Corrective Action Plans

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Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1...
Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): CIP agrees with the finding. To address the finding and prevent recurrence, CIP will: - Revise and strengthen written financial management policies to clearly define documentation requirements to substantiate expenditures and ensure costs are within the award’s period of performance. - Incorporate federal regulation references, including 2 CFR 200.303 (Internal Controls) and 2 CFR 200.344 (Closeout). - Implement a standardized checklist for technical analyst and program managers to confirm that all expenditure documentation includes dates verifying that costs were incurred within the period of performance. - Require a secondary review and sign-off by the CIP Administrator prior to submission of documentation to auditors. - Conduct mandatory annual training for program on federal period of performance requirements and required supporting documentation standards. - Provide refresher sessions before each audit cycle. - Establish a quarterly self-audit of grant files to verify that documentation is complete and properly supports expenditures. - Document results of each review and address deficiencies immediately. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Proposed Completion Date: December 31, 2025
View Audit 371187 Questioned Costs: $1
Finding No.: 2022-013 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Questioned Costs: $1,828,733 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan:...
Finding No.: 2022-013 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Questioned Costs: $1,828,733 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Furthermore, based on our documentation, the Authority to Proceed (ATP) requirement was not fully communicated or operationalized with the relevant agencies until late 2021. During this period, the National Environmental Policy Act (NEPA) compliance processes were nascent for both OGM and the partner agencies, and subsequently required coordination with the U.S. Army Corps of Engineers for proper implementation. Given that these procedural requirements were still in the initial stages of establishment and integration, the CNMI Government should not be deemed liable for noncompliance with obligations that were not yet fully defined or operationalized. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): We respectfully disagree with this finding. Our office has obtained an Authorization to Proceed (ATP) for all projects funded by the Office of Insular Affairs under the 702 Capital Improvement Project (CIP) grants. It appears that supporting documents may not have been provided to the assigned auditor within the required timeframe; however, our office has maintained all ATPs associated with the projects listed in Condition 2. In addition, the Capital Improvement Program has implemented a process to include the Authorization to Proceed when routing contracts for projects procured through sealed bid procurement and sealed proposals. Corrective Action Plan: 1. Centralized Record Submission: - Designate a staff member responsible for ensuring that all ATP supporting documents are submitted to the auditors during scheduled audits. - Create a checklist to confirm that all required ATP documentation is included in audit packets. 2. Process Improvement: - Incorporate a mandatory step in the contract routing process to attach the Authorization to Proceed for all projects procured through sealed bid procurement and sealed proposals. - Update internal procedures to reflect this requirement. Training & Awareness: - Conduct a briefing for CIP staff on the importance of timely submission of ATP documentation to auditors. - Provide refresher training annually to ensure continued compliance. 4. Timeline for Implementation: - Checklist & Process Update: By October 15, 2025 - Staff Training: By October 31, 2025 Proposed Completion Date: December 31, 2025
View Audit 371187 Questioned Costs: $1
Will have a policy for FEMA allowable expenditures in the future
Will have a policy for FEMA allowable expenditures in the future
Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice a...
Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice and Payment Documentation: • All invoices related to the federal program will be promptly reviewed and approved by the appropriate personnel to ensure they reflect allowable costs under the specific terms and conditions of the award. • Management will establish clear procedures for the proper recording and classification of payments, ensuring that they are linked directly to the corresponding federal program expenses. • All supporting documentation (e.g., purchase orders, contracts, receipts) will be retained in electronic formats within the accounting system, in accordance with the Organization’s record retention policy, ensuring availability for future audits or reviews. Retention and Accessibility: • The Organization will maintain a secure, organized filing system for all invoices and payments, ensuring that each record is easily accessible for audit purposes. This system will include electronic records that are stored in a centralized database, with restricted access to authorized personnel. • Retained invoices and payment documentation will be kept for the full duration required by federal regulations, typically for a period of at least seven years after the final expenditure report for the federal award has been submitted, or as otherwise required by the specific federal agency. Periodic Reviews and Monitoring: • To ensure ongoing compliance, Management will perform periodic reviews of federal program expenditures and documentation. This will include random sampling of invoices and payment records to confirm that they are complete, accurate, and in compliance with federal regulations. • In the event of any discrepancies or issues identified during these reviews, Management will take immediate corrective action to address the issue and prevent recurrence. By maintaining thorough records of all invoices and payments, the Organization aims to not only comply with federal audit requirements but also to ensure transparency, accountability, and sound financial management of federal funds.
View Audit 370890 Questioned Costs: $1
Finding 2022-002: Written Uniform Guidance Policies Responsible Individuals: Jeannie Walters, Finance Officer Corrective Action Plan: The Association will develop written Uniform Guidance policies. Anticipated Completion Date: December 31, 2025
Finding 2022-002: Written Uniform Guidance Policies Responsible Individuals: Jeannie Walters, Finance Officer Corrective Action Plan: The Association will develop written Uniform Guidance policies. Anticipated Completion Date: December 31, 2025
Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going f...
Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.
View Audit 370564 Questioned Costs: $1
Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher tra...
Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher training to ensure proper and full use and utilization of its document management system and all other College systems.
Activities Allowed or Unallowed/ Allowable Costs/Cost Principles: The College agrees with the finding. We take note previous corrective actions did not fully resolve the issue. The College will implement monthly/quarterly budget-to-actual reconciliations as a new agenda item during its monthly grant...
Activities Allowed or Unallowed/ Allowable Costs/Cost Principles: The College agrees with the finding. We take note previous corrective actions did not fully resolve the issue. The College will implement monthly/quarterly budget-to-actual reconciliations as a new agenda item during its monthly grant meetings. The College will enforce stricter oversight by the grants office to ensure compliance with allowable cost principles.
View Audit 370531 Questioned Costs: $1
Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student m...
Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student meal listings, as well as discrepancies between paid hours/rates and approved documentation. These gaps arose primarily from inadequate internal controls and the limitations of the previous manual filing system, which hindered timely verification during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily accessible documentation for all program expenditures. Internal controls have been strengthened to require proper supporting documents including signed employment contracts, verified timesheets, approval for incentive and leave payments, and student listings—before any program costs are processed or reported. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure accuracy and compliance. Staff have been trained—and will continue to be trained twice a year—on federal cost principles and documentation standards to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which ma...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which made timely retrieval difficult during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system to improve recordkeeping, accessibility, and documentation retention for all program expenditures. Internal controls have been strengthened to ensure that all stipends, salaries, and benefits charged to the TRIO Upward Bound program are fully supported by proper documentation, verified, and reviewed before payment and reporting. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure compliance. Staff have been trained—and will continue to be trained twice a year—on federal grant cost principles and documentation requirements to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionali...
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionalized a cloud- based filing system to ensure accurate recordkeeping, easy retrieval, and compliance with federal documentation requirements. Internal control procedures have been strengthened, and staff have received proper training, which will continue to be conducted twice a year on compliance with federal allowable cost principles and documentation standards. These measures will prevent recurrence of similar issues and ensure that all federal expenditures are adequately supported and fully compliant going forward.
View Audit 370531 Questioned Costs: $1
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly a...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly aligned with the purpose of the related subgrants. These gaps occurred because of inadequate internal controls and the limitations of the previous manual filing system, which made it difficult to locate and verify supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant- related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff have been trained and will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Views of Responsible Officials and Corrective Action: Us Helping Us has sought consultation from its contract CPA firm regarding this known time management issue. The organization is currently utilizing a payroll allocation system aligned with a time management system approved by current grantors fo...
Views of Responsible Officials and Corrective Action: Us Helping Us has sought consultation from its contract CPA firm regarding this known time management issue. The organization is currently utilizing a payroll allocation system aligned with a time management system approved by current grantors for reimbursements and reporting. Us Helping Us acknowledges the audit finding regarding the organization’s timekeeping and payroll allocation practices. Specifically, the absence of timesheets for each pay period and reliance on budget estimates for payroll allocation does not fully comply with the standards outlined in 2 CFR § 200.430(i) for compensation for personal services. Us Helping Us is in the process of implementing a timesheet system which will be supported by internal controls allowing for accurate, allowable and properly allocated time charges. To address this issue and ensure future compliance, Us Helping Us has implemented the following measures: The organization is to adopt a formal timekeeping policy requiring all employees whose salaries are charged to Federal awards to submit timesheets for each pay period. These timesheets must Reflect 100% of the employee’s compensated activities, be signed by both the employee and their supervisor, and distinguish between Federal and non-Federal activities. For employees working exclusively on a single Federal award, and for those working across multiple funding sources, detailed timesheets will be required for each pay period. While budget estimates may be used for interim accounting purposes, we now perform reconciliations to compare budgeted payroll allocations with actual time worked. Adjustments are made if discrepancies exceed 10% Staff involved in payroll and grant management will have received training on Federal time and effort reporting standards. We have also implemented internal controls to ensure consistent documentation and review. The system will comply with established accounting practices of Us Helping Us and reflect the total activity for which employees are compensated. The system will support the distribution of the Us Helping Us employee salaries among cost objectives, Federal awards, non-Federal awards, indirect and direct cost activities. The system will also allow for the appropriate maintenance of record keeping activities and supporting documentation. Us Helping Us’ financial policies have been updated to include requirements for time and effort documentation per 2 CFR § 200.430(i), procedures for reconciling payroll allocations with actual time worked and documentation retention standards aligned with 2 CFR § 200.302(b)(3). Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that personnel costs charged to Federal awards are accurate, allowable, and properly documented. The Executive Director and the Deputy Executive Director for Finance and Administration will be responsible for this Plan and will be effective immediately.
Management will be working with a consultant to update their written policies and procedures to be in compliance with the requirements of the Uniform Guidance.
Management will be working with a consultant to update their written policies and procedures to be in compliance with the requirements of the Uniform Guidance.
Management will ensure that all nongrant expenditures are kept to a minimum until the cash balance of NVT is in excess of the unearned grant revenue and restricted fund balance. A large part of this problem in the current year was the amount of money paid to the Village’s accountants/consultant in p...
