Corrective Action Plans

Finding 51057 (2022-001)

Significant Deficiency 2022

OR

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

The District?s Indirect costs worksheet to determine allowable costs had an error in the calculation. The District has addressed the cause of the error and future amounts should calculate correctly.

View Audit 41523

Finding 51055 (2022-102)

Significant Deficiency 2022

Greater Phoenix Urban League INC

AZ

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

Responsible Individual: William Bridgeman, George Dean Corrective Action Plan: Greater Phoenix Urban League didn?t agree with the recommendation reference in the monitoring report produced by the grantee?s monitoring contractor ?The Pun Group? The entire $69,980 of consultant cost was supported by i...

Responsible Individual: William Bridgeman, George Dean Corrective Action Plan: Greater Phoenix Urban League didn?t agree with the recommendation reference in the monitoring report produced by the grantee?s monitoring contractor ?The Pun Group? The entire $69,980 of consultant cost was supported by invoices detailing the hours/cost charged to Head Start ($46.107) and Central Office ($23,873) by billing cycle. Each invoice was reviewed and approved by the President/CEO prior to payment. The invoices submitted were based upon ?actual? time and effort? and not on an ?allocation methodology. A check in the amount of $46,107 was submitted to the City of Phoenix reimbursing the grantee to resolve the issue. Anticipated Completion Date: February 23, 2023

View Audit 48064 Questioned Costs: $1

Finding 51054 (2022-101)

Significant Deficiency 2022

Greater Phoenix Urban League INC

AZ

Questioned Costs Allowable Costs / Cost Principles

Finding 2022-101 Responsible Individual: William Bridgeman, Natalie Alvarez Corrective Action Plan: Greater Phoenix Urban League (Delegate Agency) will collaborate with the City of Phoenix (Grantee) in evaluating year-to-date cumulative in-kind match on a quarterly basis to ensure the year- to- date...

Finding 2022-101 Responsible Individual: William Bridgeman, Natalie Alvarez Corrective Action Plan: Greater Phoenix Urban League (Delegate Agency) will collaborate with the City of Phoenix (Grantee) in evaluating year-to-date cumulative in-kind match on a quarterly basis to ensure the year- to- date is tracking at a level to meet the required 20% match based upon the anticipated actual funding. At the end of each quarter, if Greater Phoenix Urban League determines that it will be unable to meet the required match on an annualized basis the delegate agency will utilize the projected analysis year-to-date forecast. The Greater Phoenix Urban League will notify the grantee in writing requesting a review of anticipated revenue and develop an action plan to meet the 20% match or request a waiver following the Head Start Performance Standards Guidelines. Anticipated Completion Date: Ongoing throughout the contract period on an annualized basis. June 30, 2023

View Audit 48064 Questioned Costs: $1

Finding 51036 (2022-003)

Significant Deficiency 2022

West Deptford Board of Education

NJ

Allowable Costs / Cost Principles

Finding No. 2022-003 Information on the Federal Program U.S. Department of Treasury ? Coronavirus State and Local Fiscal Recovery Fund (SLFRF) (Assistance Listing Number 21.027) (FAIN ? SLFRFDOE1SES) -7/1/21 ? 6/30/22 Passed through N.J. Department of Education as Additional or Compensatory Special ...

Finding No. 2022-003 Information on the Federal Program U.S. Department of Treasury ? Coronavirus State and Local Fiscal Recovery Fund (SLFRF) (Assistance Listing Number 21.027) (FAIN ? SLFRFDOE1SES) -7/1/21 ? 6/30/22 Passed through N.J. Department of Education as Additional or Compensatory Special Education and Related Services (ACSERS) Condition - The School District did not make adjustments to the initial cost estimates for ACSERS; therefore, the School District was reimbursed more costs than were actually incurred. Recommendation - The School District develop and implement internal control procedures to ensure only allowable costs are reported to grantor agency when seeking reimbursements. Method of Implementation - The School District shall allow an internal control procedure that completes a verification of a report prior to submission. This will allow a third party verification of the submitted report. Person Responsible - Child Study Team Director / School Business Administrator. Planned Date of Completion - Immediate. See Corrective Action Plan for full chart/table

View Audit 43178

Finding 51019 (2022-002)

Material Weakness 2022

Two Rivers Regional Council of Public Officials

IL

Allowable Costs / Cost Principles

Corrective Action Plan The Finance Director has implemented policy through the 2022 term of reviewing all funds at least once a quarter and all major funds once a month. The Finance Director will review any outstanding funds with balances and complete closing of funds. Anticipated Completion Date 1s...

