursement documentation our office will accept. For many projects, an architect certification for each draw would be financially prohibitive and would likely reduce the financial viability of affordable housing developments. Our office does conduct intermittent on-site or desktop monitoring throughout the course of the project to ensure evidence activities. Additionally, all construction projects must complete permit requirements to ensure housing quality. Evidence of monitoring or activity was provided to the auditors. Expected Implementation Date: October 2024 Contact person: Marlee Pittman Miller, Director, Mayor-President’s Office of Community Development

View Audit 321162

Finding 498455 (2023-004)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.522

Management’s response and corrective action is as follows: After reviewing the condition, cause, and effect of the presented Finding, the City-Parish finds it important to clarify that the duplicative charges were initially identified and documented as a self-reported finding. This discrepancy was...

Management’s response and corrective action is as follows: After reviewing the condition, cause, and effect of the presented Finding, the City-Parish finds it important to clarify that the duplicative charges were initially identified and documented as a self-reported finding. This discrepancy was discovered during the subrecipient monitoring component of this award and was promptly reported and reconciled prior to being presented as an audit finding. Upon identification of the duplicative charges, totaling approximately $22,000, immediate corrective action was taken to address the non-compliance. Dated January 5, 2024, a memorandum was filed disclosing the duplicative reimbursements, documenting the actions taken to rectify these charges, and recommending further steps to enhance the internal controls of the non-profit organization. The following information summarizes the East Baton Rouge City-Parish American Rescue Plan Act (ARPA): Duplication of Benefits - Findings and Corrective Action Memorandum: This memorandum documents the incidental reimbursement of multiple duplicative items associated with the subrecipient’s grant agreement and the corrective actions undertaken to resolve these findings, ensuring compliance with the terms of this award. During the routine subrecipient monitoring reviews, it was discovered that duplicate reimbursements occurred for 12 items between separate federal awards (American Rescue Plan Act SLFRF and CARES Act). In accordance with 2 CFR 200.522(c), a corrective action plan was provided to resolve the non-compliance. To address this, the following actions were taken: 1) Reconciliation of Duplicate Reimbursements: The non-profit entity has since reconciled the total value of $22,222.98 in duplicate reimbursements with an equivalent value of eligible expenses, including all necessary backup documentation to satisfy existing procurement and reimbursement requirements. 2) Development of a Duplication of Benefits Policy: It was recommended that the non-profit entity develop a comprehensive duplication of benefits policy to strengthen their internal controls further. These additional safeguards are considered best practices and are intended to minimize the risk of future non-compliance. Additionally, a comprehensive, grant specific, financial management policy template was provided to support the non-profits action to adopt and implement an appropriate standard of internal controls. The City-Parish is committed to maintaining robust internal controls and ensuring compliance with federal regulations. Immediate corrective measures were proactively taken to address these duplicative charges. Additionally, the City-Parish's third-party grants manager has established recurring weekly monitoring meetings with the non-profit entity to support the development and implementation of an adequate system of internal controls. Continuous efforts are being made to improve these processes to prevent such issues in the future. Expected Implementation Date: January 2024 Contact person: Courtney Scott, Assistant Chief Administrative Officer, Mayor-President’s Office

View Audit 321162 Questioned Costs: $1

Finding 498454 (2023-003)

None 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Allowable Costs / Cost Principles

Management’s response and corrective action is as follows: The volume, complexity, and rapid pace needed to provide benefits inherently results in higher risk of fraud. The City-Parish's policies and procedures detected the fraud as required by program guidance. Additional restrictions were impleme...

Management’s response and corrective action is as follows: The volume, complexity, and rapid pace needed to provide benefits inherently results in higher risk of fraud. The City-Parish's policies and procedures detected the fraud as required by program guidance. Additional restrictions were implemented to further protect the program from fraud including no longer allowing any exceptions to homestead, not allowing any single-room rentals, and requiring a landlord provide documentation of 3 months of rental payments/deposits—no handwritten receipts accepted. The City-Parish also sent an email blast out to applicants to ensure they understood the additional documentation requirements. Consultants for the City-Parish provided a fraud detection tip sheet to case managers, consolidating previously given guidance, to assist them in determining potential incidents of fraud. There have been no instances of suspected fraud since July 2023 due to these measures. Expected Implementation Date: June 2024 Contact person: Dante Bidwell, Chief Administrative Officer, Office of the Mayor-President

View Audit 321162 Questioned Costs: $1

Corrective Action Plans

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