Management will ensure that all nongrant expenditures are kept to a minimum until the cash balance of NVT is in excess of the unearned grant revenue and restricted fund balance. A large part of this problem in the current year was the amount of money paid to the Village’s accountants/consultant in prior years. This has been resolved and the new accountant’s fees are much more in line with reasonable amounts.
The organization contracted with an independent CPA and engaged that firm to conduct the omitted Single Audits, as soon as the oversight was brought to the organization's attention (by the new firm). The Single Audits were conducted for both 2021 and 2022 and were being submitted at the same time. T...
The organization contracted with an independent CPA and engaged that firm to conduct the omitted Single Audits, as soon as the oversight was brought to the organization's attention (by the new firm). The Single Audits were conducted for both 2021 and 2022 and were being submitted at the same time. The organization has also reviewed Federal guidelines, bond covenants and other details. The organization has created new internal control policies and has documented these. Further, they have discussed the requirements and importance with management and governance. They have designed policies to monitor and review this area to ensure future compliance.
In a previous period and by previous auditors, PAX was told that because we were using a percentage of effort calculation in budgeting that time sheets were no longer needed for this purpose. At that time, we abandoned the time sheet process (which was arduous). Based upon current auditor’s advice, ...
In a previous period and by previous auditors, PAX was told that because we were using a percentage of effort calculation in budgeting that time sheets were no longer needed for this purpose. At that time, we abandoned the time sheet process (which was arduous). Based upon current auditor’s advice, PAX established an effort verification reporting system. This system was launched in FY23 and enhanced in FY24. It will accurately capture the effort spent by each employee on specific grants, ensuring proper documentation of allocation of wages and salaries to the respective federal awards.
View Audit 370331 Questioned Costs: $1
The Government concurs with the auditor's findings and recommendations. Isolated occurrence while the MAP program was being transitioned from one building to another. As the equipment could not be used at the new location, it was stored for future use. The Director of Asset Management has oversight ...
The Government concurs with the auditor's findings and recommendations. Isolated occurrence while the MAP program was being transitioned from one building to another. As the equipment could not be used at the new location, it was stored for future use. The Director of Asset Management has oversight of the storage of inventory to avert future occurrences.
View Audit 369907 Questioned Costs: $1
The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available ...
The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available for transactions entries or liquidations. Additionally, a dedicated Fiscal Analyst is being inserted into the workflow to ensure compliance.
View Audit 369907 Questioned Costs: $1
The Government concurs with the auditor's findings and recommendations. The Stats Timeforce system has been implemented. Time and attendance are no longer a manual process eliminating these types of variance. The system is automated wherein designated employees utilize a fingerprint to log their tim...
The Government concurs with the auditor's findings and recommendations. The Stats Timeforce system has been implemented. Time and attendance are no longer a manual process eliminating these types of variance. The system is automated wherein designated employees utilize a fingerprint to log their time. The time once vetted and approved, is released to the Department of Finance for check processing. The process is automated to fall in line with designed ERP cost center listed on the employee's Notice of Personnel Action. Invoice transactions are vetted by the CFO. Any transactions over $50K is then approved by the Commissioner or her designee.
The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.
The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.
The Government concurs with the auditor's findings and recommendations. The Division of Human Resources is now adjusting the Notice of Personnel Actions to reflect the requisite Project code at the beginning of each Fiscal year.
The Government concurs with the auditor's findings and recommendations. The Division of Human Resources is now adjusting the Notice of Personnel Actions to reflect the requisite Project code at the beginning of each Fiscal year.
The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.
The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.
View Audit 369907 Questioned Costs: $1
The Government concurs with the auditor's findings and recommendations. DOJ will ensure each timesheet contains approval by the respective employee’s supervisor before it is forwarded to DOF Payroll Division for processing.
The Government concurs with the auditor's findings and recommendations. DOJ will ensure each timesheet contains approval by the respective employee’s supervisor before it is forwarded to DOF Payroll Division for processing.
The Government concurs with the auditor's findings and recommendations. DOH fully acknowledge and accept the auditor’s finding regarding DOH’s inability to reconcile the payroll expenses listed in the SEFA with those documented in the payroll register. This discrepancy arose because payroll adjustme...
The Government concurs with the auditor's findings and recommendations. DOH fully acknowledge and accept the auditor’s finding regarding DOH’s inability to reconcile the payroll expenses listed in the SEFA with those documented in the payroll register. This discrepancy arose because payroll adjustments were not completed in time to reflect accurately in the FY2022 SEFA. To address this, DOH team has received thorough training, and staff members now have the necessary access to make payroll adjustments in the Government Financial Management System as of FY2024. Moving forward, DOH will strengthen our SOPs by conducting monthly reconciliation meetings with all relevant program teams to ensure timely adjustments and continuous monitoring. Additionally, DOH will update procedures to guarantee that all new fiscal staff are granted complete financial system access and are trained on reconciliation and adjustment processes within two weeks of starting.
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