Corrective Action Plan The Finance Director has implemented policy through the 2022 term of reviewing all funds at least once a quarter and all major funds once a month. The Finance Director will review any outstanding funds with balances and complete closing of funds. Anticipated Completion Date 1st Quarter 2023 Responsible Parties Jeremy Oshner, Executive Director Mike Muehl, Finance Director 107 North 3rd Quincy, IL 62301 (217) 224-8171

View Audit 51685

Finding 50981 (2022-003)

Significant Deficiency 2022

Union County

NC

Questioned Costs Allowable Costs / Cost Principles Cash Management

Responsible Parties: Michelle Lancaster, Deputy County Manager / Human Services Director Beverly Liles, Finance Director ...

Responsible Parties: Michelle Lancaster, Deputy County Manager / Human Services Director Beverly Liles, Finance Director Finding 2022-003, Significant Deficiency and Nonmaterial Noncompliance - Special Test and Provisions See Corrective Action Plan for chart / table.

View Audit 45126 Questioned Costs: $1

Finding 50979 (2022-001)

Significant Deficiency 2022

The Montessori Network

IL

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties

Corrective Action Plan Finding 2022-001 Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding wa...

Corrective Action Plan Finding 2022-001 Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal year 2020, and corrective actions were taken by the School in 2021. To address the issue, the School implemented new procedures that require a monthly review by management, which includes a detailed reconciliation of submitted personnel activity reports to vouchers prepared for federal and other programs. This reconciliation process helps to ensure that payroll cost allocation accurately reflects the submitted personnel activity reports. In addition, the School has made changes to its payroll system to ensure accurate time tracking for its various programs. This includes changing the service provider responsible for voucher submissions. These changes will help to prevent similar issues from occurring in the future and ensure that employee-related costs are accurately allocated to the appropriate programs. As of 2022, the School has successfully implemented these changes and continues to review and monitor its procedures to maintain compliance with federal and other program regulations. Anticipated Completion Date: June 30, 2022 Contact Person: Rita Nolan, Executive Director

View Audit 45124

Finding 50976 (2022-001)

Material Weakness 2022

Ou Medicine, Inc.

OK

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

Corrective Action Plan Finding 2022-001 Internal Control Deficiency Allowed/Allowable Costs At the beginning of the pandemic, OU Health created working groups to evaluate the requirements for COVID-19 funding received and ensure the funds were only used for allowable purposes. The working groups w...

Corrective Action Plan Finding 2022-001 Internal Control Deficiency Allowed/Allowable Costs At the beginning of the pandemic, OU Health created working groups to evaluate the requirements for COVID-19 funding received and ensure the funds were only used for allowable purposes. The working groups were assisted by outside consultants to stay updated on the reporting requirements as the continued to evolve. As part of the Uniform Guidance audit, OU Health provided documentation of the FEMA review process that explained how eligible costs were identified and submitted. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will develop a checklist to document the review and approval of supporting documentation of personnel costs as reported as FEMA federal expenditures. The supporting documentation will be reviewed by management to ensure expenses charged to the federal program are allowable and have not been reimbursed under another federal program. The checklist will be retained with the existing report. Responsible Official: Michael Milligan, Vice President of Accounting Anticipated Completion Date: March 31, 2023

View Audit 40950 Questioned Costs: $1

Finding 50966 (2022-001)

Significant Deficiency 2022

Carver County

MN

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Significant Deficiency

Carver County ? Corrective Action Plan Year Ended December 31,2022 U.S. Department of Health and Human Services Carver County respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: 1/1/2022 to 12/31/2022 The findings from the schedule of finding...

Carver County ? Corrective Action Plan Year Ended December 31,2022 U.S. Department of Health and Human Services Carver County respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: 1/1/2022 to 12/31/2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT None FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Services 2022-001 Medical Assistance ? Assistance Listing No. 93.778 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual?s termination to other departments. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure timely notice is given to other departments of an individual?s termination. Name of the contact person responsible for corrective action: Mary Kaye Wahl (Assistant Financial Services Director) Planned completion date for corrective action plan: December 31, 2023. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Mary Kaye Wahl at 962-361-1938.

View Audit 43619

Finding 50959 (2022-009)

Significant Deficiency 2022

Ucan

IL

Questioned Costs Period of Performance Allowable Costs / Cost Principles § 200.403

Identifying Number: 2022-009 Finding: Period of Performance: payroll costs Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly recorded and reported. UCAN has already taken steps to insure that i...

Identifying Number: 2022-009 Finding: Period of Performance: payroll costs Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly recorded and reported. UCAN has already taken steps to insure that items are billed in the period incurred and only items that fall into the grant period are billed. We believe that significant turnover in the finance department led to this deficiency, so we are actively documenting procedures and cross-training employees, so we always have coverage. All vouchers will also go through a review process before they are sent to the funder. This is a repeat finding, with the original corrective action plan to be completed before June 30, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

View Audit 53429 Questioned Costs: $1

Finding 50958 (2022-008)

Material Weakness 2022

Ucan

IL

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Identifying Number: 2022-008 Finding: Unallowable cost ? salary certification and personnel activity reports Corrective Actions Taken or Planned: UCAN agrees with this finding and believes the turnover in personnel affected this area as there was a misunderstanding on what was required. Employees ...

Identifying Number: 2022-008 Finding: Unallowable cost ? salary certification and personnel activity reports Corrective Actions Taken or Planned: UCAN agrees with this finding and believes the turnover in personnel affected this area as there was a misunderstanding on what was required. Employees in leadership positions have been trained on what is required and are ensuring that all staff certifications are being gathered monthly. This is a repeat finding, with the original corrective action plan to be completed before December 31, 2022. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

View Audit 53429 Questioned Costs: $1

Finding 50957 (2022-014)

Significant Deficiency 2022

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Allowable Costs / Cost Principles

2022-014) Allowable Costs Management?s response and corrective action is as follows: In developing the Cost Allocation Plan, the City-Parish previously excluded risk management costs in the calculation of the rate for the Head Start program. When the City-Parish began utilizing a new consultant t...

2022-014) Allowable Costs Management?s response and corrective action is as follows: In developing the Cost Allocation Plan, the City-Parish previously excluded risk management costs in the calculation of the rate for the Head Start program. When the City-Parish began utilizing a new consultant to prepare the Cost Allocation Plan, the consultant included those costs in the rate calculation when they should have been excluded. The 2023 report will be revised to exclude costs for risk management functions and will continue to be excluded for future plans. The City-Parish does not charge the full amount of indirect costs that would be allowable based on the approved indirect cost rate to the grant programs that paid for the insurance policies. In 2022, the indirect cost allowable based on the approved rate was $1,410,223.04; however, only $131,232.00 was directly charged to the Head Start grant and $955,904.84 was used as in-kind match leaving a balance of $323,086.20 in allowable indirect cost that was not charged. Expected Implementation Date: June 2023 Contact person: Shalanda Nalencz, Accounting Manager, Finance Department

View Audit 53428 Questioned Costs: $1

Finding 50955 (2022-005)

Significant Deficiency 2022

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Allowable Costs / Cost Principles

2022-005) Allowable Costs Management?s response and corrective action is as follows: In an effort to avoid non-compliance with the federal grant program, all employee payroll charges will be transferred to an alternative City-Parish funding source. If a federal grant program is used in the future...

2022-005) Allowable Costs Management?s response and corrective action is as follows: In an effort to avoid non-compliance with the federal grant program, all employee payroll charges will be transferred to an alternative City-Parish funding source. If a federal grant program is used in the future for employee payroll charges, the employees will be trained on the applicable federal guidelines prior to use. Expected Implementation Date: June 2023 Contact person: Adam Smith, Interim Director, Environmental Services

View Audit 53428 Questioned Costs: $1

Finding 50946 (2022-001)

Significant Deficiency 2022

Piedmont Healthcare, Inc.

GA

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303

Finding No. 2022-001 ? Activities Allowed and Unallowable/Allowable Costs Program: COVID -19 Provider Relief Fund Award Year: January 1, 2020 through June 30, 2022 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over th...

Finding No. 2022-001 ? Activities Allowed and Unallowable/Allowable Costs Program: COVID -19 Provider Relief Fund Award Year: January 1, 2020 through June 30, 2022 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work, we selected a sample of 40 incentive bonus payments made during the fiscal year 2022 reporting period. We noted that PHC was unable to provide evidence of management review and approval for each of the incentive bonus payments sampled. These disbursements were made for allowable costs under the terms and conditions of the program. (c) Possible Cause PHC was unable to provide evidence of certain management reviews and approvals because the control was not designed to require the retention of documentation of management review at the transactional level. (d) Questioned Cost None. (e) Effect Evidence of the effective operation of management review controls was not maintained in accordance with Federal requirements. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year Repeat of prior year Finding No. 2021-001. (h) Recommendation We recommend that PHC strengthen controls over the management review process to enhance the retention of evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While we believe appropriate controls exist relating to the management review and approval of allowable costs at the transactional level, we concur that procedures relating to obtaining and maintaining documentation of such reviews need to be strengthened. (j) Corrective Action Plan Management will ensure communication of the finding to the reviewers and submitters of allowable costs and revise procedures to ensure documentation of reviews and approvals is obtained and maintained. Prior to submitting allowable costs to Health Resources and Services Administration (?HRSA?), we will obtain documentation of the approval of these costs and maintain this documentation in the same manner as the documentation of the submission of the costs to HRSA. (k) Anticipated Completion Date Correction of corrective action anticipated by August 31, 2023. (l) Name of Person for Corrective Action Marie Gaffney, Vice President Corporate Finance: (470) 271-6007.

View Audit 53715

Finding 50945 (2022-001)

Material Weakness 2022

Garrett Regional Medical Center

MD

Questioned Costs Allowable Costs / Cost Principles Special Tests & Provisions § 200.303

Finding 2022-001- Allowable Costs, Activities Allowed and Special Tests and Provisions Contact Person: Lori Dixon Management?s Response: GRMC management will implement the following processes/procedures as a result of the finding of the 2022 Single Audit. During the audit review, FEMA hours we...

Finding 2022-001- Allowable Costs, Activities Allowed and Special Tests and Provisions Contact Person: Lori Dixon Management?s Response: GRMC management will implement the following processes/procedures as a result of the finding of the 2022 Single Audit. During the audit review, FEMA hours were found to be unallowable on sample patients treated for COVID. Management reviewed the findings and identified additional patients/hours not covered by other funding sources to replace the unallowed data totaling $8,550. Completion Date: The steps above will be completed by October 31, 2023.

View Audit 52431 Questioned Costs: $1

Finding 50944 (2022-004)

Significant Deficiency 2022

Meeker Memorial Hospital

MN

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Finding 2021-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution Federal Financial Assistance Listing #93.498 Significant Deficiency Compliance Requirement: 2 CFR 200.303(a) establishes that the aud...

Finding 2021-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution Federal Financial Assistance Listing #93.498 Significant Deficiency Compliance Requirement: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Finding Summary: The Hospital did not have an adequate internal control policy in place to ensure review and approval of the lost revenue calculation and report submitted to the Department of Health and Human Services for Period 4. Responsible Individuals: Nicole Siegner, CFO Status: Management will enhanced internal controls to ensure lost revenue calculations and reporting submissions to HRSA were reviewed by an individual other than the preparer and documentation of approval was maintained.

View Audit 51724

Finding 50935 (2022-102)

Material Weakness 2022

Nevada Legal Services, Inc.

NV

Allowable Costs / Cost Principles Material Weakness

Name of contact person: Peter Wetherall, Esq., Executive Director Corrective Action: Nevada Legal Services, Inc. agrees with the finding. A monthly close list of activities has been developed which includes specific steps to be followed each month to review the statement of activities by class and e...

Name of contact person: Peter Wetherall, Esq., Executive Director Corrective Action: Nevada Legal Services, Inc. agrees with the finding. A monthly close list of activities has been developed which includes specific steps to be followed each month to review the statement of activities by class and ensure that after indirect cost allocations have been made, the indirect expense account codes are $0 indicating everything in the indirect cost pool has been allocated. Proposed Completion Date: Fully corrected prior to release of December 31, 2022 audit.

View Audit 48954

Finding 50927 (2022-003)

Material Weakness 2022

Flagler Hospital, Inc. and Subsidiaries

FL

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Condition: The System?s controls in place for subrecipient payments did not ensure that subrecipients were paid within the required 30 day window. Planned Corrective Action: The System will review and enhance its grant agreement review process by implementing controls to grant agreements are thoroug...

Condition: The System?s controls in place for subrecipient payments did not ensure that subrecipients were paid within the required 30 day window. Planned Corrective Action: The System will review and enhance its grant agreement review process by implementing controls to grant agreements are thoroughly reviewed and are adhering to all the compliance requirements. Contact person responsible for corrective action: Paige Stanton Anticipated Completion Date: 6/30/24

View Audit 46814

Finding 50923 (2022-001)

Significant Deficiency 2022

Verde Valley Sanctuary, Inc.

AZ

Allowable Costs / Cost Principles Reporting Cash Management § 200.510

Finding Number: 2022-001 Program Name/Assistance Listing Titles: Crime Victim Assistance; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Assistance Listing Numbers: 16.575, 93.671 Contact Person: Jessica Bryson, Finance Administrator Anticipated Completion ...

Finding Number: 2022-001 Program Name/Assistance Listing Titles: Crime Victim Assistance; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Assistance Listing Numbers: 16.575, 93.671 Contact Person: Jessica Bryson, Finance Administrator Anticipated Completion Date: Completed effective October 2022 Planned Corrective Action: During the audited fiscal year, the organization experienced significant staff turnover in the Finance Department. As a result, the methodology of accounting relative to class/customer tracking changed part-way through the year. This resulted in the inability to immediately produce documentation from the financial reporting software that corroborated the grant billings. Although the organization is confident that expenses were billed to appropriate grants throughout the year (due to backup documentation in the grant billing portals), the organization?s financial software did not directly reflect this. To correct this problem, a new class/customer tracking system has been established to ensure that the financial reporting software more accurately tracks expenditures related to Federal Awards and organizational programs. Furthermore, grant billings are regularly reviewed by an independent accounting firm, the organizations Treasurer, and/or the Executive Director to ensure proper coding/tracking.

View Audit 41296

Finding 50915 (2022-005)

Significant Deficiency 2022

Tennessee Wildlife Resources Foundation, Inc.

TN

Equipment & Real Property Management Allowable Costs / Cost Principles

Finding 5: Controls over Equipment Purchases for Federal Programs (2022-05) 5.1 Ac3on Plan To address the identified issues regarding the controls over equipment purchases for federal programs, the organization will take the following steps: ? Development of Policy: Develop a flexible yet comprehens...

Finding 5: Controls over Equipment Purchases for Federal Programs (2022-05) 5.1 Ac3on Plan To address the identified issues regarding the controls over equipment purchases for federal programs, the organization will take the following steps: ? Development of Policy: Develop a flexible yet comprehensive policy that outlines the procedures and controls over equipment purchases for federal programs. This policy will provide guidelines on the allowable conditions for equipment purchases and usage, keeping in mind the diverse geographical locations of operations. The policy will be designed to accommodate long-distance equipment purchasing and monitoring, ensuring feasibility and compliance without compromising operational efficiency. ? Inventory Management: Incorporate procedures for periodic physical inventory of the equipment to ensure accurate tracking and compliance with federal requirements. ? Monitoring and Compliance: Establish mechanisms for regular monitoring of equipment purchases to prevent the charging of potentially unallowable costs to federal programs. Page 46 5.2 Responsible Personnel The newly appointed Grants Manager, who is also overseeing the corrective actions for the other findings, will be responsible for implementing and monitoring the new policy. Their extensive experience of over 20 years in grant management equips them with the necessary skills and knowledge to effectively manage this task. 5.3 Resources and Tools The organization will leverage its existing resources, including the custom-built grant management solution and QuickBooks Online, to facilitate the monitoring of equipment purchases and the management of the periodic physical inventory. 5.4 Implementa3on Timeline The organization plans to initiate the implementation of the corrective actions immediately, with the aim to have the new policy fully operational by the end of Q4 2023. 5.5 Training and Support Training programs will be developed to assist the Grants Manager and other relevant personnel in adapting to the new policy protocols. This will include training on the procedures for equipment purchases and inventory management. 5.6 Monitoring and Evalua3on A monitoring and evaluation system will be established to assess the effectiveness of the new policy. This system will involve regular reviews to ensure compliance with the policy and federal requirements, thereby safeguarding the organization from potential discrepancies and unallowable costs.

View Audit 44500

Finding 50912 (2022-004)

Significant Deficiency 2022

Tennessee Wildlife Resources Foundation, Inc.

TN

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

Finding 4: Policy for Indirect Costs and Monitoring of that Policy (2022- 04) 4.1 Action Plan To address the identified issues regarding the policy for indirect costs and monitoring of that policy, the organization will take the following steps: ? Formalization of Policy: Develop and formalize a ...

Finding 4: Policy for Indirect Costs and Monitoring of that Policy (2022- 04) 4.1 Action Plan To address the identified issues regarding the policy for indirect costs and monitoring of that policy, the organization will take the following steps: ? Formalization of Policy: Develop and formalize a policy to consistently charge a de minimis rate of 10% for indirect costs on all federal programs. This policy will replace the previous practice of determining indirect costs on a case-by-case or grant-by-grant basis. ? Documentation of Base Rate: Document the base rate for modi?ed total direct costs to establish a clear and consistent basis for calculating the 10% de minimis rate. ? Monitoring and Compliance: Implement procedures for monitoring compliance with the new policy, including regular reviews to ensure that the 10% rate is being applied consistently across all federal programs. 4.2 Responsible Personnel The newly hired Grants Manager, along with the executive management team, will be responsible for ensuring compliance with the new policy. Their responsibilities will include overseeing the implementation of the policy and monitoring its adherence across all relevant programs. 4.3 Resources and Tools Page 45 The organization will leverage its existing resources, including the custom-built grant management solution and QuickBooks Online, to facilitate the implementation and monitoring of the new policy. 4.4 Implementa3on Timeline The organization plans to implement the new policy immediately, applying the 10% de minimis rate to all new grants moving forward without delay. 4.5 Training and Support The organization will provide necessary training and support to the Grants Manager and other relevant personnel to ensure a smooth transition to the new policy protocols. This will include training on the calculation and application of the 10% de minimis rate. 4.6 Monitoring and Evalua3on A monitoring and evaluation mechanism will be established to assess the e?ectiveness of the new policy. This will involve regular reviews to ensure consistent application of the 10% rate and compliance with federal requirements, thereby preventing the charging of potentially unallowable costs to federal programs.

View Audit 44500

Finding 50905 (2022-001)

Material Weakness 2022

Kelso School District No. 458

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kelso School District No. 458 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Fede...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kelso School District No. 458 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District 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: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Scott Westlund, Chief Financial & Operations Officer 601 Crawford, Kelso WA, 98626 (360) 501-1903 Corrective action the auditee plans to take in response to the finding: The Kelso School District appreciates the State Auditor?s Office review of the Davis-Bacon Act requirements in our use of federal funding for the Huntington Middle School construction project. The Kelso School District agrees with the auditor?s finding that more frequent monitoring of wage and payroll certifications is necessary to conform to Davis-Bacon Act. We realize that our reliance on the State of Washington?s Labor and Industries prevailing wage and payroll certifications site (where wage and certification data is submitted and stored) will require weekly review of submitted contractor payrolls and certifications. As we move forward into two additional construction projects utilizing federal funds, we will ensure our project management team provides weekly oversight of contractor compliance, collects weekly certifications and payrolls, and provides Kelso School District with required documentation. Anticipated date to complete the corrective action: Currently in place

View Audit 44228

Finding 50889 (2022-001)

Material Weakness 2022

Cheney School District No. 360

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cheney School District No. 360 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regu...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cheney School District No. 360 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District 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: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Jamie Reed, Director of Finance 12414 S. Andrus Road (509) 559-4501 Corrective action the auditee plans to take in response to the finding: Although the District does not concur with the finding or questioned costs as detailed in the response to the finding, we are taking this finding seriously and will implement stronger internal controls and ensure compliance in the future. In addition, we look forward to working with the FCC to resolve this finding. Anticipated date to complete the corrective action: Immediately

View Audit 42227 Questioned Costs: $1

Finding 50884 (2022-003)

None 2022

City of Baton Rouge - Parish of East Baton Rouge

LA

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

2022-003) Allowable Costs and Activities Management?s response and corrective action is as follows: The OCD has policies and procedures in place to prevent and detect fraud in the ERAP and will continue to follow its established policies and procedures. In addition, the ERAP has updated its progr...

2022-003) Allowable Costs and Activities Management?s response and corrective action is as follows: The OCD has policies and procedures in place to prevent and detect fraud in the ERAP and will continue to follow its established policies and procedures. In addition, the ERAP has updated its program guidelines to forbid the provision of rental assistance to any single-family home rentals where the landlord holds homestead exemption. Any other single-family rentals owned by an individual will need to provide proof of payment and receipt of three months of rental assistance via cancelled checks or bank statements. This rule is being implemented due to evidence that most fraud cases involve single-family home rentals owned by individuals. Expected Implementation Date: June 2023 Contact person: Marlee Pittman, Interim Director, Office of Community Development

View Audit 53428 Questioned Costs: $1

Finding 50874 (2022-007)

Significant Deficiency 2022

City of Baton Rouge - Parish of East Baton Rouge

LA

Allowable Costs / Cost Principles

2022-007) Internal Controls for Allowable Costs Management?s response and corrective action is as follows: The City-Parish transitioned the administration of the OCD in late 2021 throughout 2022. The new leadership self-identified the need for additional staff training, coaching, and technical as...

2022-007) Internal Controls for Allowable Costs Management?s response and corrective action is as follows: The City-Parish transitioned the administration of the OCD in late 2021 throughout 2022. The new leadership self-identified the need for additional staff training, coaching, and technical assistance and began to invest in individual development plans for all program administrators and analysts. While additional training can only improve knowledge of the Uniform Guidance and reduce the likelihood of internal controls not detecting and preventing unallowable costs to the programs. The OCD provided a sample of reimbursements to the auditors for transactional testing which indicated that no unallowable activities were permitted in 2022. The Office of Community Development had self-identified opportunities for certain process improvements for internal controls to detect issues in backup documentation. The City-Parish procured a software that will serve as the system of record and is currently implementing that new software. Moving forward, the OCD team will have the systems in place to assess, reject, and approve the documentation required from subrecipients more thoroughly and efficiently. Expected Implementation Date: December 2024 Contact person: Marlee Pittman, Interim Director, Office of Community Development

View Audit 53428

Corrective Action Plans

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